Privacy Policy

Effective: September 1, 2020

WE RESPECT YOUR PRIVACY

This privacy policy (this “Privacy Policy”) explains what information True Rate Services LLC (together with our affiliates and subsidiaries, collectively, “we”or “us”) collects from you when you use our website (the “Website”) or interact with our third- party partners (“Partners”). By using our Website, you agree to all the terms and conditions stated in this Privacy Policy. Please take a moment to review this information.

How We Protect Your Information

We take reasonable measures to protect your personally identifiable information(“Personal Information”) to prevent against unauthorized use, access, disclosure, and destruction. Please be aware that, despite our best efforts, security measures are not impenetrable, and we can’t guarantee against misuse.

What Information We Collect

Contact Information

If you choose to contact us using the “Contact Us” link or otherwise communicate with us in anyway via the Website, we may collect your contact information, such as your name and email address, in order for us to communicate with you.

If you write a message, we may also store the message so we can reference it to tailor our responses to you if appropriate.

Website Visitor Data

Directly or through the use of third-party data analytics services, we collect visitor information, including your IP address and server log data (the address of the web page you visited before using the Website, your browser type and settings, the date and time of your use of the Website, and language preferences).

We may gather your information about the device you are using to access our Website, including what type of device it is, what operating system you are using, device settings, application IDs, location, unique device identifiers, and crash data. Other data is collected, including data generated by your use of the Website and links you interact with.

Other Data for Special Events

We may occasionally collect additional personal information that you voluntarily submit to us through the Website for other purposes, such as in connection with invitations to special events where an RSVP response and associated information is necessary for the event.

How We Use Your Information·

We use your information to operate, manage, and improve our Website and for marketing and administrative purposes.· If you communicate with us, we will send you newsletters and marketing information about our services, until you decide to opt out. We may also send you notifications, updates, and changes about our Website and contact you to provide customer service and support.· We may use your Personal Information, including any information you share with us, to improve our service or to facilitate special events connected to our company or services.

We may use your information to comply with legal or regulatory requirements, to respond to lawful requests, court orders and legal process, to enforce our rights, to prevent fraud, and to protect the security of the Website.· We may use your IP address and location data to analyze usage, administer our Website, and gather demographic information for aggregate use.· With your consent, we may use your Personal Information in other ways.

How we share your information

We do not knowingly sell, trade or otherwise share your Personal Information with any third parties without your consent, except as disclosed in this Privacy Policy, as required by law, or when we reasonably believe it is necessary to prevent or take action regarding illegal activities, suspected fraud, or to protect the safety of any person.

We may share Personal Information in collaboration with our Partners, including companies that assist with business analytics, data processing, customer and user management, and other services. We instruct these parties to use your Personal Information only to the extent necessary to provide the services we have requested.

Although we take reasonable steps to ensure that Partners receiving your information are bound by privacy restrictions as restrictive as those set forth in this Privacy Policy, we are not responsible for any issues that may arise regarding the privacy policies or practices of any Partners. By using the Website, you agree that we are not responsible or liable for any claims and/or damages that may arise from the actions of any of our Partners.

Social Media

If you click on our social media links (such as Facebook, LinkedIn, Medium, Youtube, Instagram and Twitter), you will be directed to a third-party platform, and any information you share on those websites will be covered by their privacy policies.

Cookies and Other Technologies

What are cookies?

A cookie is a small file that can be placed on your computer’s hard disk or on a website server. Cookies do not retrieve information stored on your hard drive and do not corrupt or damage your computer or computer files. For those using the Website, we may link cookie information to your email address to maintain and recall your preferences within the Website.

Why we use cookies

We may use cookies and similar tracking technologies to improve or administer the Website, analyze trends, track users’ movements around the Website, support security features on the Website, and to gather demographic information about our user base.

How to disable cookies

Although most browsers and devices accept cookies by default, their settings usually allow you to delete or decline cookies. If you disable cookies, however, some of the features of the Website may not function properly. You may opt out of receiving certain cookies and certain trackers by visiting the Network Advertising Initiative (NAI) opt-out page or the Digital Advertising Alliance(DAA) consumer opt-out page.

Please note that the reference (and link) to NAI and DAA are for informational purposes only. We do not, in any way, endorse or approve of any information contained on such websites as the same are owned and operated by unaffiliated third parties. Any questions or concerns with respect to such websites should be directed to the owners of the same.

Opt-In / Opt-Out of Communications

By using the Website, you expressly allow us to contact you and use your information as set forth in this Privacy Policy. You may opt-out of receiving marketing emails anytime by clicking the “unsubscribe” button in the email.

Links

The Website provides a link for investors to a third-party platform and may also provide links to other third-party websites. Our decision to link to a third-party website is not an endorsement of the content, products or services in the third-party website.

We do not control these third-party websites and expressly disclaim any responsibility for the content, the accuracy of the information and any products or services available on the third-party websites. We have not investigated or monitored the third-party websites for accuracy or completeness. The third-party websites may have different privacy policies and security standards than our Website.

Your Choice to Access, Edit, or Delete Information.

We strive to provide you with as many choices and as much control as possible regarding your Personal Information. You have the right to access and change your Personal Information. Please contact us at the address provided at the bottom of this Privacy Policy to find out how. We will, upon receiving your request, make reasonable efforts to correct, delete, and/or block your Personal Information from further use to the extent that it remains in our possession, except to the extent not permitted by law.

Minors

Our Website is not directed to children under 13. If you learn that a child under13 has provided us with Personal Information without consent, please contact us. If we become aware that a child under 13 has provided us with his or her Personal Information, we will promptly delete it.

Business Transitions

In the event we go through a business transition, including without limitation merger, acquisition, partnership, business reorganization, debt finance, or sale of company assets, or in the event of an insolvency, bankruptcy, or receivership (together a Business Transition), we may use information collected in accordance with this Privacy Policy and subject to its restrictions, as part of any such Business Transition. In such instances, your information can be part of the assets transferred.

Do-Not-Track

You may have implemented a “do not track” signal through your browser. As there currently is no fixed standard for do-not-track signals, we currently do not respond to these signals from your web browser.

Data Retention and Destruction

We will retain Personal Information for as long as necessary to accomplish our purposes for such data. You can request that your information be deleted by contacting us at the address provided at the bottom of this Privacy Policy. At the time your information is deleted, we will destroy your Personal Information using reasonable data-destruction practices.

We may, however, retain certain information to comply with legal or contract obligations or to facilitate law enforcement requests.

California Privacy Rights

If you are a California resident, you may ask us for a notice identifying the categories of Personal Information that we share with our Partners and/or third parties for marketing purposes and to refrain from sharing your Personal Information with certain of these entities for their marketing purposes. Please tell us your preference by contacting us at the address provided at the bottom of this Privacy Policy. In your request, please specify that you want a “TrueRate Services’ California Privacy Rights Notice.” Please allow 30 days for a response.

Changes

We may revise this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post the revised policy here. If changes are significant and materially affect your rights under this Privacy Policy, we may provide a more prominent notice on the Website. In certain cases, we may also provide email notification of the revised Privacy Policy and either seek your consent or give you the right to opt out from our use of your Personal Information in accordance with the revised Privacy Policy.

However, as we may make changes at any time without notifying you, we suggest that you periodically consult this Privacy Policy. Please note that our rights to use any information collected will be based on the Terms of Use and Privacy Policy in effect at the time the information is used.

Contact Us

If you have any questions about the Privacy Policy, please contact us.