VERITABLE DATA SOLUTIONS PRIVACY POLICY

Effective Date: May 1, 2020

This Privacy Policy describes how Veritable Data Solutions, Inc. (“Veritable”, “we”, “us” or “our”) collects your personal information, why we collect this information, how we use or disclose this information and how we protect your information.

This Privacy Policy applies to all personal information collected about you when you communicate with us during any written, electronic, and oral communications, or when you access or use our website at https://www.veritabledata.com/  (“Website”), mobile applications (“App”), or any features or content owned or operated by Veritable that link to this Privacy Policy (collectively, the “Services”).  Use of our Services is subject to our Terms of Service (“Terms”), which you can view at Terms Service, and this Privacy Policy, which is part of the Terms.  By using our Services, you accept the Terms and this Privacy Policy. If you do not feel comfortable with any part of this Privacy Policy or our Terms, you must not use or access our Services.

We may update this Privacy Policy from time to time and make changes to information previously collected, as permitted by law.  If we make changes, we will post the updated Privacy Policy on this page with an “Updated” effective date of the revisions.  If we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective.  We encourage you to look for updates and changes to this Privacy Policy by checking the effective date when you access our Website and App.

We may provide additional “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may supplement or clarify Veritable’ s privacy practices or may provide you with additional choices about how we process your information. If you have any questions, please contact us at support@veritabledata.com.

INFORMATION WE COLLECT
Throughout this Privacy Policy we use the term “personal information” to describe data that identifies you or makes you identifiable. The definition of personal information depends on the applicable law based on your physical location and may include other types of information such as your IP address. Only the definition that applies to your physical location will apply to you under this Policy. The types of information that we may collect about you include, but are not limited to:

• Information You Provide to Us. We collect personal information you give us when you use our Services, so that we can fulfill your request for services. For example, to use our Services to verify signers’ identities, notaries need to provide Veritable their names, notary license numbers, email addresses, phone numbers, selfie images and video clips stating that the provided information is true and correct. When notarizing a document, Veritable requests notaries to also submit a signature page of an applicable document, a notary stamp, a selfie of a signer, and an image of a signer’s ID (passport, driver license).  In California, to notarize a document, Veritable will be also capturing an image of a signer’s thumbprint.
• Information About Your Use of Our Services. We may collect information about your use of the Services. For example, we may collect:
  • Device information, such as your hardware model, IP address, other unique device identifiers, operating system version and settings of the device you use to access the Services. We use such information for diagnostic and statistical purposes and to administer the Website and Apps.
  • Usage information regarding customer traffic patterns and use of our Services. This information is used to analyze and improve our Services and to provide Veritable users with a better user experience.
  • We may also use “cookies” to store your preferences to make your use of the Website more productive.
• Information Collected from Other Sources. We may receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud.
• Cookies and Other Tracking Technologies. We may use cookies and similar tracking technologies to track the activity on our Services. Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted.  We may also use other tracking technologies, such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.

Cookies set by us are called “first party cookies,” while cookies set by parties other than Veritable are called “third-party cookies.” The parties that set third-party cookies can recognize your web browser both when it visits our Site and when it visits certain other websites or mobile applications. We do not control the types of information collected and stored by these third-party cookies. You should check the third party’s website for more information on how they use cookies.

Generally, we use first-party and third-party cookies for the following purposes to store your preferences, to help us review Website traffic patterns and improve our Website, to make our Services function properly, to provide a secure browsing experience during your use of our Services; and to help us improve our Services.

The cookies that may be used on our Services may be categorized as:

• Strictly Necessary Cookies, which are needed for the Website or Services to operate as reasonably expected by you.
• Functional or Preference Cookies, which remember your name or choices.
• Performance or Analytic Cookies, which collect passive information about your use of the Website or Services.
• Advertising or Targeting Cookies, which are used to make advertising messages more relevant and personalized to you based on your inferred interests.

Google Analytics. Veritable uses Google Analytics to collect information about the effectiveness of our Services. Google Analytics uses “cookies”, text files stored on your computer, to learn about how people use our Website. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service and the Google Privacy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics. You can prevent your information from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on.

Your Choices. As described below, you can change your browser setting to prevent the acceptance of cookies, but this may prevent you from using some of the features of our Website.

• First-Party Cookies – You can enable, disable or delete our cookies through the browser you are using to access our Services. To do this, follow the instructions provided by your browser, which are usually located within the “Help”, “Tools” or “Edit” settings. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
• Third-Party Cookies – To opt-out of third-party advertising networks and similar entities that use advertising cookies go to aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities.

Do Not Track.  Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Website does not currently process or respond to “DNT” signals.

HOW WE USE INFORMATION
We will only use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place. Described below is how we may use your personal information.

• To Provide Our Services.  We may use your personal information to provide you with information or perform Services that you request.
• To Provide Service-Related Communications.  We may send you administrative information to keep you updated about our Services. Such communications may include information about changes to this Privacy Policy, our Terms, security updates and tips or other relevant information. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to our Services.
• To Provide Customer Support. We collect any information that you provide to us when you contact us with questions, concerns or feedback. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
• To Ensure the Security of the Services.  To keep your information secure while using our Services we must process your personal information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
• To Enforce Compliance with Our Terms and Policies. When you access or use our Services, you are bound by our Terms and this Privacy Policy. We may process your personal information to: investigate, prevent or mitigate violations of our policies, terms or agreements; and enforce our agreements with third parties and service providers.
• To Engage in Marketing Activities. Marketing lets us grow our community and update you about new services. We may use your personal information to send you information that we believe may be of interest to you, based on information you provided to us.
• For Internal Use.  We may use your personal information for the purposes of furthering our business, including analyzing your information to understand how our Website and Apps perform. We may monitor how our users use our Website and Apps, including search terms entered, pages visited, and documents viewed.
• To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under applicable law.

SHARING AND DISCLOSURE OF INFORMATION
We may disclose your personal information we the following circumstances:

• Service Providers. We may employ other companies and individuals to facilitate our Website or Services (“Service Providers”), provide the services on our behalf, perform service-related activities or assist us in analyzing how our Website or Services are used. These Service Providers may provide us support services such as credit card processing, website hosting, email and postal delivery, location mapping, analytics and marketing services, or conducting research. The Service Providers have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Corporate Transactions. Circumstances may arise where for business reasons, Veritable decides to sell, buy, merge or otherwise reorganize its businesses in the United States or some other country. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers and/or receiving such information from sellers.
• To Maintain Legal and Regulatory Compliance. Veritable also may disclose your personal information to another party, such as law enforcement officials, to comply with legal requirements, court orders, government or law enforcement agency requests, to protect or defend Veritable, or where we perceive an immediate danger of death or serious physical injury to someone as a result of activity on our Services. Our disclosures may occur under circumstances where we may not be authorized to advise you of such action.

YOUR PRIVACY RIGHTS

• Right to Access, Correct or Update Your Information: If you would like to correct or update personal information that you have provided to us, please logon to your account and update your profile.  You may also notify us via the information in the “Contact Us” section below to request access to, or to correct any personal information 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.
• Communication Preferences. We may send you messages or updates about Veritable, our Website or other activities. If you do not wish to receive non-transaction/security related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication or contact us where specified in the “Contact Us” section, below. Similarly, you may opt in to receive text messages, telephone calls and mailings.  Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your Information shall remain subject to the prior privacy settings. Additionally, you should be aware that any Information provided to third-parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

SECURITY
We take precautions to protect personal information under our control from misuse, loss or alteration. Our security measures include industry-standard physical, technical and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or App, you are responsible for keeping this password confidential. You should not share your password with anyone.

The transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

THIRD-PARTY LINKS
Our Services may contain links to websites that Veritable does not operate or control.  This Privacy Policy does not apply to information collected through those websites.  We are not responsible for the privacy practices of these websites, nor any adverse consequences that may result from your interaction with such third-party websites. Veritable has no influence over the privacy practices of these other websites or their use of cookies and other tracking technology.

CHILDREN
Our Services are not directed to children under the age of 18. We do not knowingly collect personal information from any child under the age of 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information from our files.

CONTACT US
Should you have any questions regarding this Privacy Policy, our Services, or our privacy practices, please contact us at: support@veritabledata.com.