Introduction

RangeMe America LLC (together with its affiliates, “RangeMe”, “we”, “us”, and “our”) respects individual privacy and values the confidence of its clients, customers, employees, and business partners. RangeMe complies with the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, lawfulness of processing, notice, choice, onward transfer, security, access, rectification, erasure, portability and enforcement required under applicable laws, rules and regulations, including the GDPR.

This Privacy Statement (the “Statement”) sets forth the privacy principles that RangeMe follows.

Scope

This Statement applies to personal information received by RangeMe in any format, including electronic, paper, or verbal.

Privacy Principles

The privacy principles of RangeMe are:

Lawfulness, Fairness, and Transparency

When RangeMe collects personal information, it will be processed lawfully, fairly, and in a transparent manner in relation to the data subject.

Purpose Limitation

When RangeMe collects personal information, it will be collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

Data Minimization

When RangeMe collects personal information, it will be adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.

Accuracy

When RangeMe collects personal information, it will be accurate and, where necessary, kept up to date; reasonable steps will be taken to ensure that personal information that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without unreasonable delay.

Storage Limitation

When RangeMe collects personal information, it will be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information is processed.

Integrity and Confidentiality

When RangeMe collects personal information, it will take measures designed to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage.

Lawfulness of Processing

Any and all processing will be done lawfully. RangeMe will process personal information only if and to the extent that at least one of the following applies: (1) the data subject has given consent to the processing of his or her personal information for one or more specific purposes; (2) processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract; (3) processing is necessary for compliance with a legal obligation to which the data controller is subject; (4) processing is necessary in order to protect the vital interests of the data subject or of another natural person; (5) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and (6) processing is in the legitimate interests pursued by RangeMe or by a third party.

Information Collected

As you interact with RangeMe, there may be opportunities for you to provide us with your information. Additionally, we may collect certain information about you as further described below.

We may also obtain information from other sources and combine that with information we collect from you. For example, we may collect information about you from third parties, including, but not limited to, our affiliates, identity verification services, and credit bureaus.

The types of information that RangeMe collects about you may include, but are not limited to:

• Contact information (such as name, address, city, state and ZIP code, age or date of birth, occupation, email address and telephone number);
• Information about your connected devices (such as mobile phone, computer, or tablet) and how you interact with our services, apps, and websites (such as IP address, browser type, unique device identifier, cookie data, and associated identifying and usage information);
• Demographic information (such as gender and date of birth);
• Marketing and business profile information;
• Business contact information, including names, job titles, email address and phone number, for employees or other business representatives;
• Payment and financial information; and
• Photographs and videos such as those that you may submit to aid in product, retailer and vendor discovery on our online platform.

How We Use and Disclose Information

We use and disclose personal information you provide to us as described to you at the point of collection. We also use and transfer personal information from or about you:

• to respond to your inquiries and fulfill your requests, such as to send you documents you request or e-mail;
• to send you important information regarding our relationship with you, changes to our terms, conditions, and policies and/or other administrative information;
• for the purpose for which the information was collected, for example, to facilitate orders for products and to otherwise provide our services to you;
• for our business purposes, such as marketing new products, events, and services, data analysis, audits, developing new products, events, or services, operating or enhancing our website, improving our products, events, and services, identifying usage trends, providing products, events, and services, maintaining customer/client relationships, improving the quality, safety, and security of our products, events, and services, administering your account(s), troubleshooting, supporting electronic signature, customizing and improving communication content, evaluating product, event, or service performance, providing customer support, and determining the effectiveness of our website;
• with other users of our services, as you may request;
• to our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, credit card processing, IT services, e-mail services, marketing services, auditing services, and other services, in order to enable them to provide services;
• to verify your information and authenticate payments and process orders, such as disclosing certain financial and other information you provide to RangeMe to third parties that provide credit reporting, payment or order fulfillment services;
• to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
• when we otherwise have your consent.

In addition, we use and disclose personal information as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our website Terms of Service; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We also use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

Choice

RangeMe will give individuals the opportunity to affirmatively and explicitly consent (opt in) to the disclosure of certain sensitive personal information to a third party or the use of the personal information or sensitive personal information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. RangeMe will provide individuals with reasonable mechanisms to exercise their choices in regard to personal information

Your California Privacy Rights

Under California’s “Shine the Light Law”, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

To obtain this information on behalf of RangeMe, please send an email message to support@rangeme.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in the response. Please be aware that not all information is covered by the “Shine the Light “ requirements and only information on covered sharing will be included in our response.

Security

RangeMe will take reasonable steps to protect the personal information in its possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction, and will take precautions with regard to the nature of the data and the risks of the processing, to preserve the security of the data and, in particular, prevent its alteration and damage or access by non-authorized third parties. RangeMe has put in place technical, physical, and organizational procedures and security measures designed to safeguard and secure the personal information from destruction, loss, alteration, unauthorized access or disclosure, or other forms of unauthorized or unlawful processing commensurate with the risks posed by the particular type of processing, the nature of the personal information and in accordance with applicable law and guidelines, if any, promulgated by authorities having jurisdiction therefor, and taking into consideration the cost of implementing such measures. RangeMe cannot guarantee the security of personal information on or transmitted via the Internet.

RangeMe will comply with the General Data Protection Regulation (“GDPR”) and other applicable local laws, rules and regulations with respect to data breach disclosure and notification.

Access

Upon request by the individual, if required by applicable law, RangeMe will grant individuals reasonable access to their personal information. Such access may include: (1) confirmation as to whether or not personal information concerning him or her are being processed; (2) the purposes of the processing; (3) the categories of personal information concerned; (4) the recipients or categories of recipient to whom the processing data have been or will be disclosed, in particular recipients in third countries or international organizations; (5) if possible, the period for which the personal information will be stored, or, if not possible, the criteria used to determine that period; (6) the existence of the right to request from RangeMe rectification or erasure of personal information or restriction of processing of personal information concerning the data subject or to object to such processing; (7) the right to lodge a complaint with a supervisory authority; (8) information about the source of the data, if not directly from the data subject; (9) whether the personal information will be subject to automated processing, including profiling and, if so, the logic and potential consequences involved; and (10) if the data is transferred to a third country or international organization, information about the safeguards that apply.

Rectification

If the data subject requests, personal information collected by RangeMe will be corrected based on information provided by the data subject. Where necessary, RangeMe will take steps to validate the information by the data subject to ensure that it is accurate before amending it.

Erasure

If the data subject requests, their personal information collected by RangeMe will be erased without undue delay provided that one of the following applies: (1) the personal information is no longer necessary for the purposes for which it was collected; (2) the data subject withdraws consent and there is no other legal ground for processing; (3) if required by applicable law, the data subject objects to the processing of the personal information; (4) the personal information have been unlawfully processed; (5) the personal information has to be erased for compliance with a legal obligation of RangeMe; or (6) where the personal information was relevant to the data subject as a child.

Portability

If required by applicable law, upon the data subject’s request, their personal information collected by RangeMe will be provided to them in a structured, commonly-used and machine readable or the personal information transferred to another party.

Enforcement

RangeMe will use a self-assessment approach to verify compliance with this Statement and periodically verify that the Statement is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible, and in conformity with applicable law.

RangeMe encourages interested persons to raise any concerns using the contact information provided in this Statement. RangeMe will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with this Statement. Any employee of RangeMe that RangeMe determines is in violation of this Statement will be subject to disciplinary action up to and including termination of employment.

RangeMe will (1) provide recourse to data subjects with respect to enforcement of this Statement; (2) provide follow up procedures for verifying that the attestations and assertions RangeMe has made about its privacy practices are true; and (3) remedy problems arising from the failure of RangeMe to comply with this Statement.

International Data Subjects

While this Statement applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to RangeMe (“Local Laws”) may require standards which are stricter than this Statement and, in such event, RangeMe will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions. Your personal information may be stored and processed in any country where we have facilities or service providers. Irrespective of which country your personal information is transferred, we would only share your personal information under a ‘need to know’ basis. In these circumstances we will, as required by applicable law, ensure that your privacy rights are protected by organizational, technical, contractual and/or other lawful means.

EU Data Subjects

In the European Economic Area and Switzerland (“EU”), “Personal Data” is defined very broadly and includes any information about a natural person, who can be identified, directly or indirectly, from data that we hold about them or from data that is combined with other information. EU data protection law requires us to have a legal basis before processing any Personal Data about you. The legal bases for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary to for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests. To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. In some circumstances, withdrawing your consent to RangeMe’s use or disclosure of your Personal Data will mean that you cannot take advantage of certain RangeMe products or services.

We may transfer your Personal Data outside the EU to the United States or any country that RangeMe or its service providers may have operations. Such countries do not have the same data protection laws as the EU. Any transfer of your personal information will be subject to a European Commission approved contract (as permitted under the General Data Protection Regulation) that is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To obtain a copy of the such safeguards please contact us.

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• Fair processing of information and transparency over how we use your use personal information
• Access to your personal information and to certain other supplementary information that this Statement is already designed to address
• Require us to correct any mistakes in your information which we hold
• Require the erasure of personal information concerning you in certain situations
• Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• Object at any time to processing of personal information concerning you for direct marketing
• Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• Object in certain other situations to our continued processing of your personal information
• Otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation (or other relevant guidance).

If you would like to exercise any of those rights, please email us at support@rangeme.com with the following:

• Enough information to identify you
• Proof of your identity and address
• The information to which your request relates

How to Complain

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the EU state where you work, normally live, or where any alleged infringement of data protection laws occurred.

Dispute Resolution

In compliance with this Statement, RangeMe commits to resolve complaints about the privacy, collection and use of personal information. Persons with inquiries or complaints about this Statement are encouraged to first contact RangeMe.

Changes to this Statement

This Statement may be amended from time to time, consistent with the requirements of applicable law. A notice will be posted by RangeMe on RangeMe’s Internet website located at www.rangeme.com when this Statement is changed.

Other Policies

RangeMe has other policies that may be applicable to personal information, including the website Privacy Policy.

Contact Information

If you have any questions about this Statement, please contact us by e-mail at support@rangeme.com or write to us at 665 3rd St, Suite 425, San Francisco, CA 94107.

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