VIRTUALITICS, INC. PRIVACY POLICY

Last Updated: May 29, 2018

This Privacy Policy explains how Virtualitics, Inc. (“Virtualitics”) collects, uses, and discloses information about you through its website, software application (the “Software”) and other online products and services (collectively, the “Services”)
or when you otherwise interact with us.

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage
or sending you a notification).  We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us.  For example, we collect information when you create an account, participate in any interactive features of the Services, fill out a form, purchase a license to the Software, request customer support or otherwise communicate with us.  The types of information we may collect include your name, email address, company or employer information, financial information in connection with purchasing a Software license, job title, phone number and any other information you choose to provide.

Information About Your Use of the Services

Usage Information

We collect information about your use of the Services, such as Software functionality and analytics (with your consent) and the amount of data transferred in using our Services.

Automatically Collected Information

When you access or use our Services, we automatically collect information about you, including:

  • Log Information:  We collect log information about your use of the Services, including the type of browser you use, Software version, access times, pages viewed, your IP address, and your MAC address.
  • Device Information:  We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and your MAC address.
  • Information Collected by Cookies and Other Tracking Technologies: We use different technologies to collect information, including cookies.  Cookies are small data files stored on your hard drive or in device memory that help
    us improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies and how to disable them, please see “Your Choices” below.
  • Use of Information

    We use the information we collect to provide, maintain, and improve our Services, such as to register, administer, and secure your account and make the Services available to you.  We may also use the information we collect to:

  • Send you technical notices, updates, security alerts and support and administrative messages and to respond to your comments, questions and customer service requests;
  • Communicate with you about releases, products, services, and offers;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Detect, investigate, and prevent fraud and other illegal activities and protect the rights and property of Virtualitics and others;
  • Personalize and improve the Services;
  • Comply with our legal obligations;
  • Enforce, or otherwise use in connection with, any terms governing use of our Services; and carry out any other purpose described to you at the time the information was collected.
  • Sharing of Information

    We will not share data except in the following circumstances:

  • With other users of our Software at your direction or with your consent;
  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Virtualitics or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • Between and among Virtualitics and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
  • With your consent or at your direction.
  • We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

    Advertising and Analytics Services Provided by Others

    We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications.  These entities may use cookies, web beacons, device identifiers and other technologies to collect information
    about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information.  This information
    may be used by Virtualitics and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand
    your online activity.  For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices
    If you are a resident of the EEA (defined below), you may have additional choices.  Please visit http://youronlinechoices.eu/ for more information.

    Data Retention

    We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it.  We may retain certain information for legitimate business purposes or as required by law.

     

    Transfer of Information to the U.S. and Other Countries

    Virtualitics is based in the United States and we process and store information in the U.S.  As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent
    levels of data protection as your home jurisdiction.  We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.

    Residents of the European Economic Area

    If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.

    Legal Basis for Processing

    If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:

  • We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the Virtualitics Services you have requested).
  • We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about releases or changes to our Services, and to provide, secure, and improve
    our Services.
  • Data Subject Requests

    If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred.  You may also have the right to object to, or request that we restrict,
    certain processing.  If you would like to exercise any of these rights, you may contact us as indicated below.

    Questions or Complaints

    If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside.  For contact details of your
    local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm, http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

    Your Choices

    Account Information

    You may update, correct or delete information about you at any time by emailing us at info@virtualitics.com.  If you wish to deactivate your account, please email us at info@virtualitics.com, but note that we may retain certain information
    as required by law or for legitimate business purposes.  We may also retain cached or archived copies of information about you in connection with our data retention policies.

    Cookies

    Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  Please note that if you choose to remove or reject cookies, this could affect the
    availability and functionality of some of our Services.

    Promotional Communications

    You may opt out of receiving promotional emails from Virtualitics by following the instructions in those emails or by emailing us at info@virtualitics.com.  If you opt out, we may still send you non-promotional emails, such as those about your
    account or our ongoing business relations.

    Contact Us

    If you have any questions about this Privacy Policy, please contact us at: Virtualitics Inc, 225 S. Lake Avenue Suite 120, Pasadena, CA, 91101 (info@virtualitics.com) .