PRIVACY POLICY

This Policy discloses the privacy practices for Cerebrum Technology’s website (the “Site”), as well as related products and services we may offer to you (the “Service”). This Policy also covers how personal and other information that we receive or collect about you and your clients (“Clients”) is treated. Please read the information below to learn the following regarding your use of this Site.

We reserve the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on our site, and by updating any privacy information on this page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your (a) acknowledgment of the modified Policy; and (b) your agreement to abide and be bound by that Policy.

IMPORTANT: BY USING THE SITE AND/OR OFFERINGS AVAILABLE ON THIS SITE, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED BELOW. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS, DO NOT USE THE SITE.

1. Types of Information We Collect

In order to better provide you with our Service, we collect two types of information about our users: Personally Identifiable Information (“PII”) and Aggregate Information

Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities on this Site, such as registering for an account, downloading or purchasing a product or service, submitting content and/or posting content in a public forum on this Site, or sending us feedback, we may ask you to provide certain information about yourself.

Examples of PII may include your first and last name, email address, mailing address (including postal/zip code), employer, job title and department, telephone and facsimile numbers, and other identifying information. When ordering products or services on the Site, you may be asked to provide a credit card number.

Aggregate Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our Site and what other sites may have directed you to us. This information, which is collected in a variety of different ways, is compiled and analysed on both a personal and an aggregated basis. This information may include the Website’s Uniform Resource Locator (“URL”) that points to the site you just came from, which URL you go to after visiting our Site, what browser you are using, and your Internet Protocol (“IP”) address.

2. How We Collect and Use Information

Cerebrum Technology do not collect any PII about you unless you voluntarily provide it to us. However, you may be required to provide certain PII to us when you elect to use certain products or services available on the Site. These may include: (a) registering for an account on our Site; (b) uploading individual transaction data obtained from your third-party invoicing or accounting applications (for example, “QuickBooks,” “Xero,” “Clio” etc.), (c) uploading user generated content and other information uploaded to the Site (d)sending us an email message; (e) submitting a form or transmitting other information by telephone or letter; or (e) submitting your credit card or other payment information when ordering and purchasing products and services on our Site.

We will primarily use your PII to provide product or service offerings to you. We will also use certain forms of PII to enhance the operation of our Site, improve our internal marketing and promotional efforts, statistically analyse Site use, improve our product and service offerings, and customize our Site’s content, layout, and services. We may use certain information about you without identifying you as an individual to third parties. We do this for purposes such as analysing how the Service is used, diagnosing service or technical problems, maintaining security, and personalising content. We may also use PII to deliver information to you and to contact you regarding administrative notices. Finally, we may use your PII to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Site Terms of Use, and this Privacy Policy.

We may also collect or our third party advertising partners may collect, certain Aggregate Information. For example, we may use your IP address to diagnose problems with our servers, software, to administer our Site and to gather demographic information. Our third party advertising partners may also provide us with aggregate, but not individual, reports that will tell us how many ads were presented and clicked upon at out Site.

3. Cookies

Depending on how you use our Site, we will store cookies on your computer in order to collect certain aggregate data about our users and to customize certain aspects of your specific user experience. A cookie is a small data text file which is stored on your computer that uniquely identifies your browser. Cookies may also include more personalized information, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and your first name to welcome you back to our Site. We may use cookies to perform tasks such as: monitoring aggregate site usage metrics, storing and remembering your passwords (if you allow us to do so), storing account and advertising preferences that you have set, and personalizing the Services we make available to you. However, we do not use cookies to track your browsing behaviours.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some aspects of the Site may not function properly if you elect to disable cookies.

4. Release of Information

Cerebrum Technology will not sell, trade, or rent your PII to others. We do provide some of our product and service offerings through contractual arrangements made with affiliates, service providers, partners and other third parties (“Service Partners”). We and our Service Partners may need to use some PII in order to perform tasks between our respective sites, or to deliver products or services to you. For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on this Site; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us provide customer service.

We will encourage our Service Partners to adopt and promote strong privacy policies. However, the use of your PII by our Service Partners is governed the respective privacy policies of those providers, and is not subject to our control. Except as otherwise discussed in this Privacy Policy, this document only addresses the use and disclosure of information we collect from you. Other Sites accessible through this Site, including our Advertising and Service Partners, have their own privacy policies and data collection, use and disclosure practices. Please consult each Site’s privacy policy. We are not responsible for the policies or practices of third parties

Occasionally we may be required by law enforcement or judicial authorities to provide PII to the appropriate governmental authorities. In such cases, we will disclose PII upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

We may also provide Aggregate Information about our customers’ sales, traffic patterns, and related Site information to third party advertisers, but these statistics do not include any Personally Identifiable Information.

5. Updating and Correcting Information

We believe you should have the ability to access and edit the PII that you have provided to us. You may change any of your PII in your account online at any time by linking to your account in accordance with instructions posted elsewhere on this Site.

We encourage you to promptly update your PII if it changes. You may ask to have the information on your account deleted or removed; however, some information, such as past transactions, logs of technical support calls, or other information may not be deleted. In addition, it may be impossible to completely delete your information without some residual information because of backups.

6. User Choices on Collection and Use of Information

We may, from time to time, send you email regarding new products and services that we feel may interest you. In addition, if you indicated upon registration that you are interested in receiving offers or information from us and our partners, we may occasionally call or send you direct mail about products and services that may be of interest to you. Only Cerebrum Technology (or agents working on behalf of Cerebrum Technology and under confidentiality agreements) will send you these solicitations, and only if you have previously indicated that you wish to receive them. If you do not want to receive solicitations from us, you can “opt-out” by accessing your account online editing your account information to no longer receive such offers and mailings.

You also have choices with respect to cookies, as described above. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of our Site may not work properly in your case.

7. Security of Your PII

At our Site you can be assured that your PII is secure, consistent with current industry standards. We strive to take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of your PII. For example:

• We work hard to ensure that the data we collect is reliable, accurate, complete and current. We encrypt all PII, in order to prevent unauthorized parties from viewing such information when it is transmitted to us. We also only keep collected information: only for as long as reasonably necessary and use it only for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.

• We limit access to PII only to specific employees, contractors and agents who have a reasonable need to come into contact with your information. For example, we may provide members of our technical support team with limited access to your account in order to allow them to troubleshoot problems you may be having with the Site.

• Additionally, we also employ a number of physical, electronic, and procedural safeguards to protect PII. Our secure servers and our data centres are protected by industry-standard encryption, and our servers reside behind firewalls and employ high-level password protection.

• Finally, access by you to your PII is available through a password and unique customer ID selected by you. This password is encrypted. We recommend that you do not divulge your password to anyone.

In order to most effectively serve you, credit card transactions and order fulfilment are handled by established third party banking institutions and processing agents (such as e.g. PayPal). They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your PII, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed. As we have no control or ability to monitor the security of your device, you should take measures reasonably available to secure your device.

In the event that PII is compromised as a result of a breach of security, Cerebrum Technology will promptly notify those persons whose PII has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, by email, or as otherwise required by applicable law. You agree to immediately notify us and your Clients if you have experienced a breach of security on your device which may have affected the security of our Site or Service.

8. Miscellaneous

You must be at least 18 years old to have our permission to use this Site. By agreeing to Our Policy, you are hereby confirming that you are at least of 18 years old. Our policy is that we do not knowingly collect, use or disclose PII about minor visitors.

You should also be aware that when Personally Identifiable Information is voluntarily disclosed (i.e. your name, email address, etc.) in the discussion forums or other public areas on this Site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages (including unwanted spam messages) from third parties. Such activities are beyond our control and this Policy does not apply to such information. Please consult our Site Terms and Conditions of Use Agreement for our Site Conduct policies.

If you have any questions, concerns or inquiries about our Privacy Policy, or our use of your PII, or our privacy practices, please contact us at: [email protected]. You can also reach our Privacy Compliance Officer by sending written correspondence to:

Cerebrum Technology

Email: [email protected]

Attn: Privacy Compliance Officer

9. GDPR: European or UK data subjects

Our clients use the Cerebrum Technology software to collect and process the personal data of individuals, which may include individuals in the EU and/or the UK. In particular, they use the software to manage their marketing lists and campaigns, which includes the processing of the personal data of their customers.

For the purposes of the GDPR (and the UK GDPR) Cerebrum Technology acts as a processor of the personal data of data subjects. The controller of the data subjects’ personal data is either our client, or the customers of our client.

We only process such personal data in accordance with the instructions of our client and in compliance with our obligations as a processor. We ensure that a data processing agreement is entered into between us and our client in order to ensure that appropriate safeguards are in place.

Updated: November 27, 2023