Privacy Policy Revision Date: 01/01/2020

Please read this privacy policy (the “Privacy Policy“) carefully to understand how Backgrounds 360, LLC, its subsidiary and affiliate corporations, successors, and assigns (collectively, “Backgrounds 360“, “our”, “us” or “we”) uses and protects the information that we collect from (1) visitors to the Backgrounds360.com website, (2) all other websites owned and operated by Backgrounds 360 that redirect to Backgrounds360.com and all subdomains of Backgrounds360.com, (collectively, the “Backgrounds 360 Site”), (3) the users of the Backgrounds 360, portal and system integrations and extension add-ons (collectively, “Users”).

This Privacy Policy applies to (1) information collected by Backgrounds 360 through the Backgrounds 360 Site; (2) any Backgrounds 360 computer software downloadable or otherwise available from the Backgrounds 360 Site (“Backgrounds 360 Software“); and (3) any Backgrounds 360 services purchased or otherwise made available from the Backgrounds 360 Site (“Backgrounds 360 Services“).

This Privacy Policy does not apply to the practices of any third party websites, applications or services that Backgrounds 360 does not own or maintain (collectively, “Third Party Services”) or to any third parties who use Backgrounds 360 Application Programming Interface (API) to perform any function related to Backgrounds 360 (“Integrated Platforms”). Specifically, this Privacy Policy does not apply to any information or other content viewable via Backgrounds 360 on Integrated Platforms or information you provide to Third Party Services accessed via Backgrounds 360. Backgrounds 360 disclaims any responsibility for content or privacy policies of any Third-Party Services, as further detailed below.

This Privacy Policy also does not apply to any information, recorded in any form, about more than one individual where the identities of the individuals are not known and cannot be inferred from the information (“Aggregated Information”). Backgrounds 360 reserves the right to use Aggregated Information in any legal way Backgrounds 360 reasonably determines is appropriate.

By using a Backgrounds 360 Service or otherwise providing us with your information, you acknowledge you understand the practices described in this Privacy Policy and the actual collection, use, and disclosure of your information in accordance with this Privacy Policy. If you do not understand the practices related to the collection, use and disclosure of your information in this way, please do not use any of Backgrounds 360 or otherwise provide Backgrounds 360 with Personal Information.

We may update the terms of this Privacy Policy from time to time to reflect changes in Our information practices. If We make changes to these terms, We will post the new Privacy Policy with a notice that the Privacy Policy has been updated. We may also notify you via email or other direct electronic communication method of any changes that, in our sole discretion, materially impacts your use of Backgrounds 360’s system or the treatment of your Personal Information. You are responsible for periodically visiting this Privacy Policy to check for changes. Your continued use of the Program and website is your acceptance of the Privacy Policy as revised. Identification of when the Privacy Policy has last been updated is located at the top left corner of the page.

A. WHAT INFORMATION BACKGROUNDS 360 COLLECTS

Users utilize Backgrounds 360 to order, view, and share results of Backgrounds 360 Services. As part of this process, Backgrounds 360 collects two (2) types of information about you or the individuals you are ordering services on: Personal and Non-Personal Information.

“Personal Information.“ Personal Information is any information about an identifiable individual (e.g. name, address, social security number, date of birth, telephone number and e-mail address), or an individual whose identity may be inferred or determined from the information. Backgrounds 360 may collect Personal Information when you use the Backgrounds 360 Services. You may either enter in the information manually by typing it, or it may be mapped via regular expressions on the HTML of the page you are ordering from. Backgrounds 360 only collects personal information necessary to perform services you have engaged us to perform on your behalf.

“Non-Personal Information.” Non-Personal Information is information that does not, by itself, identify you as a specific individual (e.g. website visitations limited to Backgrounds 360 domains or products). In addition to collection methods utilized for Personal Information above, Backgrounds 360 may also collect Non-Personal Information automatically through use of technologies described below.

B. HOW BACKGROUNDS 360 COLLECTS INFORMATION

Registration. Prior to using one or more of the Backgrounds 360 Services, Backgrounds 360 may require you to provide certain Personal Information and Non-Personal Information to create an account (“Account”) or to enable features or functionality of Backgrounds 360.

For Users, Backgrounds 360 may gather Personal Information about organizational representatives via various methods (phone, email, online forms, in-person meetings) but only if such Personal Information is submitted voluntarily. Backgrounds 360 may use such Personal Information for sales, marketing, and support of Backgrounds 360. This Personal Information is never shared with third parties other than Third Party Service Providers utilized by a User in connection with Backgrounds 360 Services, or as otherwise permitted by this Policy.

User communications: When you send email or other communications to Backgrounds 360, we may retain those communications in order to process your inquiries, respond to your requests and improve Backgrounds 360.

Payment Information: When creating an Account, for certain Backgrounds 360 Services, or when you make online purchases, you may be asked to provide information, which may include your payment instrument number (e.g., credit card), your name and billing address, and the security code associated with your payment instrument (e.g., the CSV) and other financial data (“Payment Information”). We use Payment Information to complete transactions and for the detection and prevention of fraud. When you provide Payment Information, we will store that data to help you complete future transactions without your having to provide the information again. We do not, however, retain the security code associated with your payment instrument (e.g., the CSV) in this manner. To remove or modify Payment Information, contact us at info@backgrounds360.com. Note that Backgrounds 360 reserves the right to retain Payment Information for as long as reasonably necessary to complete an existing transaction with you and for the detection and prevention of fraud after account closure or removal of Payment Information,

Third Party Databases. We may collect information about you from other sources including publicly available databases or third parties from whom we have purchased data. Aggregating this data with prior data allows us to evaluate our services’ effectiveness by analyzing our records. Examples:

• Address information about you from third-party sources, such as the U.S. Postal Service, to verify your address before we send you mail; • The U.S. Federal Do Not Call registry, to verify do not call preferences recorded there; • Census and other aggregate data sources containing statistical information about people who share some of your traits or demographic markers.

Information Collected Through Technology. Backgrounds 360 automatically collects and receives certain information from your computer or mobile device, including the activities you perform on any websites you request to interact or integrate with, Backgrounds 360 Software and the Backgrounds 360 Services, the type of hardware and software you are using (for example, your operating system or browser), and information obtained from cookies. If you have an Account, we may link this Non-Personal Information to your Account to better understand your needs and the needs of Users in the aggregate, diagnose problems, analyze trends, provide services, improve the features and usability of Backgrounds 360, and better understand and market to our customers and Users.

Methods Used to Automatically Gather Information:

• Cookies. Backgrounds 360 uses cookies on the Backgrounds 360 Site and other aspects of the Backgrounds 360 site. Cookies, including local shared objects, are small pieces of information that are stored by your browser on your computer’s hard drive which work by assigning a unique number to your computer. Cookies do not generally contain any Personal Information. Cookies help Backgrounds 360 to remember information about your visit, like your preferred settings. Cookies play an important role; they can make your next visit easier and the Backgrounds 360 Site more useful to you. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. You can learn more about Cookies by visiting allaboutcookies.org, where you will also find information about how to block Cookies on different types of browsers. However, please be aware that by blocking or deleting Cookies you may not be able to take full advantage of Backgrounds 360 and certain features may be rendered unavailable to you. Backgrounds 360 uses automation services, such as Pardot, to create and monitor cookies.

• IP Address. You may visit many areas of the Backgrounds 360 Site anonymously without the need to become a registered User. Even in such cases, Backgrounds 360 may collect IP addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin services with an Internet services provider. Each time you access the Backgrounds 360 Site and each time you request one of the pages of the Background s 360 Site, the server logs your IP address. Backgrounds 360 uses tools such as Google Analytics and Pardot to monitor IP addresses of website traffic.

• Web Beacons. Web beacons are small pieces of data that are embedded in web pages and e-mails. Backgrounds 360 may use these technical methods in HTML e-mails that Backgrounds 360 sends to Users to determine whether they have opened those e-mails and/or clicked on links in those e-mails. The information from use of these technical methods may be collected in a form that is Personal Information.

• Do Not Track Standard: The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, the Backgrounds 360 Site is not compatible with DNT and so do not recognize DNT settings.

Tracking Content Usage. If you use the Backgrounds 360 Services and you post audio visual materials including, without limitation, videos, links, logos, artwork, graphics, pictures, advertisements, sound and other related intellectual property contained in such materials (collectively, “Content”) to your website or to a third party website, Backgrounds 360 tracks and captures Non-Personal Information associated with User accounts and the use of Content by those that access your Content.

Information You Provide About a Third Party. Backgrounds 360 features allow the User to communicate with others, such as by sending account access to a colleague or notifying an applicant of a request to screen them. In order to use these features, we may ask you to provide certain information about the person with whom you wish to communicate (e.g., name, e-mail address, etc.). Backgrounds 360 collects such information for the purposes of facilitating the requested communication, which may contain a specific promotional message from you (e.g., an invitation to watch a video). Unless stated otherwise, Backgrounds 360will not use this information for other marketing purposes without first obtaining consent from the person to whom the relevant information pertains. Please be aware that when you use any invitation functionality on Backgrounds 360, your e-mail address, name or username, and message may be included in the communication sent to your addressee(s).

C. HOW BACKGROUNDS 360 USES YOUR INFORMATION

Personal Information. Backgrounds 360 identifies the purpose for which your Personal Information is collected, used, or disclosed. If not listed below, we will obtain your express consent for any additional purposes for which we will collect your Personal Information, before or at the time of collection. You can change your consent preferences at any time by contacting us (see the “How to Access and Change Your Personal Information” section below).

By using the Backgrounds 360, you consent to our use of your Personal Information for the following purposes: • communicating with you generally; • processing your transactions; • processing and keeping track of transactions and reporting back to you; • protecting against fraud or error; • providing information or services requested by you; • administering and managing the Backgrounds 360 Site and our business operations; • personalizing your experience with the Backgrounds 360 Site, as well as evaluating statistics on Backgrounds 360 activity. • performing statistical analyses of your behavior and characteristics, in order to measure interest in and use of the various sections of the Backgrounds 360 Site; • communicating with you on other websites; • e-mail communications with you; • delivery of content and information to Third Party Services Providers; • complying with legal and governmental requirements; and/or • fulfilling any other purpose that would be reasonably apparent to the average person at the time that we collect it.

Non-Personal Information. Backgrounds 360 may use Non-Personal Information for the following purposes: • System Administration: To assist in diagnosing problems with Backgrounds 360 servers, monitoring Backgrounds 360’s system performance and traffic on Backgrounds 360 and to gather broad demographic information about Users. • Personalization: The use of Cookies and IP Addresses to track features such as delivering Content specific to your interests and informing you of new, relevant services or certain third-party offerings. • Advertising: To assist in optimizing the delivery of advertisements to viewers of your Content.

D. HOW TO ACCESS AND CHANGE YOUR PERSONAL INFORMATION

Updating Your Personal Information. Upon request, Users shall be authorized to update, or correct Personal Information previously submitted, but only to the extent such activities do not compromise privacy or security interests. Additionally, upon request, Backgrounds 360 shall endeavor to delete Personal Information from the database where such information is stored. Even through compliance with a deletion request, Users are cautioned that residual information may remain due to the manner in which data backups are maintained. Requests may be submitted to info@backgrounds360.com.

E-mail Preferences. Backgrounds 360 may use your Personal Information to send you e-mails periodically listing promotions or events relating to Backgrounds 360 or from Backgrounds 360’s marketing partners or sponsors. You may opt-out of receiving such promotional e-mails by sending an e-mail to info@backgrounds360.com and/or following the instructions in such correspondence. Once processed, Backgrounds 360 will not send you promotional e-mails unless you opt back in to receiving such communications.

E. DISCLOSURE OF INFORMATION TO THIRD PARTIES

Backgrounds 360 sells, transfers, or otherwise discloses, or trades your Personal Information to outside parties pursuant to the limitations expressed below. We will not sell, transfer, disclose or trade Personal Information in contravention of law. • Disclosure of Personal Information to trusted third party service providers who assist us in administering and providing Backgrounds 360 or provide services to us. Examples include storing and managed Content, analyzing data, providing marketing assistance, integrations of Third-Party Services such as CRM and MAP services, processing credit card payments, and providing customer service. These third-party service providers will have access to Personal Information needed solely to perform their functions, and for no other purposes. We may use service providers located outside of Canada, and, if applicable, your Personal Information may be processed and stored in other countries and therefore may be subject to disclosure under the laws of those countries. • Disclosure of Payment Information with third parties for purposes of fraud prevention or to process payment transactions. • Release of information to comply with law enforcement and regulatory mandates, as otherwise required under any applicable law, regulation or rule, enforce our policies, or protect our, or others’ rights, property or for safety. • Bankruptcy or Acquisition. Information, including Personal Information, which we collect from Users and viewers, is considered to be a business asset. As a result, in the unlikely event that we go out of business, enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Information may be disclosed or transferred to the third-party acquirer in connection with the transaction. • Certain Identifiable Usage Information. Backgrounds 360 may provide Users with certain identifiable usage information directly related to the videos and/or other Content Users make available through use of Backgrounds 360. This information may include the number and specific content watched by a particular viewer; the viewer’s specific location during viewing, and the frequency with which a particular viewer watched particular Content. In addition, if you, as a viewer, provide Personal Information (e.g. e-mail address) as part of accessing and viewing Content, Backgrounds 360, a provider of Third Party Services or an Integrated Platform on behalf of the User who owns the Content and shared with that User or Third Party Service providers to that User, may collect that Personal Information as we and others are their service provider. The use of such information will be subject to the information and privacy practices and policies of such Users and Backgrounds 360 will not be responsible or liable for the use of any information by such Users. • Under certain exceptional circumstances, Backgrounds 360 may have a legal duty or right to collect, use or disclose your Personal Information without your knowledge or consent. In accordance with applicable laws, We will not disclose any consumer information (which may include Personal Information) without your written consent, except where consumer information is required to be disclosed: (i) for billing or market operation purposes; (ii) for law enforcement purposes; or (iii) for the purpose of complying with a legal requirement. • If your Personal Information is shared with third parties other than Users, those third parties may be, but are not always, subject to appropriate agreements with Backgrounds 360 and/or its Users to secure and protect the confidentiality of your Personal Information. • We may also provide non-Personal Information to other parties for marketing, advertising, or other uses.

F. SAFEGUARDING YOUR PERSONAL INFORMATION

Backgrounds 360 is committed to protecting your data and your privacy. Backgrounds 360 takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of Personal Information. These include, but are not limited to, internal reviews of: (a) Backgrounds 360’s data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where Backgrounds 360 stores Personal Information. However, due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information, and we expressly disclaim any such obligation. All Backgrounds 360 employees, contractors and agents who access Personal Information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of Personal Information. Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

G. THIRD PARTY WEBSITES AND SERVICES

Backgrounds 360 may contain links to third party websites, applications, or services (collectively, “Third Party Services”) not owned or controlled by Us. Links to Third Party Services are intended for convenience only. We have no control over these Third-Party Services, their privacy policies, the content they display on their websites and their data collection practices. Backgrounds 360: (a) has no responsibility or liability for these independent privacy policies or actions; (b) is not responsible for data collection practices or the content of such websites; and (c) does not make any warranties or representations about the content, products or services offered on such websites or the security of any information you provide to them. If you choose to submit Personal Information while visiting these websites, please be aware your rights will be governed by the third parties’ privacy policies. We strongly encourage you to carefully read the privacy policy of any website you visit or use. If you would like to receive a copy of our privacy policy, please contact us and we will provide a copy in the manner requested.

H. HOW TO CONTACT US

If you have any questions or concerns about our privacy policy or privacy practices, you may contact us directly as follows:

Email us: info@backgrounds360.com Phone: 415-595-0876 or: Backgrounds 360, LLC 3481 Huellmantel Drive Traverse City, MI 49685