SimTrack, LLC

We take care of your data and undertake to guarantee its confidentiality and security.

This Privacy Notice ("Privacy Notice") sets forth the policies and practices used by SimTrack, LLC ("SimTrack") regarding how we collect, use, and disclose any information associated with an identified or identifiable individual ("Personal Information"). It also explains the rights and choices individuals have concerning their Personal Information. SimTrack, the owner and operator of simtrackpro.com, simtrackpro.app, scenariobuilder.app, simtrackcore.com, and simtrackcore.app (the "Websites"), and all related services (collectively the "Services"), is a limited liability company formed under the laws of the State of Florida.

I. WHAT INFORMATION DO WE COLLECT?

We collect a variety of information to provide analytics, reporting, and other services to our customers, users of the Website, and the public at large. This includes both data that we collect directly and data uploaded by third-party customers. We are committed to collecting only Personal Information that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed. If you believe we have collected Personal Information that is not necessary for the purposes described in this Privacy Notice, please contact us at admin@simtrackpro.com.

Below is a breakdown of the types of information we collect:

Information Uploaded by Our Customers.

As part of providing the Services, we allow organizations – our customers – and their employees or sub-licensors to upload their own datasets to our platform. These datasets may include Personal Information about individuals, which is provided at the sole discretion of the customer uploading the data. Examples of Personal Information that may be included in customer uploads are:

• Identifying information, such as name and email address.
• Contact information such as your address or phone number.
• Employment-related information.
• Education-related information.
• Demographic information, such as age, gender, occupation, or education.
• Health information or data, with the proper HIPAA consent or other permissible legal basis for processing.
• Other data we are required or entitled by applicable law to collect and process for the purposes of authentication or identification, or for the verification of data we collect.
• Location Information if included in the dataset.

Information You Voluntarily Submit.

We collect Personal Information from you when you voluntarily provide such information, such as when you contact us, register for access to our Services, purchase products or services, or use our Services. Personal Information may include, but is not limited to:

• Account information, such as username and password.
• Identifying information, such as name and email address.
• Contact information such as your address or phone number.
• Marketing and notification preferences, including email or other communication preferences.
• Identifying and/or contact information for other individuals when you act on their behalf or in their interest (such as when you direct us to send a gift on your behalf).
• User account or profile information.
• Employment-related information.
• Education-related information.
• Demographic information, such as age, gender, occupation, or education.
• Any information you provide in communications with us, including via e-mail or other contact method.
• Other personal information, including physical characteristics, and/or physical description.
• Other data we are required or entitled by applicable law to collect and process for authentication or identification, or for the verification of data we collect.
• Transaction information and User Account activity, including purchases, sales, and usage of our products and Services.
• Tax identification data and numbers, including VAT identification numbers and business EINs that you provide when using our payment services.

If you submit any Personal Information relating to other people in connection with any SimTrack Online Properties, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.

Information Collected Automatically.

When you interact with the Website, we automatically collect the following information about you:

• Device Information. We collect device-specific information, such as your operating system version, device type, and the name of the mobile network you are using. Our system logs may record certain information about your visits to our Websites, including web requests, Internet Protocol ("IP") addresses, device and mobile ad identifiers, browser information, and other such information. We may also collect device information from emails you receive from us which helps us track which emails are opened and which links recipients click. If you use your login information while connected to a Virtual Private Network, we may also collect that information.
• Location Information. Depending on your device permissions, when you access the Website or use our Services, we automatically collect and process information about your general location. We use various technologies to determine location, including IP address, GPS, Wi-Fi access points and mobile towers.
• Client and Log data. We collect technical details, including your device's Internet Protocol (IP) address, time zone and operating system. We will also store your login information (registration date, date of last password change, date of last successful login), type and version of your browser.
• Usage Information. We collect information about your activity on our Website which includes a timestamp of each visit. Based on your interactions and use of the Website, we may also collect additional information that is generated as part of such use.
• Cookies. If you access our Website through a web browser, we use cookies to manage your session, store your preferences and language choice, and deliver relevant advertisements to you. "Cookies" are small text files transferred by a web server to your device's hard drive and may be used to collect data such as the date and time of your visit, your browsing history, preferences, and username. You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website or Services may become inaccessible or not function properly.

Most web browsers are set to accept cookies by default. You can usually configure your browser to remove or block cookies. Keep in mind that if you choose to remove or reject cookies, it may impact the availability and functionality of our Websites, Platform, and/or Services. Please note that not all tracking will stop even if you delete cookies.

Information Collected from Other Sources.

We may collect information from third parties, including advertising and marketing partners, public databases, and social media platforms (such as those from individuals you are friends with or otherwise connected to). If we do, this Privacy Notice explains how we use that information, whether such use is independent of or in combination with the information you have provided.

Sensitive Personal Information.

We do not ask for, and you are not required to provide, sensitive Personal Information as part of our operation of our business or our Websites, Platform, and/or Services. If you elect to submit such information to us, it will be subject to this Privacy Notice.

Where we process sensitive Personal Information (also known as "special category data" under the GDPR), we do so only with your explicit consent or on another lawful basis permitted by applicable law, such as where processing is necessary: (i) to protect your vital interests or those of another person; (ii) for the establishment, exercise, or defense of legal claims; (iii) for reasons of substantial public interest; or (iv) for purposes of preventive or occupational medicine. We implement enhanced security measures and access controls for sensitive Personal Information, and we limit access to authorized personnel on a need-to-know basis. We will inform you at the time of collection about the specific legal basis we rely upon for processing your sensitive Personal Information.

II. HOW DO WE USE YOUR PERSONAL INFORMATION?

We process Personal Information only for the purposes described in this Privacy Notice or for purposes compatible with those for which the Personal Information was originally collected. Before using Personal Information for a new purpose that is materially different from or incompatible with the original purpose, we will notify you and, where required by applicable law, obtain your consent. If you have questions about how we use your Personal Information or believe that your Personal Information has been used in a manner inconsistent with this Privacy Notice, please contact us at admin@simtrackpro.com.

SimTrack may use Personal Information as permitted by law, for the following business purposes:

To provide you with the Websites, Platform, and/or Services

• To operate and maintain the Websites, Platform, and/or Services.
• To enable or facilitate specific product or Service features.
• To provide you with user support.
• To track and measure Website performance.
• To fulfill or meet the reason the individual provided the information (e.g., process orders, provide information).
• To create your user account, identify you as a user of the Website, and customize the Website to your account.
• To process payment for purchases you make through the Website.
• For billing, invoicing, account management, and rewards/loyalty program finance functions.

To communicate with you

• To respond to your comments or inquiries and fulfill your requests.
• To provide you with user support and customer care, including resolving user-initiated requests, questions, or complaints and handling support tickets, transaction inquiries, and after-sale correspondence.
• To send you administrative communications, such as confirmation e-mails, technical notices, policy updates, or security alerts.
• To solicit and respond to user feedback, reviews, survey responses, and product evaluations.

To send you marketing and/or promotions

• To send you promotional information.
• To notify you of new information or services that may be of interest to you, including promotions, campaigns, programs, contests, or sweepstakes.

For analytics, research, and product and Service improvements

• To track and measure Website performance.
• To perform quality control of our Website and Services through analytics and market research, and to otherwise improve the quality of our Website and Services.
• To conduct aggregated or de-identified research and statistical reporting for business purposes or regulatory/royalty reporting.

To ensure the security and integrity of the Services

• To protect, investigate, and deter against unauthorized or illegal activity.
• For identity verification and authentication.
• For risk analysis, risk management, and compliance with security best practices.
• To enforce the legal terms that govern our business and commercial relationships.

For other business purposes, including:

• For preserving and managing records of employment, business relationships, and performance for legal/commercial purposes.
• To share personal information with service providers, contractors, business partners, affiliates, parent/subsidiary companies for business-related functions.
• To manage and maintain ongoing relationships and contracts.
• For business transfers (mergers, sales, acquisitions, bankruptcy, or dissolution).

We may also use Personal Information as we believe to be necessary or appropriate for certain essential purposes, including:

• To comply with law and legal process and protect rights, safety and property.
• To detect, prevent, or investigate security incidents, breaches, or fraud.
• To enforce our Terms of Use or any other applicable terms or policies.
• For other purposes requested or permitted by our users or other relevant individuals, such as website visitors.

Use of AI, ML, and Automated Decision Making

To the extent permitted by law, we may use Artificial Intelligence ("AI"), Machine Learning ("ML"), or Automated Decision Making ("ADM") as part of our processes that use your Personal Information. Such uses include:

• Functionality/Operation. We use AI and ML technologies to enable normal operation of the Services, develop new features, technologies, or improvements, analyze new features or functions, including user reactions, to determine whether updates or modifications may be appropriate, and build, train, analyze, and improve the performance and/or accuracy of our AI, ML, and ADM model(s).
• Communication. We use AI and ML technologies to interact with and assist the user and collect information and provide responses via our AI Chatbot.
• Automated Decision-Making. Certain decisions regarding our services may be made automatically using ADM processes. These decisions are based on data analysis and are designed to improve service efficiency and accuracy.

Vendor Use of AI, ML, and ADM

Our service providers may use techniques like AI and/or ML to help us improve our Websites, Platform, and/or Services. When our service providers use such tools, it either: (1) still has a human being involved in the process, and thus is not fully automated; or (2) uses such tools in ways that do not have significant privacy implications (e.g., reordering how products might appear when you visit an online store) and does not produce any legal or similarly significant effects.

AI Chatbots

We may use software applications that incorporate artificial intelligence technology ("AI Tools"), such as an AI Chatbot. AI Chatbots utilize advanced algorithms to interact with users. By engaging with SimTrack's AI Chatbots, users consent to the collection and use of their Personal Information.

Our AI Chatbot collects and processes Personal Information provided directly by users (e.g., identifiers and contact details, the text and content you provide, contextual and device data, inferences, and various other types of information) for the purposes of using SimTrack's Services, to improve functionality, and provide personalized recommendations. This data is used to enhance user experience, develop new features, and ensure compliance with legal standards.

Our AI Chatbot uses a third-party service provider, OpenAI, to host or process interactions with our chatbot. OpenAI processes your inputs and the responses you receive on our behalf under a data processing agreement, and may temporarily log prompts and/or responses to operate, secure, and troubleshoot the service.

Our legal basis to process data provided through our AI Chatbot includes providing the service you request, performing our contract with you, and pursuing our legitimate interests in improving support and product/service discovery. Where required, we also rely on your consent. We retain and protect personal information provided to the AI Chatbot consistent with the terms of this Notice.

We cannot guarantee the accuracy, completeness, or up-to-date nature of the information provided by the AI Chatbot, and it is strictly recommended that users use responses as a starting point and verify any critical details before acting on information provided. Do not share sensitive personal information or payment details via the AI Chatbot.

Disclosure of Personal Information

To the extent permitted by law, your Personal Information may be disclosed with the following categories of third parties:

• Parent Companies and Affiliates. For business-related functions, we may share Personal Information with a parent company, any subsidiaries, or other companies under a common control (collectively, our "Affiliates"), but only to the extent such information is provided an equal or greater level of protection as provided by this Privacy Notice.
• Business Transfers. If we sell or transfer all or part of our business assets, Personal Information may be included. We will make every effort to ensure that any transferred Personal Information receives protection equal to or greater than that provided by this Privacy Notice. In the event of such a transfer, you are encouraged to contact the recipient with any questions about their applicable privacy practices.
• Agents, Consultants and Related Third Parties. For business-related functions (such as mailings, database maintenance, and payment processing), we may share Personal Information with third parties, but only to the extent necessary to perform their designated function.
• When Legally Required. We may share Personal Information with law enforcement authorities, regulators, courts and tribunals, governmental or public bodies, and other relevant third parties as we believe necessary or appropriate to protect people or property, to protect our services, rights or property, to comply with legal or regulatory requirements and to respond to legal process, law enforcement requests and requests from other public and government authorities.
• Third Party Vendors. We share Personal Information with vendors who provide products and services related to the operation and maintenance of the Website, the performance of certain Services, the analysis of user behavior, promotion of the Services, and/or evaluation of our advertising efforts (the Third Party Vendor’s privacy notice explains their use of your Personal Information), including the following Third Party Vendor service providers:
  • Tracking – To improve our Website and Services, we may share your de-identified, anonymized, and/or aggregated information with analytics providers that help us analyze how people use our Services. For example, we use industry-standard analytics software to understand how people use our app, enabling us to improve the Services and increase engagement. We use the following third-party service providers for tracking: Google Analytics: Privacy Notice
  • Subscription and Membership – We utilize third-party vendors to handle membership and/or subscription sign-ups and collection of member information.
  • Surveys and Forms – We utilize third-party vendors to create and manage online surveys and other forms, facilitating the collection and organization of information. Personal Information may be collected and maintained as a result of interacting with any surveys or forms.
  • CRM – We utilize a third-party vendor to manage customer interactions and data, which may be enriched or updated by the vendor to ensure accuracy and relevance.
  • Email Marketing/Newsletters – We utilize third-party vendors as our email service provider and email marketing vendor. Through our third-party vendors, we collect information related to our communication effectiveness and the impact of our email marketing, including tracking the actions you take that assist us in measuring the performance of our Website, our Services, and our Email Marketing. Upon subscription, our email marketing track the pages you visit on our Website from our marketing emails. If you are or become a subscriber and/or are or become a customer, information about your transactions is provided to these vendors to assist in this function. Our marketing emails contain tracking pixels, allowing us to analyze the success of our marketing emails. These tracking pixels allow us to see if and when you opened an email, which links you click in the email, and which pages of the Website you visit.
  • eCommerce – We utilize the following vendors to process transactions:
    • Stripe – for payment transactions. Stripe collects Personal Information such as your name, e-mail address, zip code, and payment information. You may access Stripe's Privacy Notice here.
    • Bank of America – for financial transactions. You may access Bank of America's Privacy Notice here.
    • QuickBooks – for accounting and tracking of financial transactions. You may access QuickBooks' Privacy Notice here.

    At no time is your banking information passed to the Website from the Third-Party Vendor. We receive only information necessary for order fulfillment.

• Other Third Parties. We send your Personal Information to whom you ask us to send your information.

Disclosure of Other Information

In addition to collecting Personal Information, we may collect information that does not identify you and is not associated with your Personal Information. We may also de-identify, anonymize, or aggregate information so it no longer identifies you.

Analysis of Website Performance. We may collect and combine such information with other data to monitor, for example, the total number of visitors to our Website, the number of visitors to each page, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Information is involved or used in this process.

Customer Research. To better serve and understand the needs of the Website's users, we may conduct research on their demographics, interests and behavior using the Personal Information and other data we collect. This research may be compiled and analyzed in the aggregate, and we may share this aggregated data with our affiliates, agents and business partners. This aggregate information does not identify you personally. SimTrack may also disclose aggregated user statistics to describe our services to current and potential business partners, as well as to other third parties for lawful purposes.

Legal Basis for Processing Your Personal Information

Some jurisdictions require that companies tell you about the legal grounds that allow your data to be used or disclosed. Below are the types of lawful bases that we will rely on to process your Personal Information:

• Legitimate Interest: The purpose of conducting and managing our business to enable us to provide you with the best service, product, and a secure experience. We balance the potential positive and negative impacts on you and your rights. If the impact on your rights outweighs our legitimate business interests, we do not use or disclose your Personal Information without your consent, unless required or permitted by law. You can obtain further information about how we evaluate our legitimate interests against any potential impact on you for specific activities by contacting us at admin@simtrackpro.com.
• Performance of Contract: Processing your Personal Information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply With a Legal or Regulatory Obligation: Processing your Personal Information where it is necessary for compliance with a legal or regulatory obligation.
• Consent: You have given express permission to a particular use of your Personal Information.

III. YOUR RIGHTS RELATED TO YOUR PERSONAL INFORMATION

We provide several ways for you to exercise certain privacy choices about your Personal Information that we process. We are committed to respecting your privacy rights under all applicable data protection and privacy laws. Some privacy laws require us to give specific details about individual rights to consumers, which we have set forth in Section IX of this Privacy Notice.

Marketing. You may opt out of marketing-related communications from us at any time by contacting us through the contact information provided in this Privacy Notice or by using the unsubscribe mechanism contained in each email. We will make efforts to honor your request as soon as reasonably possible. Please note that even if you opt out of marketing emails, we may still send you important administrative messages, which you cannot opt out of.

Cookies Preferences. To review and update your preferences for most types of cookies (other than those that are necessary) for our Services, click the "Cookie Preferences" link in the footer of the Website.

Location Information. You can choose whether or not to allow the Websites, Platform, and/or Services to collect and use real-time information about your device's location information from your device in your device's privacy settings. If you block the use of location information, some parts of the Websites, Platform, and/or Services may become inaccessible or not function properly.

Deactivation. You can deactivate your User Account at any time by contacting us at admin@simtrackpro.com or by selecting the "Deactivate My Account" option in your User Account. However, you will not be able to access any part of the Services that are for registered users only once your User Account is deactivated. Please note that even if you request deactivation of your User Account, it may take some time to fulfill this request.

Access, Amendment and Deletion. Under applicable privacy laws, you may have the right to request to review, make amendments, have deleted, or otherwise exercise your rights over your Personal Information that we hold, subject to certain legal limitations and requirements. If you are subject to such a privacy law, you may submit a request to us related to your Personal Information:

• By submitting an email request to us at admin@simtrackpro.com

We will process any request in accordance with – and where required by – applicable law with respect to your Personal Information. We will take steps to verify your identity before implementing your request. Unless prohibited by applicable law, we reserve the right to charge a reasonable fee to cover costs for providing copies of Personal Information that you request.

Although our active systems and databases will reflect updates that have been requested and processed, we may retain all Personal Information for backups, archiving, fraud and abuse prevention, analytics, and to satisfy other legal obligations that we reasonably believe apply.

Time for Changes to Take Effect

We aim to complete requests as soon as reasonably practicable, consistent with applicable laws. Requests made on behalf of another, which require confirmation of the agent's authority and the authenticity of the requester, will likely take more time to complete.

We may need to retain certain information for recordkeeping purposes and to complete transactions you started before requesting a change or deletion. Some residual information may also remain in our databases and records and will not be removed. We may not always be able to fully comply with your request, especially if doing so would compromise our duty of confidentiality or if we are legally allowed to handle the request differently.

For jurisdiction-specific data privacy policies, please consult Section IX of this notice for additional information.

IV. CHANGES TO THIS PRIVACY NOTICE

We may periodically update this Privacy Notice. Please reference the "LAST UPDATED" legend at the top of this page to see when this Privacy Notice was last revised. Any changes to this Privacy Notice will take effect upon the posting of the revised Privacy Notice on the Website.

If any changes to this Privacy Notice could potentially require you to provide renewed or additional consent for the use of your Personal Information, notice of the requirement, as well as information we are required to disclose related to your renewed or additional consent, will be prominently displayed and will be sent to you directly via email and/or any other acceptable means of contact under applicable law. Your continued use of the Services will, along with express consent where required, constitute your consent to any additional processing of your Personal Information described therein.

V. AGE RESTRICTIONS

SimTrack does not knowingly collect any Personal Information from children under 18. We encourage parents and legal guardians to monitor their children's Internet activity and to help enforce this Privacy Notice by instructing their children never to provide Personal Information on this (or any) Website without parental permission. If a parent or guardian believes that SimTrack has Personal Information about a child under 18 in its database, please contact admin@simtrackpro.com immediately. We will make every effort to promptly remove such information.

VI. THIRD PARTY PRIVACY PRACTICES

Our Websites, Platform, and/or Services may contain links to third-party websites or apps. If you click on one of these links, be aware that each one will have its own Privacy Notice. We do not control these websites/apps and are not responsible for their policies. When you leave the Website, we encourage you to read the Privacy Notice of every website you visit.

We are not responsible for the privacy and data security practices of other organizations, such as Facebook, Instagram, Apple, Google, Microsoft, X, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer. Please read their privacy policies and consider customizing your browser or device settings to limit the disclosure of certain information, such as location data.

Any Personal Information that you provide through these third-party websites, mobile applications, or social platforms will be subject to the Privacy Notice of its operator, and not this Privacy Notice.

VII. DO NOT TRACK SIGNALS

We do not monitor or follow "Do Not Track" (DNT) signals because there is no standard interpretation or practice for DNT signals. Therefore, we handle all user information consistent with this Privacy Notice.

VIII. MISCELLANEOUS TERMS AND CONDITIONS

Other Terms and Policies

This Privacy Notice is to be read in conjunction with this Website's Terms of Use, Disclaimer, and Cookie Policy. Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with SimTrack. Please refer to those agreements as needed.

Reservation of Rights

Regardless of any other part of this Privacy Notice, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) in emergencies, to protect the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations to reduce credit risk and protect against fraud.

Security of Personal Information

We use standard physical, technical and administrative measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your Personal Information. Unfortunately, no system or network can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you suspect that the security of specific Personal Information you provided to us has been compromised), please notify us immediately at admin@simtrackpro.com.

Data Breach Notification

In the event of a security incident involving unauthorized access to, disclosure of, or loss of Personal Information that is likely to result in harm or injury and/or increased risk of identity theft, we will notify affected individuals and relevant supervisory authorities in accordance with applicable law. Where required, we will provide notification without undue delay, and in any event within the timeframes mandated by applicable data protection laws. Notifications will include, where required a description of the nature of the breach, the likely consequences of the breach, the measures we have already taken or propose to take in order to address the breach, and contact information for obtaining further information. For jurisdiction-specific breach notification requirements, please consult the applicable addendum in Section IX of this Privacy Notice.

Retention of Personal Information

We retain each category of Personal Information for only as long as necessary to fulfill the purposes described in this Privacy Notice. We consider the amount, nature, and sensitivity of the Personal Information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it and whether those purposes can be achieved through other means.

We retain datasets uploaded by our customers for as long as our customers are members of our Services. We therefore maintain the right to store any Personal Information contained therein for as long as the customer maintains their account. To protect any Personal Information included in customer-uploaded datasets, we employ the following security measures:

• Encryption and Secure Storage is used to safeguard data both at rest and in transit;
• Access Restrictions allow only authorized personnel to access Personal Information; and
• Customers are contractually obligated to comply with all applicable data protection laws, including requirements to obtain appropriate consent for any data they upload.

If you believe that your Personal Information has been improperly included in a dataset by one of our customers, please contact that customer directly to exercise any rights you may have regarding such information.

IX. ADDITIONAL INFORMATION FOR CERTAIN JURISDICTIONS

Residents of certain countries or U.S. states have additional rights under applicable privacy laws, as described in this section. The term "Personal Information" encompasses "Personal Information" as defined by Canadian law, as well as "Personal Data" as defined by the EU, the UK, and Swiss law. See the list below for which section applies to you.

• If you are a resident of the EEA or the United Kingdom, please review Section A.
• If you are a California resident, please review Section B.
• If you are a resident of another U.S. state, please review Section C.
• If you are a resident of Canada, please review Section D.

A. Residents of the European Economic Area or the United Kingdom

The GDPR, Swiss, and UK data protection laws (where applicable), give data subjects the following rights regarding their Personal Information:

You may submit your GDPR, UK GDPR, or Swiss Federal Act on Data Protection request to us via Email: admin@simtrackpro.com

International Transfers

We may transfer Personal Information outside of the EEA/UK. Where we do so, we rely on appropriate safeguards, such as European Commission–approved Standard Contractual Clauses (and the UK Addendum/IDTA, as applicable), and supplementary measures, or on adequacy decisions where available.

B. Residents of the State of California

CCPA Personal Information Use Disclosure

The California Consumer Privacy Act of 2019 ("CCPA") requires that we disclose certain categories of Personal Information that we collect, the sources of that Personal Information, the purpose of collecting such information and the categories of third parties with whom we share that information.

Categories of Personal Information that we collect and disclose

Our collection, use and disclosure of Personal Information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident. Below we describe the categories of Personal Information we may collect about California residents (including the categories of Personal Information that we have collected about California residents in the past 12 months):

• Identifiers: Includes direct identifiers such as a real name, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.
• Customer records: Paper and electronic customer records containing Personal Information, such as name, digital signature, address, telephone number, email and other contact information, government identifiers, financial and payment information.
• Characteristics of protected classifications: Such as disability and health information (e.g., which we may collect to, for example, make accommodations available to you at events we host), as well as inferences made about such characteristics based on other types of information we have collected from you or from third parties.
• Commercial information: Including services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
• Usage data: Internet or other electronic network activity information including without limitation browsing history, search history, and information regarding a consumer's interaction with an Internet website, application, or advertisement.
• Location data: Location information about a particular individual or device.
• Employment history: Professional or employment-related information.
• Education information: Education history and background.
• Profiles and inferences: Inferences drawn from any of the information identified above to create a profile reflecting characteristics, behavior, attitudes, intelligence, abilities, or aptitudes.
• Sensitive Personal Information: In limited circumstances, we may collect certain information considered to be sensitive Personal Information under the CCPA, including tax ID; financial account number and payment card data; health and medical data; geolocation data; and gender or gender identity/expression. If we process Sensitive Personal Information, California residents may also exercise the 'Limit the Use and Disclosure of My Sensitive Personal Information' option by contacting us as described above.

The chart below summarizes the CCPA disclosure requirements and where you can find this information in this Privacy Notice:

We do not 'sell' Sensitive Personal Information.

In addition, we may disclose any of the categories of Personal Information we collect about you to other third parties as directed by or consented to by you, or where necessary to fulfill your specific requests.

Sales and Sharing

The CCPA defines a "sale" as disclosing or making available Personal Information to a third party in exchange for monetary or other valuable consideration, and "sharing" broadly includes disclosing or making available Personal Information to a third party for cross-context behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may "sell" or "share" (as defined by the CCPA): (i) identifiers, usage data, customer records, commercial information and profiles with our affiliates and subsidiary companies (e.g., so they can improve or enhance their own records and for other purposes); (ii) identifiers, customer records and commercial information related to property sales and transactions with partners and third-party businesses, who may use or process the information for their own commercial purposes; and (iii) identifiers, usage data and commercial information to ad networks, social media platforms and data analytics providers (e.g., to improve and measure our ad and marketing campaigns). Some third-party cookies and similar technologies on our Website may constitute a 'sale' or 'sharing' of Personal Information under California law. You can manage these by using the 'Cookie Preferences' or by enabling GPC in your browser.

Sources of Personal Information

We may collect Personal Information from the following sources:

• Directly from the individual;
• Advertising networks;
• Data analytics providers;
• Social networks;
• Government entities;
• Data brokers;
• Affiliate and subsidiary companies; and
• Service providers.

Purposes of Collection, Use, and Disclosure

As described in more detail in Sections I and II, we collect, use, disclose, and otherwise process Personal Information (including sensitive Personal Information) for the following business or commercial purposes or as otherwise directed or consented to by you:

• Providing support and related services;
• Analyzing and improving our business;
• Advertising, marketing, and promotional purposes;
• Securing and protecting our business;
• Defending our legal rights;
• Planning and facilitating business transactions;
• Auditing, reporting, corporate governance, and internal operations; and
• Complying with any legal obligations.

Retention

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice or otherwise disclosed to you at the time of collection unless an extended retention period is required or permitted by law. We may retain Personal Information for longer where required by our legal and regulatory obligations, professional indemnity obligations, or where we believe it is necessary to establish, defend, or protect our legal rights.

California law may permit you to request that we:

• Provide you with a list of the categories of Personal Information we have collected or disclosed about you in the last twelve (12) months; the source category of such information; the business or commercial purpose for collecting or selling the information; and the categories of third parties to whom we disclosed the information;
• Provide access to and/or a copy of the Personal Information we have collected about you.
• Delete certain Personal Information we have collected about you.
• Do not sell your Personal Information to any third parties.

Certain information is exempt from such requests under applicable law. You may also have the right to receive information about the financial incentives we offer you (if any). You also have certain rights under the CCPA not to be subject to certain negative consequences for exercising your CCPA rights.

Minors

We do not knowingly sell or share Personal Information of consumers under 16 years of age. If we become aware that a consumer is between 13 and 16 years old, we will obtain that consumer's affirmative authorization (opt-in) before any sale or sharing; for consumers under 13, we will obtain parental/guardian consent.

Submitting CCPA Requests

California residents may exercise their CCPA privacy rights to know/access, delete, correct, and limit use/disclosure of sensitive Personal Information by submitting a verifiable request to us via:

• Email at admin@simtrackpro.com

We will respond to verified requests received from California residents as required by law. When you submit a request to know or delete, we will take steps to verify your identity by matching the information you provide with the information we have on file. You must provide all requested information so that we can process and verify your request. In some cases, we may ask for additional information to verify your request or, if necessary, to process it. If we are unable to verify a request, we will notify the requester. Authorized agents can submit a request on behalf of another individual by contacting us via email or phone. To do so, they will need to provide proof of their authorization. Additionally, we may also require the relevant consumer to directly verify their identity and the authority of the authorized agent.

Requests to Opt Out

Our Websites, Platform, and/or Services responds to global privacy control—or "GPC"—signals, which means that if we detect that your browser is communicating a GPC signal, we will treat that as a request to opt out of sales and sharing (such as through cookies and tracking tools) on the Websites, Platform, and/or Services. Note that if you come back to our Website from a different device or use a different browser on the same device, you will need to opt out or set GPC for that device and browser as well. You can also manage your preferences for targeting and other cookies on our Website through the "Cookie Settings" link in the footer of each Website. For more information about GPC, please visit: https://globalprivacycontrol.org/. You may also submit a request to opt out of other sharing and sales by submitting a request via:

• Email at admin@simtrackpro.com

Incentives

We may make certain programs or offerings available that are considered "financial incentives" under the CCPA. In such cases, we will provide notice of the material terms of these incentives and obtain consent from individuals before including them in these incentive programs. You can opt out of such programs at any time through the opt-out mechanism provided in the program information.

Rights Under California Shine the Light Law

California residents may request from businesses with whom they have an established business relationship: (1) a list of categories of Personal Information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties' direct marketing purposes and (2) the names and addresses of all such third parties. To request the above information please contact us by writing to us under the "Contact Us" section above. We will respond to such requests within 30 days of receipt. For more information about our privacy practices, contact us as set forth above.

C. Residents of Other U.S. States

Several U.S. states may provide (now or in the future) their state residents with rights to:

• Confirm whether we process their Personal Information, and if so, provide limited information about the nature of the Personal Information collected, processed, and disclosed, the business or commercial purpose, and information concerning third parties to whom the Personal Information was disclosed.
• Access and delete certain Personal Information.
• Correct inaccuracies in their Personal Information, considering the Personal Information's nature and processing purpose (excluding Iowa and Utah).
• Data portability.
• Opt-out of Personal Information processing for targeted advertising (excluding Iowa), sales, or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive Personal Information.

The exact scope of these rights may vary by state. To exercise or appeal a decision regarding a consumer rights request, please contact us at admin@simtrackpro.com.

If we deny your request, you may appeal our decision by emailing us and including 'Appeal' in the subject line and a brief explanation. We will inform you in writing of any action taken or not taken in response to the appeal within 45 days, including a written explanation of the reasons.

Nevada provides its residents with a limited right to opt out of the sale of Personal Information. However, please note that we do not currently sell data that triggers the statute's opt-out requirements.

D. Residents of Canada

Canadian privacy laws, including the Federal Personal Information Protection and Electronic Documents Act ("PIPEDA"), the Personal Information Protection Act, SBC 2003 c 63, in British Columbia, the Personal Information Protection Act, SA 2003 c P-6.5, in Alberta, and the Act Respecting the Protection of Personal Information in the Private Sector, CQLR c P-39-1 ("Quebec Private Sector Act"), in Quebec, apply to the collection of Personal Information from and about Canadian residents. "Personal Information," as used in this Privacy Notice, includes "Personal Information" as defined under those laws.

SimTrack's Data Privacy Officer is responsible for managing Personal Information, including under the Quebec Private Sector Act. You may contact them by email at admin@simtrackpro.com. When SimTrack collects Personal Information from Canadian residents, including those in Quebec, it transfers some data to data centers in the United States. When SimTrack relies on service providers to process Personal Information as described herein, these providers may also be located outside of Canada or Quebec.

Personal Information may be processed in the United States and other countries by SimTrack and its service providers. While located your Personal Information is stored outside Canada, it will be subject to the laws of that foreign jurisdiction, which may differ from Canadian law.

You have the right to request access or rectification of the Personal Information SimTrack holds related to you or to withdraw any consent given to the processing of such Personal Information. You may exercise those rights by contacting SimTrack's Data Privacy Officer at admin@simtrackpro.com. If SimTrack has your Personal Information that was initially collected with your consent by an entity that subsequently provided it to SimTrack, please contact that entity for any questions related to that entity's privacy policies and consent practices.