INFOREACH, INC. PRIVACY POLICY

This InfoReach, Inc. Privacy Policy was last updated and became effective on August 30, 2018.

This website is operated by InfoReach, Inc. ("InfoReach" or "we", "us", or "our"). This Privacy Policy applies to all of the websites operated by InfoReach, Inc. unless a different policy is provided on a particular site, in which case such different policy shall control. This Privacy Policy is subject to change, so you are encouraged to revisit and review this Privacy Policy from time to time. InfoReach reserves the right to alter, modify, update, add to, subtract from or otherwise change this Privacy Policy at any time for any reason or no reason at all. InfoReach will post any changes here, and any changes will become effective immediately upon being posted unless otherwise indicated in the posted Privacy Policy. We will always date these changes so you know if you are looking at a changed version.

Acceptance:

Please read this Privacy Policy carefully. Your use of this website indicates that you have read and accepted InfoReach's privacy practices, as described in this Privacy Policy. In addition, please review our Terms of Use, which govern your use of this website, and into which this Privacy Policy is incorporated by reference.

This website is operated in the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be collected within the United States. By using our website, participating in any of our services and / or providing InfoReach with your information, you consent to this transfer.

Information That InfoReach Collects and How InfoReach Collects It:

InfoReach collects the following information:

1. Personally identifiable information is information that identifies you or could reasonably be used to identify you personally (such as, but not limited to, your real name, address, phone number, or e-mail address). Providing personally identifiable information is voluntary. You may, however, not be able to use the full functionality of this website if you do not provide certain information. InfoReach collects personally identifiable information that you provide during your use of the website, including:
   • information regarding your account and transactions conducted through our website services, such as executing trades and routing your orders to brokers or otherwise managing a InfoReach user account, including your name and contact information. We use credit card information only to pass on to our credit card processors and do not store the credit card number after the purchase is complete. However, for historic receipt purposes, we do store the card type (Visa, MasterCard, etc.), the last three digits of the card (e.g., xxxx xxxx xxxx x123) and expiration date;
   • information you provide when you sign up for interactive aspects of our website;
   • information you provide when you sign up for any services (e.g., newsletter or marketing offers) offered on the website; and
   • information collected when you contact us via online forms (providing feedback, support queries, sales questions, etc.) or offline methods (e.g., telephone).
   • in some cases, we may ask you for a username and password that should only be known to you.
2. InfoReach Website Cookies: We use cookies, but only to store session information, for keeping your login/password information live (if you so choose) for your account, to limit multiple responses and registrations, to enhance website navigation, and to track usage patterns on the website or to analyze user activity on the site (without tying that information to personally identifiable information, except that your submissions and postings in interactive portions of the website will be stored and available to InfoReach and other users and will include your on-screen identification). Cookies are text files used to identify users and possibly to prepare customized web pages for the user. You may configure your browser to reject cookies but, if you do so, you may not be able to use the full functionality of this website.
3. Web Server Log Information: InfoReach collects non-personally identifiable web log information regarding visitors to its website and each visitor's activity on the website. This information includes, but is not limited to your IP address, the time and date of your visit(s), the pages you visit, the frequency of your visits and the length of stay on each page, your browser type, and information that identifies any linking or referral web page visited prior and /or subsequent to visiting our website.
4. Javascript - InfoReach uses third party web log analysis services (e.g., Google Analytics) for web log analysis and, therefore, non-personally identifiable web log information is transferred to these third parties and stored by them on their servers. These services require the use of Javascript code in our web pages in order to transfer the web log information. We then use this information to track how users interact with, and reach our website. InfoReach's analytics vendors may also transfer this information to other third parties where required to do so by law, or where such third parties process the information on behalf of InfoReach's vendors. By using this website, you consent to the processing of data by these services in the manner and for the purposes set out above.

You may have the opportunity to provide us with the personally identifiable information of a friend (or a friend of yours may provide InfoReach personally identifiable information about you), such as if you chose to email a friend a link, notice or other special feature from InfoReach's website. Any email address that you supply to InfoReach for those activities will not be retained, or used, for other purposes unless otherwise disclosed to you at the time the information is collected. We encourage you to send items from our websites only to recipients who are your friends or family or persons with whom you have a relationship that would expect such information, so that it does not seem like we are soliciting them. You are responsible for obtaining any necessary consent and authorization for sharing any personally identifying information with us. We are not liable for any content that you choose to send to another individual.

Do Not Track Disclosure

Other than as disclosed in this Privacy Policy, we do not track website visitors over time and across third party websites to provide targeted advertising, and therefore do not respond to Do Not Track (DNT) signals. The information we collect automatically is statistical data and does not include personally identifying information.

Information Relating to Children:

The InfoReach website is not directed at children and InfoReach does not knowingly collect any personally identifiable information from children under sixteen (16) years of age unless the collection complies with the Children's Online Privacy Protection Act ("COPPA"). If you are under sixteen (16) years of age, do not send any information about yourself to InfoReach. If InfoReach discovers that a child under the age of 16 has provided InfoReach with personally identifiable information, InfoReach will use commercially reasonable efforts to delete that child's personally identifiable information from its system.

How InfoReach Uses Your Information:

The information we gather and that you provide is collected and used to improve our service to you, and your experience when engaging with our websites and our services. We use personally identifiable information collected from you for the purpose disclosed at the time the information is collected (e.g., we will collect credit card information to process a payment and we will collect contact information to manage your account). We may use personally identifiable information to contact you:

• to provide you with requested information, services or content;
• to route orders to brokers designated by you at the time you execute a trade and to otherwise process your transactions;
• to notify you about InfoReach's new product and services offerings, including software, software releases and services;
• in reference to your licenses to use InfoReach software;
• to enforce the Terms of Use of this website and to address any problems or concerns we have regarding your use of this website; or
• to notify you of changes to this Privacy Policy, our Terms of Use or other policies or terms that affect you and your use of our website.

Although we may use your name and email address to inform you about future products and services, you can always unsubscribe from receiving any marketing emails via the unsubscribe option in any such marketing email you receive from us.

InfoReach may use non-personally identifiable information for many reasons, such as system administration, marketing analysis, to audit use of our website and to report aggregate information to our business partners. InfoReach may associate your IP address or other non-personally identifiable information with personally identifiable information that you provide, but InfoReach will use this aggregated information solely for InfoReach's internal business purposes, subject to this Privacy Policy as it pertains to personally identifiable information. InfoReach may disclose aggregated non-personally identifiable information to third parties.

How InfoReach Shares Your Information

We will not share your personally identifiable information with any third parties, except to process securities trades placed by you, for legal compliance purposes, as described in the "Assignability" section below, to investigate and help prevent security threats and malicious activity, or if you give us your consent. For purposes of the preceding sentence, "legal compliance purposes" includes, without limitation, compliance with laws, cooperation with any governmental (e.g., SEC) and self-regulatory (e.g., exchanges, NASD) investigations and disclosure whenever InfoReach believes disclosure is necessary to limit its legal liability or to protect or enforce the rights, interests, or safety of the website, our users or any third party. If you elect to receive communications from a third party, your information will be subject to the third party's Privacy Policy and not this Privacy Policy. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly.

InfoReach may share personally identifiable and non-personally identifiable information with entities that perform functions on behalf of InfoReach. For example, and without limitation, InfoReach may share your information with entities that host this website, send communications on our behalf, analyze data, and provide customer service. These third parties may have access to your information, including personally identifiable information, only to the extent it is necessary to perform their duties and functions, and subject to this Privacy Policy.

InfoReach's Interactive Areas:

InfoReach may provide interactive areas that allow users to contribute content to the website. If you submit to InfoReach a question, comment, code, work of authorship, photograph or any other content to be published by InfoReach (either online or offline), you agree that we may publish your name or other personally identifiable information in connection with publishing the content.

Please review our restrictions on use and guidelines for interactive areas in our Terms of Use. This Privacy Policy does not apply to any information you may disclose publicly in interactive areas. You should keep in mind that whenever you post information about yourself to a website, that information could be collected and used by people that you do not know. In addition, certain interactive areas may display the message poster's name and message. InfoReach bears no responsibility for any action or policies of any third parties who collect any information that you may disclose in such public areas, if any, of this website.

Your Choices Regarding Your Personally Identifiable Information:

You have the ability at any time to access your InfoReach Account and update your name, contact information, email address, and other information that you provide via a login on the InfoReach website. You should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.

Please also keep in mind that any opt-out choices you make will not apply in situations where: (a) you make a specific request for information from us, or (b) InfoReach uses your personally identifiable information for either operational purposes (e.g. to complete transactions requested by you, or to send you administrative communications either about your account with us or about features of our websites, including any future changes to this Privacy Policy, the Terms of Use, or any other policy or terms that affect you and your use of our website) or fulfillment purposes (e.g. completing any trade you execute).

For Website Visitors in the European Union (“EU”)

Under the General Data Protection Regulation (“GDPR”), our visitors in the EU enjoy additional rights with respect to their personally identifiable information, or “personal data” as defined under the GDPR. For the purposes of this Privacy Policy and any personal data processed for website visitors or individuals in the EU, InfoReach operates as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Privacy Policy, and only with your notice and consent as the lawful means for such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and marketing services which you have consented, and in accordance with your rights below and in this Policy.

You can exercise any of the following rights by notifying us as described below:

• Access: You may email us at legal@inforeachinc.com to request a copy of the personal data our website currently contain.
• Correction or Rectification: You can correct what personal data our website currently contains by emailing us at legal@inforeachinc.com to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
• Restrict Processing: When applicable you may restrict the processing of your personal data by submitting a request via email to legal@inforeachinc.com. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent to the processing of your personal data.
• Object to Processing: When applicable, you have the right to object to the processing of your personal data by submitting a request via email to legal@inforeachinc.com. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent to the processing of your personal data.
• Portability: Upon request, and when possible, we can provide you with copies of your personal data. You may submit a request via email to legal@inforeachinc.com. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Policy, to include withdrawing your consent.
• Withdraw Consent: At any time, you withdraw your consent to our processing of your personal data through this website by notifying us via email at legal@inforeachinc.com. Using the same email address you have provided to us, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data.
• Erasure: If you should wish to exercise your “right to be forgotten” and cease use of our website and have your personal data deleted from our website, then you may submit a request via email to legal@inforeachinc.com. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted.
• Submit Complaints or Questions: If you wish to raise a complaint on how we handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.

Links:

This Privacy Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. You may leave InfoReach's website by clicking on certain links on InfoReach's website. Many of these links take you to websites and online content that are not operated by InfoReach and are beyond InfoReach's control. Some of these links may even include InfoReach's logo as part of a joint marketing arrangement. If you "click" on these links, you will be taken to a third party website. InfoReach has no control over, and is not responsible for, the content of any third party sites to which you link. In addition, these other websites have their own privacy policies and practices that may differ from InfoReach's, and we encourage you to review the privacy policies of any other website you visit.

Security:

InfoReach takes reasonable steps to secure its systems and to secure your personally identifiable information on our systems, including limiting access to the personally identifiable information contained on our servers and using the Secure Sockets Layer (SSL) protocol when processing your account transactions and your credit card information. You may utilize a username and password to enjoy our websites. It is your responsibility to keep confidential your username and password. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

Unfortunately, data transmissions over the Internet cannot be guaranteed to be secure. InfoReach makes no warranty regarding the security of any information you transmit to InfoReach and you do so at your own risk.

Assignability:

InfoReach reserves the right to disclose, share, assign and/or otherwise transfer user information, including without limitation personally identifiable information, in connection with a merger, acquisition, consolidation, the sale of substantially all of its assets or stock, or any other corporate change or restructuring, whatever form it may take.

Contacting InfoReach:

Any questions or concerns regarding this Privacy Policy and InfoReach's handling of personal information (including, without limitation, personally identifiable information) should be directed to: legal@inforeachinc.com, or via mail to InfoReach, Inc., Attn: Privacy Policy, 20 South Clark Street, Suite 2150, Chicago, IL 60603, U.S.A. InfoReach will contact any person lodging a formal complaint and will cooperate with appropriate regulatory authorities to resolve any complaints that cannot be resolved between InfoReach and any individual(s).