1. The Scope of this Policy 7Square Investments Inc. (the “Company,” “7square,” “we,” “us” or “our”) is committed to respecting the privacy rights and concerns of all users of the Company’s website (the “Site”), software applications (the “Apps”) and services (we refer to the Site, the Apps and the services and the software made available by the Company through the Site and Apps, collectively, as the “7square Service”). As such, we have established and implemented this Privacy Policy to inform visitors to the Site and Apps and users of the 7square Service how we use and protect the information we collect through the Site and the 7square Service. By visiting the Site or the Apps or using any of the 7square Service, you consent to the Company’s collection, use, storage, deletion and disclosure of information relating to you as set forth in this Privacy Policy. This Privacy Policy is effective as of the date set forth above and is only applicable to the Apps, the Site and the 7square Service and not to any other website, tablet or mobile application that you may be able to access from the Apps, the Site or the 7square Service which may have its own data collection and use practices and policies. 2. The Information We Collect Types of Information We Collect Personal information means information that can be used to identify and contact you. You need to submit personal information to access the Apps, the Site and the 7square Service. To create an account for the 7square Service, we require you to provide certain information to create your profile, including your name, password, certification information, email address and phone number. We may also collect financial qualification and billing information, such as billing name and address and credit/debit card information. Depending on your choices when using the 7square Service, we may collect additional personal information. In connection with your use of certain 7square Service, we will also collect the personal information of your clients, including, but not limited to, your clients’ name(s), loan information, relevant financial institution(s) information and the address of the property in question. By submitting personal information through the 7square Service, you authorize the Company to use and share this personal information for the purposes identified herein and in connection with the 7square Service, such as preparing and delivering appraisals to those persons on whose behalf you are submitting information (including, but not limited to, Broker Price Opinions and approved financial institutions, real estate companies and other third parties), responding to user inquiries, processing transactions, and making available the 7square Service and their underlying appraisal systems, methodologies and proprietary data indexes and scores. 3. How We Use Your Personal Information The personal information you provide to us will allow us to provide the 7square Service to you (including its underlying appraisal systems, methodologies and proprietary data indexes and scores; verify your identity; alert you of new products or services, features, or enhancements to the 7square Service; handle your customer service questions or issues; provide for order processing; request feedback; distribute newsletters; and notify you of promotions, contests, surveys updates, or special offers that we think may interest you). We may also use your email address as part of the 7square Service in sending you messages about the 7square Service and other general announcements. We keep track of your interactions with us, including but not limited to your activity within the 7square Service. We may use your personal information to respond to requests in connection with your use of any of the 7square Service. We may also use your personal information to contact you when necessary. We may use the personal information you submit with non-personal information that we have collected in a manner such that the end-product does not personally identify you, your client or any other user of the 7square Service. We may make the personal information you submit non-personally identifiable by either combining it with information submitted by other users (aggregating the personal information you have submitted with the personal information other users have submitted), or by removing characteristics (such as names or email addresses) that make the information personally identifiable. This process is known as de-personalizing your information. You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use such personal information in connection with the creation and development of analytical and statistical analysis tools relating to the use of the customer data we collect in providing the 7square Service (the “Analytical Data”). You expressly authorize us to make any commercial use of the Analytical Data, including without limitation, sharing the Analytical Data with third parties, provided that we do not sell, trade, or otherwise transfer from us any part of the Analytical Data that personally identifies any 7square Service users. Do Not Track In compliance with California legislation, AB370, effective January 1, 2014, our practices in responding to “do not track” signals and collecting user information over time and across a network of websites when you visit the Site are as follows: We do not currently respond to “do not track” signals sent by your browser when you visit the Site. Additionally, we may collect user information about your online activities over time and across different websites, or authorize third parties to do so. Google Analytics We use third-party service providers such as Google Analytics to help us learn about who visits the Site and what pages are being viewed. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics’ collection and use of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. Cookies “Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive. Like many websites, we may employ cookies in certain areas of the 7square Service to allow us to provide information to make your online experience more convenient. While the Company may use cookies to track your visit to the Apps and/or the Site, this information does not identify you personally and you remain anonymous, even if you have previously submitted personal information to the Company through the 7square Service or otherwise. Third parties whose websites or applications are accessible through links provided through the 7square Service may also use their own cookies when you link to their application, site or service. The Company does not control these third parties’ use of cookies and cannot guarantee that they will uphold the same privacy standards as the Company. The Company expressly disclaims any and all liability related to the collection, use or disclosure of information by third parties. You should review the privacy policies of any third party sites that you visit through a link from the Apps, the Site or the 7square Service to understand how these third parties use cookies and the information they collect through cookies. Most cookies are “session cookies” which means that they are automatically deleted at the end of each session. Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you a chance to decide whether or not to accept it. Log Information Our servers automatically record information that your browser sends whenever you visit the Apps or the Site or use the 7square Service. This information includes your Internet Protocol address, your browser type and version, the search engine you used to find the 7square Service, if any, which 7square Service you use and from where, and when and how long you use them. We use this information to monitor and analyze how users use the 7square Service, to provide customer service and to maintain and improve the 7square Service. Children’s Privacy We do not knowingly collect personal information from children under 13, or allow them to create an account for the 7square Service. We take children’s privacy seriously, and encourage parents to play an active role in their children’s online experience at all times. 4. How We Share Your Information with Third Parties Sharing Your Information We use your personal information to provide the 7square Service (including appraisals) to you and those persons on whose behalf you are submitting information (including, but not limited to, approved financial institutions, real estate purchasers and investors, and other third parties), to send communications to you about new services, features, or enhancements to the 7square Service that may be of interest to you and to handle your customer service questions or issues. We will also share the personal information we collect from you under the following circumstances: Protection of rights. We will share personal information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce the ToU or any other agreement, understanding or arrangement between you and 7square, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the 7square Service, or (iv) such action is appropriate to protect the rights, property or safety of the Company, its employees, users of the 7square Service or others. Asset transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of the Company’s assets, user information, including personal information collected from you through your use of the 7square Service, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you through email and/or a prominent notice on the Apps and/or Site. Service Providers. We may share your personal information with service providers (including our affiliates that provide services on our behalf) that we engage for the purpose of processing information on our and your behalf. Additionally, we may partner with other companies to process, analyze, and/or store data, including, but not limited to, Analytical Data. While providing services for us, these companies may access your personal information. To the extent applicable, we require these entities to comply with this Privacy Policy and appropriate confidentiality and security measures. Third Party Privacy Policies Through the 7square Service, you may be able to link to technology, software and services owned and controlled by third parties (the “Third Party Features”). You may be permitted or required to submit personal information to access Third Party Features. Such use of Third Party Features and submission of information through Third Party Features will be subject to such applicable third party’s Terms of Use/Service and Privacy Policy. You agree to look solely to the applicable third party and not to the Company to enforce your rights in relation thereto. When you have clicked on a third party logo or URL displayed on the Apps, the Site or accessible through the 7square Service which links you to any Third Party Features, our Terms of Use (the “ToU”) and any other terms and conditions agreed to by you in connection with the 7square Service no longer apply and you must read the terms of use/service and privacy policy of the third party to see how your personal information will be handled on their website. 5. Your Rights and Choices Regarding Your Information Control of Your Information You may update or delete your personal information or modify your account preferences for the 7square Service by accessing the account interface provided through the 7square Service. Please note that if you disable your account, we will keep your email address and submitted content on file and we may retain other account information for a reasonable period of time afterward for the purpose of internal account management and fraud prevention activities. In addition, you may not have the ability to remove certain submitted content (including submitted content uploaded as part of an appraisal) once uploaded through the 7square Service. For clarity, once any of your information or other submitted content is included within a completed and submitted appraisal or any other product or service generated by or through the 7square Service, it will not be able to be changed or removed. Your Choice to Opt Out If you no longer want to receive our emails or other announcements, you may unsubscribe by following the instructions provided through the 7square Service. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating to your account transactions. 6. How We Store and Safeguard Your Information What security measures do we take to safeguard your personal information? The personal information that you provide to us is stored on servers, which are located in secured facilities and protected by protocols and procedures designed to ensure the security of such information. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of any of the 7square Service and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems. In the event that personal information you provide to us is compromised as a result of a breach of security, when appropriate we will take reasonable steps to investigate the situation, notify you and take the necessary steps to comply with any applicable laws and regulations. 7. California Residents Privacy Rights The California Consumer Privacy Act of 2018 (the “CCPA”) is a California law that gives California residents (“consumers”), the right to learn about and control certain aspects of how a business handles the personal information that a business collects about them. Pursuant to the CCPA, effective January 1, 2020, consumers whose personal information have been collected by us, have certain rights, including: The right to know the categories of personal information we’ve collected and the categories of sources from which we got the information; The right to know the business purposes for sharing personal information; The right to know the categories of third parties with whom we’ve shared personal information; and The right to access the specific pieces of personal information we’ve collected; and The right to delete your information. California residents also have the right to not be discriminated against if they choose to exercise their privacy rights. To learn more about these rights, your personal information under the CCPA, or to exercise your rights, please visit our 7square California Privacy Policy homepage. You can also email us at privacy@7square.com. 8. Changes to this Privacy Policy We may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, We will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your account and cease use of our Services. 9. Contact Us If you have any questions about our privacy practices or this Privacy Policy, please contact us by email at privacy@7square.com.