SMARTBOARD, LLC

THIS PRIVACY POLICY APPLIES TO YOUR ACCESS AND USE OF THE COMPANY’S ONLINE SERVICES, INCLUDING USE OF OUR WEBSITE, APPLICATIONS, SOFTWARE, GENERAL SERVICES, AND OTHER ONLINE PROGRAMS (COLLECTIVELY THE “ONLINE SERVICES”). BY DOWNLOADING OR USING ANY OF THE ONLINE SERVICES, YOU ARE AGREEING THAT YOU HAVE READ AND AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DISAGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE ANY OF THE ONLINE SERVICES.

We want you to enjoy every visit to our website. Whether you are leaving us a comment, making a suggestion, or using our Mobile Application, Smart Driver (“Mobile App”), please understand that we do collect information about you and we may share that information with third parties in certain circumstances, so please read the details about how we use personal information that we collect about you when you use the Online Services. Company controls and operates its business and the Online Services from within the United States of America. Our online privacy practices are governed by the laws of the United States and the State of Illinois, which may differ from privacy laws in your state or home country. By submitting your personal information to us or our agents, through the use of the Online Services, you consent to the transfer of your personal information to any country and its use and disclosure in accordance with applicable U.S. Federal and State laws and with this

We may update our Privacy Policy from time to time, so please Review the Privacy Policy from time to time. If we make material changes to the Privacy Policy we will inform you in advance by posting a notice within the Online Services, or by US mail.Your continued use of the Online Services, after we publish any updates, indicates your acceptance of any changed or updated terms of the Privacy Policy.

1. KINDS OF INFORMATION COMPANY COLLECTS.

We collect the information that you voluntarily provide to us when using our Online Services. Regardless of whether you access Online Services from your computer, smartphone, or tablet, Company and its agents collect information that identifies you or relates to you as an individual (“Personal Information”), such as your: name; mailing address; telephone number; e-mail address; username and password (for account administration); device ID, including IP address, model and manufacturer, operating system or platform, telephone network provider; geolocation, mobile camera, storage (if using the Mobile App and you consent to providing it); financial account information and other payment information (that you submit to us for order or payment processing); and additional personal information necessary for the administration of certain promotional events. We may also request to send you push notifications which can opt-out of or disable in the settings of the Mobile App. Additionally, we may collect other types of data elements(“Other Information”) that do not reveal your identity or that do not relate directly to you or any other individual, such as: browser and device information, including operating system; demographic information and other information provided by you that we may combine with other users of the Online Services or use on its own; mobile application usage data; aggregated information such as “click stream” information such as entry and exit points for the Online Services (including referring URLs or domains), certain Online Services traffic statistics, page views, and impressions; and information collected through cookies, pixel tags and other technologies described in more detail later in this Privacy Policy. In addition, when users request pages on the Online Services, our servers automatically log the IP address of the particular user. The IP address is a unique number assigned to your computer in order to identify it whenever you are surfing the Web.

2. HOW WE USE THE PERSONAL INFORMATION WE COLLECT.

We may use Personal Information about you for legitimate business purposes as described in this Privacy Policy or as otherwise disclosed to you through the Online Services, for the fulfillment of our contract with you, for compliance or legal obligations. For example, we may use Personal Information to: facilitate account creation and logon process, manage user accounts, process and manage your purchase and use of our products and services; respond to your inquiries, requests, or post your comments or statements on message boards or in our online forums; send administrative information to you, enforce our terms, protect our Online Services, create and deliver personalized promotions, and facilitate the the delivery of services and benefits you receive; communicate with you by mail, telephone, facsimile, e-mail, mobile alerts and SMS text messaging about Company or Compass Affiliates, including about orders or purchases, your services, accounts, contests you entered into, your requests for information, and to update you about changes to the Online Services; communicate with you, including by mail, telephone, facsimile, e-mail, mobile alerts and SMS text messaging, in connection with our marketing efforts, such as when we send you offers and promotions that you can take advantage of through the Online Services. Further and for our business purposes, such as to perform data analysis, audits, fraud monitoring and prevention, to enhance, improve or modify the Online Services, to identify usage trends, determine the effectiveness of our promotional campaigns and to operate and expand our business activities; and assist in the assessment of your application for various Company services. We may send you “transactional or relationship” communications to you, such as notices to facilitate a transaction you have conducted or messages that provide information about your existing account, using various electronic communication, including email and mobile communications. You must opt-out to stop the receipt of emails and mobile communications (other than “transactional or relationship” communications referenced above), including SMS text messages from Company. Any usage of your information will be subject to this Privacy Policy and we will only email you, send you mobile alerts or SMS text messages if you have not opted-out of receiving such communications from us. If, at any time, you decide you would rather not receive these types of communications from Company, you can opt-out by clicking the unsubscribe link at the bottom of any Company email, in the customer portal, or simply by email us as: support@smartboardtms.com. Please give us at least 72 hours from the time we receive your request to remove from our email and mobile communications pool.

3. HOW WE MAY DISCLOSE PERSONAL INFORMATION WE COLLECT.

Your privacy is very important to us. We generally will not disclose your Personal Information to anyone outside of Company, except in the following circumstances. a. Service Providers. We may disclose your Personal Information to third-party service providers who provide us with services such as website hosting, professional services, including information technology services and related infrastructure, customer service, e-mail delivery, auditing and other similar services. b. Compass Affiliates. We may disclose personal Information to our Compass Affiliates (“Compass Affiliates”) for the purposes described in this Privacy Policy, including for marketing purposes, and to be consistent with our goal of providing our consumers with the superior product and consumer experience that our customers have come to expect from us around the globe. Compass Affiliates are those companies that are under the Compass Holding brand as set for www.compassholding.net. c. To Perform Services You Request. We may disclose your Personal Information to third parties in order to perform services you request or functions you initiate, such as when you post information and materials on message boards and forums, including on our Facebook Page. When you post information in a public forum it becomes public information. In addition, we may disclose your Personal Information in order to identify you to anyone to whom you send communications through the Online Services, including through our gifting program. d. Corporate Transactions or Events. We may disclose your information to a third party in connection with a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings. e. Other Legal Reasons. In addition, we may use or disclose your Personal Information as we deem necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (3) to comply with subpoenas and other legal processes; (4) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our Affiliates; (6) to protect the rights, privacy, safety or property of Compass, our Affiliates, you and others; and (7) to enforce our terms and conditions.f. With your consent.

4. HOW WE MAY USE AND DISCLOSE OTHER INFORMATION WE COLLECT.

Similarly, we generally use Other Information for any purpose not prohibited by law. In particular, we may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all Other Information, provided that such information does not personally identify you. The Other Information that we collect generally will not personally identify you or be correlated to you individually for external purposes. Where we combine Other Information with Personal Information in a way that can identify you or be used to identify you personally, we will treat that information as Personal Information, subject to the provisions of this Privacy Policy.

5. HOW TO MANAGE YOUR ACCOUNT INFORMATION.

You can visit the account section of the Compass Online Services website to manage and correct any factual inaccuracies in the information we have on file about you.

6. HOW WE PROTECT YOUR PERSONAL INFORMATION.

Company has implemented reasonable safeguards designed to prevent loss, misuse and unauthorized access, disclosure or modification of Personal Information provided or collected through our Online Services. With respect to payment card information and other Personal Information collected through our Online Services, we use Secure Socket Layer Technology or SSL to encrypt or scramble that information during transmission. Unfortunately, no system or online transmission of data can be guaranteed to be 100% secure and you should always take appropriate security measures to protect your Personal Information, including ensuring that you have up-to-date antivirus software. If you believe that your Compass account or any information you provided to us is no longer secure, please notify us immediately through the Contact Us information provided below.

7. COOKIES, INTEREST-BASED ADVERTISING AND “DO NOT TRACK”.

Cookies are small text files placed in your computer browser directories to store your information about your use of the Compass Online Services and your activities online (collectively, “Cookies”). A Cookie will typically contain the name of the domain (internet location) from which the Cookie has come, the “lifetime” of the Cookie (i.e. when does it expire), and a value, usually a randomly generated unique number. We use Cookies so that we can improve your online experience – for example, by remembering you when you come back to visit us, and making the content you see more relevant to you. Cookies also enable us to track online purchases made through the Online Services. If you do not wish to receive Cookies or wish to manage when you accept Cookies in general, you may set your browser to reject Cookies or to alert you when a Cookie is placed on your computer. Although you are not required to accept our Cookies, if you set your browser to reject Cookies, you may not be able to use all of the features and functionality of the Online Services. The Help feature on most browsers will tell you how to prevent your browser from accepting new Cookies, how to have the browser notify you when you receive a new Cookie, or how to disable Cookies altogether. If you block or otherwise reject our Cookies, you may lose some of the functionality of our site. For example, you may not be able to add items to yourShopping Cart, proceed to Checkout, or use any products and services that require you to sign in. Online Services also use Cookies and other technologies such as pixel tags, web beacons and clear GIF files (collectively, “Data Collection Technologies”) to help manage our online advertising program. These Data Collection Technologies are provided by our ad management partners and other third parties. In addition, we may use these Data Collection Technologies to track the actions of users of the Online Services, to measure statistics of our marketing efforts, and to deliver advertisements on the Online Services that may be more relevant to individual consumers and that will improve the consumer experience on the Online Services. For example, if you give us your zip code and we thus know you live in an area where a particular in-store promotion is going on, we may deliver to you an advertisement that is specific to that promotion. If you want to “opt out” of receiving our emails, please email us at: support@smartboardtms.com and insert “Opt-Out” in the subject line. Please permit us at least 72 hours from the time we receive your request to remove from our email and mobile communications pool.

8. HOW LONG MAY WE KEEP YOUR PERSONAL INFORMATION.

Generally we keep your Personal Information as long as we need to in order to fulfill our contractual obligations to you, for as long as is set forth in this Privacy Policy, or for as long as is otherwise required by law. Nothing herein requires that we keep your Personal Information longer than ninety (90) months after your account is terminated or otherwise closed. At the expiration of the period set forth herein, we will either delete your information, or securely store and insolate your Personal Information from any further use until such time as we are able to delete it permanently.

9. SOCIAL NETWORKING AND THIRD PARTY SITES.

When you link to the Online Services through any social networking or third party sites, applications or services, please remember that you are bound by the privacy policy of the social network or third-party site, application or service, and we do not control and are not responsible for the privacy practices of such sites. You should consult the privacy policy of such sites to determine the information practices of those sites.

10. GOOGLE MAPS.

We use Google Maps solely for the purpose of providing a better service. Our use of Google Maps is subject to Google’s Terms of Service. See link: https://cloud.google.com/maps-platform/terms/. We may also use Google Maps Application Programming Interface to retrieve information necessary for your location specific requests, ie. GPS location either continously or while you are using the Mobile App. Revocation of this permission can be made at anytime by disabling the “GPS Locaion” in the Mobile App’s settings.

11. CHILDREN’S ONLINE PRIVACY.

Compass recognizes the importance of protecting the privacy of children. We will not knowingly collect any personally identifiable information from children under the age of thirteen (13). Whena user discloses personal information on the Online Services, the user is representing to us that he or she is at least thirteen (13) years of age. If a child under the age of thirteen (13) has provided us with personally identifiable information through the Online Services, we ask that a parent or guardian email us at support@smartboardtms.com, and we will delete the child’s information from our records.

12. CALIFORNIA RESIDENTS.

Pursuant to California’s Shine the Light” law, codified at Section 1798.83 of the Civil Code, users who are California residents may request and obtain from us an annual report, free of charge, of information about categories of Personal Information (if any) that we disclosed to third parties for direct marketing purposes along with the names and addresses of all third parties with whom we shared Personal Information in the immediately preceding calendar year. If you are a California resident, please submit your request in writing to support@smartboardtms.com with a subject line of “California Resident – Annual Report” or you may mail your request to Smartboard, 115 55 th Street, 4th Floor, Clarendon Hills, IL 60514, Attn. Legal Department.

13. CALIFORNIA RESIDENTS UNDER THE AGE OF 18.

California Residents under the age of 18 who have a registered account with Online Services has the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us by email at: support@smartboardtms.com with a subject line of “California Resident – Under 18” or you may mail your request to Smartboard, 115 55th Street, 4th Floor, Clarendon Hills, IL 60514, Attn. Legal Department. We will work to insure that any date you posted is not publicly displayed on the Online Services (system backups excluded).

14. INTERNATIONAL.

This English-language Privacy Policy is Company’s official statement of its Online Services privacy practices. In case of any inconsistency between this English-language Privacy Policy and its translation into another language, this English-language document prevails.

15. CONTACT US.

If you have any questions regarding our privacy practices, you can email us at legal@compassholding.net. You also can telephone us at (630) 560-4890, or you can write to us at Smartboard, LLC, 115 55th Street, 4th Floor, Clarendon Hills, IL 60514, Attn. Legal Department.