Privacy Policy

Introduction

This Privacy Policy outlines the manner in which Policy Sage ("we", "us", or "our") collects, uses, maintains, and discloses information collected from users (each, a "User") of our services. It applies to all products, services, and websites offered by Policy Sage. We obtain explicit consent for the collection and processing of personal data through a clear affirmative action, such as checking a box or clicking an "I agree" button, when users first access our services or create an account. By providing this consent or continuing to access or use our services, Users agree to the collection and use of information in accordance with this Privacy Policy.

We are committed to protecting the privacy and security of our Users' information. This Privacy Policy is designed to inform Users about their privacy rights and how they can exercise them. We encourage Users to read this Privacy Policy carefully to understand our practices regarding their information and how we will treat it.

Scope of Policy

By accessing or using our services, you acknowledge and agree to the terms outlined in this Privacy Policy and consent to the collection, use, and sharing of your information as described. We adhere to the principle of data minimization, ensuring that we collect, use, and store only the minimum necessary amount of personal data required to fulfill the specified purposes. The provision of personal data is voluntary. However, please note that if you choose not to provide certain required information, you may be unable to access or fully utilize actions, or services. For certain types of personal data or specific processing activities, we may seek your explicit consent before collecting or using your information. If you do not agree with the practices described in this policy or do not provide consent when requested, you should not use our services.

For the purposes of this Privacy Policy, 'Personal Information' or 'Personally Identifiable Information (PII)' means any information that can be used to directly or indirectly identify an individual, including but not limited to: full name, email address, phone number, physical address, social security number, driver's license number, passport information, IP address, device identifiers, and any other unique identifier that can be traced to a specific person.

We recognize the sensitive nature of certain types of personal information. Sensitive data, which may include but is not limited to health information, financial details, racial or ethnic origin, political opinions, religious beliefs, or biometric data, receives additional protection. We only collect sensitive data when necessary, with explicit consent, and ensure it is processed with the highest level of security and confidentiality. We implement strict access controls and additional encryption measures for any sensitive personal information we may collect.

By accessing or using our services, you acknowledge and agree to the terms outlined in this Privacy Policy and consent to the collection, use, and sharing of your information as described. The provision of personal data is voluntary. However, please note that if you choose not to provide certain required information, you may be unable to access or fully utilize our services. For certain types of personal data or specific processing activities, we may seek your explicit consent before collecting or using your information. If you do not agree with the practices described in this policy or do not provide consent when requested, you should not use our services.

We maintain comprehensive records of user consents, including the exact date and time when consent was given. These records are securely stored and can be referenced to verify the specifics of your consent at any time. By providing your consent, you acknowledge that we will keep a detailed log of your consent, which includes the timestamp of your affirmative action.

Information Collection

This Privacy Policy outlines the types of information that Policy Sage ("we," "us," or "our") collects from you ("User" or "you") when you use our services ("Services"). We collect and process personal data on the following legal bases: (1) User consent, (2) Contractual necessity for providing services, and (3) Legitimate business interests in compliance with applicable data protection laws. We are committed to protecting your . We only collect information that is necessary for the stated purposes outlined in this policy. For the purposes of this policy, 'personal data' or 'personally identifiable information' (PII) refers to any information relating to an identified or identifiable natural person, such as name, email address, phone number, location data, or online identifiers.

We collect information in the following ways:

1. Information You Provide: We collect information you provide directly to us when you use our Services, create an account, communicate with us via contact forms or email, or otherwise interact with us. This information may include, but is not limited to, your name, email address, phone number, and any other information you choose to provide.

2. Information We Collect Automatically: When you access or use our Services, we automatically collect information about you, including:

o Your IP address and browser type.

o Details of your visits to our website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the website.

o Information about your computer and internet connection, including your device's unique device identifier, operating system, and browser type.

3. Third-Party Cookies: We use third-party cookies and tracking technologies from selected partners to enhance user experience, provide analytics, and support advertising efforts. These may include cookies from analytics providers, advertising networks, and social media platforms. These technologies collect various types of data, including but not limited to: browsing history, device information, IP address, location data, and interaction with our services. Third-party cookies help us understand user behavior, improve our services, and provide personalized content and advertisements.

By using our Services, you consent to the collection, use, and sharing of your information as described in this Privacy Policy, including the use of cookies and tracking technologies. We provide granular consent options through our privacy settings, allowing you to choose which types of cookies and tracking technologies are used. You can access and modify these settings at any time through your account preferences or our cookie management tool. To withdraw your consent for cookies and tracking technologies, you can clear your browser's cookies, adjust your browser settings to block cookies, or use the opt-out mechanisms provided in our cookie management tool. Please note that withdrawing consent may affect your user experience and the functionality of certain features. Please review this Privacy Policy and your privacy settings carefully to understand our practices regarding your information and how we will treat it.

Use of Information

The Data Controller, Policy Sage, uses the information collected from users for a variety of purposes, including but not limited to:

Our legal basis for processing your personal data includes: your consent, performance of a contract with you, compliance with our legal obligations, and our legitimate interests in conducting our business operations. The specific legal basis for processing your data will depend on the context and purpose of the processing.

• Improving the services provided to users;

• Personalizing user experience on our platforms;

• Providing customer support;

• Processing transactions;

• Conducting research and analysis to enhance product and service offerings;

• Communicating with users about services, offers, promotions, rewards, and events sponsored by Policy Sage or its partners;

• Protecting against, identifying, and preventing fraud and other criminal activity, claims, and other liabilities;

• Complying with applicable legal requirements, including laws, regulations, court orders, and government and law enforcement requests.

This list is not exhaustive and may be updated from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons.

Information Sharing and Disclosure

• We may share your personal information with the following categories of third parties: law enforcement agencies, public authorities, service providers, business partners, professional advisors, and our affiliated companies. We will not share, sell, rent, or trade your personal information with third parties for their commercial purposes without your consent. To comply with legal obligations or respond to valid legal process, such as a search warrant, a court order, or a subpoena.

• In response to a request from law enforcement agencies or other public authorities.

• To protect the rights, property, or safety of Policy Sage, our customers, or the public.

• In connection with a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

• With your consent or at your direction, including if we notify you through our services that the information you provide will be shared in a particular manner and you provide such information. This consent may also extend to our third-party partners, with whom we may share your information for specific purposes as outlined in this policy. We will provide clear notification to users before sharing their personal data with any third-party partners, and users will have the opportunity to review and consent to such data sharing. The extent of data sharing with third-party partners will be limited to what is necessary for the fulfillment of the identified purposes.

We will not share, sell, rent, or trade your personal information with third parties for their commercial purposes without your consent.

Data Security

The Data Controller, Policy Sage, is committed to ensuring the security of your personal data. We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and against accidental loss, destruction, or damage. These measures are designed to provide a level of security appropriate to the risk of processing your personal data.

Among the security measures we employ are:

• Encryption of data in transit and at rest

• Secure server configurations

• Access control measures

• Regular security assessments and updates

We also ensure that any third parties processing personal data on our behalf are subject to security requirements consistent with this policy and applicable laws. In the event of a data breach, we have a comprehensive response plan in place. This plan includes immediate containment measures, a thorough investigation process, and timely notification to affected individuals and relevant authorities as required by applicable laws.

Your Rights and Choices

As a Data Subject under applicable data protection laws, you have certain rights regarding the personal information that Policy Sage collects and processes. These rights include the ability to object to automated decision-making and profiling. Policy Sage does not currently use automated decision-making processes that significantly affect individual rights. If such processes are implemented in the future, we will provide clear information about their use and your right to object:

• The right to access your personal data held by Policy Sage.

• The right to request the correction of inaccurate personal data.

• The right to request the deletion of your personal data when it is no longer necessary for Policy Sage to retain it.

• The right to object to the processing of your personal data in certain circumstances.

• The right to request the restriction of processing your personal data in certain circumstances.

• The right to data portability, allowing you to obtain and reuse your personal data for your own purposes across different services.

To exercise any of these rights, please contact Policy Sage directly. We will respond to your request within 30 calendar days of receipt, in accordance with applicable data protection laws. We do not charge a fee for exercising your rights, except in specific circumstances allowed by law, such as when requests are manifestly unfounded or excessive.

Data Retention

This Privacy Policy outlines the data retention practices of Policy Sage ("the Data Controller"). We are committed to ensuring that your personal data is stored securely and retained only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Policy.

Personal data collected by us will be retained in accordance with the following criteria:

1. The length of time your personal data is needed to provide you with our services or to operate our business effectively.

2. Any legal, regulatory, or contractual requirements that require us to retain your data for a certain period of time.

3. The necessity to retain data for the purposes of legal claims, compliance, regulatory, and investigative purposes.

We will regularly review the data we hold and delete or anonymize it when it is no longer needed. If data is anonymized, it will be done in such a way that you are no longer identifiable from the information.

Upon the expiration of the retention period, your personal data will be securely deleted or anonymized, unless there is a legal or regulatory requirement to retain it for a longer period.

International Data Transfers

Policy Sage ("Data Controller") may transfer personal information to countries outside of the jurisdiction in which it was originally collected. Such transfers will only occur to countries that provide an adequate level of data protection as recognized by applicable privacy laws. These transfers will be conducted in compliance with applicable data protection laws. Policy Sage ensures that all international data transfers are subject to suitable safeguards, such as standard contractual clauses approved by relevant authorities or other legally recognized mechanisms that ensure an adequate level of protection of personal data. In some cases, third-party service providers may be involved in these international transfers. These third parties act as data processors and are contractually bound to process your data only as instructed by Policy Sage and in compliance with this Privacy Policy and applicable data protection laws.

Policy Sage will obtain explicit consent from users before transferring their personal information internationally. This consent will be separate from the general acceptance of our services. By providing this explicit consent, you agree to the transfer of your personal information in accordance with this clause. Further details on the specific safeguards applied to your personal data transfers can be provided upon request.

Changes to the Privacy Policy

The Data Controller reserves the right to update or modify this Privacy Policy at any time and without prior notice, to reflect changes in our personal information practices or relevant laws. Any changes will be effective immediately upon the posting of the revised Privacy Policy on our website. We will make reasonable efforts to notify you of any significant changes through our website or through direct communication, where applicable. These notifications will be provided in clear, understandable language to ensure you can easily comprehend the changes. However, we encourage you to review this Privacy Policy periodically to be informed about how we are protecting your personal information.

By continuing to use our services after these changes are made, you acknowledge and agree to the updated Privacy Policy. If you do not agree to the changes, you should discontinue use of our services. We will also update the "Last Updated" date at the top of the Privacy Policy, which reflects the effective date of such changes.

Contact Information

If you have any questions about this Privacy Policy, or if you wish to exercise any of your rights regarding your personal information, please contact the Data Controller directly. You can reach us in the following ways:

• By email at: [email protected]

• By mail at: Policy Sage, Privacy Department, 1000 Ballpark Way STE 310, Arlington, TX 76011

Your inquiries will be handled with the utmost care and urgency, ensuring your rights are fully respected in accordance with the applicable laws and regulations governing personal information within our jurisdiction.