PRIVACY POLICY

Last updated May 03, 2024

This privacy notice for Virscidian, Inc. ("we," "us,"or "our"), describes how and why we might collect, store, use,and/or share ("process") your information when you use our services ("Services"), such as when you:

Visit our website at https://virscidian.com or any website of ours that links to this privacy notice Engage with us in other related ways, including any sales, marketing or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@virscidian.com.

SUMMARYOF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key pointor by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws. Want to learn more about what we do with any information we collect? Review the privacy notice in full.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS NOTICE?
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?‍

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us‍

‍InShort: We collect personal information that youprovide to us. We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices youmake, and the products and features you use. The personal information we collect mayinclude the following:

• names
• phone numbers
• email addresses
• mailing addresses
• job titles
• usernames
• contact preferences
• contact or authentication data

Sensitive Information. We do not process sensitive information. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/orbrowser and device characteristics — is collected automatically when you visit our Services. We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name orcontact information) but may include device and usage information, such as your IPaddress, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used,this device data may include information such as your IP address (or proxy server),device and application identification numbers, location, browser type, hardware model,Internet service provider and/or mobile carrier, operating system, and systemconfiguration information.

Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be ableto use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer ourServices, communicate with you, for security and fraud prevention, and to comply withlaw. We may also process your information for other purposes with your consent.We process your personal information for a variety of reasons, depending on howyou interact with our Services, including:‍

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products andservices, changes to our terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes,if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.

To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

 InShort: We only process your personal informationwhen we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such,we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e.,consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when webelieve it is reasonably necessary to achieve our legitimate business interests and those interests do not out weigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Send users information about special offers and discounts on our products and services
• Develop and display personalized andrelevant advertising content for our users
• Analyze how our Services are used so we can improve them to engage and retain users
• Support our marketing activities
• Diagnose problems and/or prevent fraudulent activities
• Understand how our users use our products and services so we can improve user experience

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights,or disclose your information as evidence in litigation in which we are involved.‍

VitalInterests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. 

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met 
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insuranceclaim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canadaor a province
• If disclosure is required to comply with asubpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

InShort: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors,Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

• Data Analytics Services 
• Communication & Collaboration Tools
• Data Storage Service Providers
• Finance & Accounting Tools
• Order Fulfillment Service Providers
• Government Entities
• Performance Monitoring Tools
• Payment Processors
• Product Engineering & Design Tools
• Retargeting Platforms
• Sales & Marketing Tools
• Testing Tools
• Social Networks
• User Account Registration & Authentication Services
• Website Hosting Service Providers
• Cloud Computing Services
• Ad Networks
• Affiliate Marketing Programs

We also may need to share your personal information in the following situations:

BusinessTransfers. We may share or transfer your information in connection with,or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

When we use Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include https://optout.networkadvertising.org/ and https://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

Affiliates. We may share your information with our affiliates, in which case wewill require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

InShort: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

We can place cookies and other similar technology onyour device, including mobile device, in accordance with your preferences seton our cookie consent manager. Depending on your settings in our cookie consent manager on your mobile device, the following information may be collected through cookies or similar technology: your unique device identifier, mobile device IP address, information about your device’s operating system, mobile carrier and your location information (to the extent permissible under applicable law).

What are cookies?

Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a site and allow a site to recognize your device. Cookies managed by Us only are called “first party cookies” whereas cookies from third parties are called “third party cookies” as explained below.

Why do we use cookies and similar technologies?

Cookies do a lot of different jobs, such as letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests. In addition, cookies can help usto analyze the use of our websites and online content (analytics cookies) andthey can also facilitate/track the interaction on our websites and online content with social media (e.g. links to social media sites, like buttons,etc.).

Do Weuse cookies for marketing and analytics?

Yes,we may use information collected from our cookies to identify user behavior and to serve content and offers based on your profile, and for the other purposes described below, to the extent legally permissible in certain jurisdictions.

In other cases, we can associate cookie information (including information from cookies placed via our advertisements on third party sites) with an identifiable individual. For example:

• If we send you a targeted email which includes web beacons, cookies or similar technologies we will know whether you open, read, or delete the message.
• When you click a link in a marketing e-mail you receive from Us, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered ator signed into our site.
• Combining and analyzing personal data – As described above, we may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites such as our careers and corporate sites and information collected when you sign-up or logon to our sites or connect to our sites using your social media credentials(such as LinkedIn). We combine this data to better assess your experience with Us and to perform the other activities described throughout our privacy policy.

Do you use any cookies from third party companies?

Some cookies, web beacons and other tracking and storage technologies that we use are from third party companies (third party cookies). Examples may include Facebook, Microsoft, Twitter, YouTube, Instagram, and Linkedin Analytics to provide us with web analytics and intelligence about our sites which may also be used to provide measurement services and target ads. These companies use programming code to collect information about your interaction with our sites,such as the pages you visit, the links you click on and how long you are on our sites. This code is only active while you are on Our website. For more information on how these companies collect and use information on our behalf, please refer to their privacy policies: Facebook at Facebook Data Policy Google(including YouTube) at Google Privacy & Terms, Microsoft at Microsoft Privacy Statement, Linkedin at Linkedin Privacy Policy, Twitter at Twitter Privacy Policy, and Instagram at Instagram Data Policy.

Do We use any tracking technologies similar to cookies?

We may also use web beacons (including conversion pixels) or other technologies for similar purposes as above and we may include these on our sites, in marketing e-mail messages or our newsletter, affiliated websites, to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but they may work in conjunction with cookies to monitor website activity. The information provided below about cookies also applies to web beacons and similar technologies. Conversion pixels are small codes located on a particular web page which are triggered when someone visitsa page resulting in an increase in the conversion count.

What if I don’t want cookies or similar tracking technologies?

You can adjust your cookie settings through our cookie consent manager. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies being placed on your device you can use our cookie consent manager. Please bear in mind that deleting and blocking cookies may have an impact on your user experience.

What types of cookies does the site use?

The cookies used on Our sites have been categorized below. However, it is important to note that not all cookies may be used in all jurisdictions or websites. A list of the categories of cookies used on this website is set out below.

Strictly Necessary cookies

These cookies are essential in order to enable you to move around the site and use its features, such as accessing secure areas of the site. Without these cookies, services you have asked for cannot be provided.

First party analytics cookies

These cookies allow us to employ data analytics so we can measure and improve the performance of our site and provide more relevant content to you. These cookies don't collect information that identifies a visitor down to an individual level that is available to us. These cookies are not passing personally identifiable information to any external third party other than in limited cases when we engage a service provider to act on our behalf but who is then unable to use the data for their own purposes. These may include Adobe’s Analytics, Target and Audience Manager.

Performance cookies

Performance cookies are generally third-party cookies from vendors we work with or who work on our behalf that collect information about your visit and use of Our website,for instance which pages you visit the most often, and if you get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how the website works. Third party vendors may have access to this data and may use it to improve their overall services and offerings.

Functionality cookies

These cookies allow a site to remember choices you make (such as your username,language or the region you are in) and provide more enhanced, personal features.

These cookies cannot track your browsing activity on other websites. They don’t gather any information about you that could be used for advertising or remembering where you’ve been on the Internet outside our site.

Advertising and social media cookies

Advertising and social media cookies (including web beacons and other tracking and storage technologies) are used to (1) deliver advertisements more relevant to you and your interests; (2) limit the number of times you see an advertisement; (3)help measure the effectiveness of the advertising campaign; (4) retargeting to Our websites/information and (5) understand people’s behavior after they view anadvertisement. They are usually placed on behalf of advertising networks with the site operator’s permission. They remember that you have visited a site and quite often they will be linked to site functionality provided by the other organization. This may impact the content and messages you see on other websites you visit.

If you have any questions now or during your visit, complete a data subject access request, by email at ccpa@virscidian.com, or by referring to the contact details at the bottom of this document. You can adjust your cookie settings at any time from your preferred web browser’s cookie consent manager.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

InShort: We may transfer, store, and process your information in countries other than your own.

Ourservers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WHENAND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in the United States, and other countries.

Ifyou are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

InShort: We keep your information for as long asnecessary to fulfill the purposes outlinedin this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information,we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

InShort: We aim to protect your personal information through a system of organizational and technical security measures.

Wehave implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals,or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

InShort: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@virscidian.com.‍

10.WHAT ARE YOUR PRIVACY RIGHTS?

InShort: In some regions, such as the European Economic Area (EEA), United Kingdom(UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However,please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.‍

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and useof your account, to respond to service requests, or for other non-marketing purposes.‍

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at privacy@virscidian.com.

11.CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications includea Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

InShort: If you are a resident of California, Colorado, Connecticut, Utah or Virginia, you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect? 

We have collected the following categories of personal information in the past twelve (12) months:

A. Identifiers

A real name, Internet Protocol address, email address, or other similar  identifiers.

Collected - YES

B. Personal information categories listed in theCalifornia Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or  description, address, telephone number, passport number, driver’s license or  state identification card number, insurance policy number, education,  employment, employment history, bank account number, credit card number,  debit card number, or any other financial information, medical information,  or health insurance information.

Some personal information included in this category may overlap with other  categories.

Collected - NO

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry,national origin, citizenship, religion or creed, marital status, medicalcondition, physical or mental disability, sex (including gender, genderidentity, gender expression, pregnancy or childbirth and related medicalconditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected - NO

D. Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Collected - NO

E. Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or otheridentifier or identifying information, such as, fingerprints, faceprints, andvoiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected - NO

F. Internet or other similar network activity

Browsing history, search history, information on aconsumer’s interaction with a website, application, or advertisement.

Collected - YES

G. Geolocation data

Physical location or movements.

Collected - YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

Collected - YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

Collected - NO

J. Non-public education information (per the FamilyEducational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such asgrades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected - NO

K. Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected - YES

We will use and retain the collected personal information as needed to provide the Services or for as long as the user has an account with us.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to yourinquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

We collect and share your personal information through:

• Targeting cookies/Marketing cookies
• Beacons/Pixels/Tags

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have shared personal information with third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve(12) months:

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (ifany) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems(e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), you have the rights listed below when a company is subject to the CCPA. We do not meet the requirements necessary to be subject to the CCPA and therefore you do not have a lawful right to demand we comply with its provisions. However, privacy is important to Us and We generally make an effort to assure our customer’s data is protected.

The California Code of Regulations defines a "residents" as:

1. Every individual who is in the State of California for other than a temporary or transitory purpose and
2. Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."‍

CA residents’ rights with respect to personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we may elect to voluntarily respect your request and delete your personal information at our sole discretion, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you may request to know:

• whether we collect and use your personal information;
• categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal information; and the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete any information, including consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights to the extent the CCPA applies to us.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request, we may verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your in request in a manner consist with the terms of this Privacy Policy. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We may, at our sole discretion, delete such additionally provided information as soon as we finish verifying you.

Other actions you may make:

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent tomake a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA, or for any other reason.
• You may request to opt out from future selling or sharing of your personal information to third parties. We have no legal obligation to honor these requests.
• To act under this Policy, you can contact us by submitting a data subject access request,by email at ccpa@virscidian.com, or by referring to the contact details at the bottom of this document. If you have acomplaint about how we handle your data, we would like to hear from you.

Colorado Residents

This section applies only to Colorado residents. We are not subject to the Colorado Privacy Act (CPA). However, privacy is important to us and we generally work toassure our customer’s data is secure.  Even under the CPA, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. Under the CPA, you may have certain rights, such as:

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct in accuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

If you have concerns with any of the above, please email privacy@virscidian.com or submit a data subject access request. We have no obligation to respond to any such request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at privacy@virscidian.com. We have no legal obligation to consider your appeal or respond to same.

Connecticut Residents

This section applies only to Connecticut residents. We are not subject to the Connecticut Data Privacy Act (CTDPA). However, privacy is important to us and we generally work to assure our customers’ data is secure. Under the Connecticut Data Privacy Act (CTDPA), you may have certain of the rights listed below when dealing with other companies. However, even these rights are not absolute, and none of them apply to Us. As such, we may decline your request as permitted by law. Underthe CTDPA, you may have certain rights, such as:

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct in accuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

If you have concerns with any of the above, please email privacy@virscidian.com or submit a data subject access request. We have no obligation to respond to any such request.

If we decline to take action regarding your request and you wish to appeal our decision, please email us at privacy@virscidian.com. We have no legal obligation to consider your appeal or respond to same.

Utah Residents

This section applies only to Utah residents. We are not subject to the Utah Consumer Privacy Act (UCPA). However, privacy is important to us and we generally work to assure our customers’ data is secure. Under the Utah Consumer Privacy Act (UCPA), you may certain rights listed below. However, event hese rights are not absolute, and none of them apply to Us. As such, we may decline your request as permitted by law. Under the UCPA, you may have certain rights, such as:

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising or the sale of personal data

To submit a request to exercise these rights described above, please email privacy@virscidian.com or submit a data subject access request.

Virginia Residents

This section applies only to Virginia residents. We are not subject to the Virginia Consumer Data Protection Act (VCDPA). However, privacy is important to us and we generally work to assure our customers’ data is secure. Under the VCDPA:

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

"Saleof personal data" means the exchange of personal data for monetary consideration.

Even if this definition of "consumer" applies to you, we are not required to adhere to the rights and obligations regarding your personal data set forthin the act. As such, we may decline your request as permitted by law. Under the VCDPA, persons may have certain rights, such as:

• Right to be informed whether or not we areprocessing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

To exercise your rights provided under the Virginia VCDPA, you may contact us by email at privacy@virscidian.com or submit a data subject access request.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Right to appeal

If we decline to take action regarding your request and you wish to appeal our decision, please email us at privacy@virscidian.com. We have no legal obligation to consider your appeal or respond to same.

13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

InShort: You may have additional rights based on the country you reside in Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular: offer you the products or services that you want respond to or help with your requests. At any time, you have the right to request access to or correction of your personal information.You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information.You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

14. DO WE MAKE UPDATES TO THIS NOTICE?

InShort: Yes, we will update this notice asnecessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at privacy@virscidian.com or contact us by post at:

Virscidian,Inc.

1151 Kildaire Farm Rd #120

Cary, NC 27511

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country,you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update,or delete your personal information, please fill out and submit a data subject access request.

Data Subject Access Request Form

You may use this form to submit requests regarding personal information collected by Us. We reserve the right to refuse requests, in part or in whole, to the extent permitted by law, or if we are unable to verify your identity, or if we cannot verify your authority to act on behalf of another person.

For certain requests, we may ask for additional information or documents to verify the identity of the consumer who is the subject of the request. The information provided through this form will be used to respond to your request, including verifying identity, identifying personal information responsive to your request, and keeping records of your request.

If your request applies to online activity information that We may have collected through cookies or similar technologies, you must make your request from the browser or device that you have previously used to access Our websites or apps. This allows us to read any identifier thatwe have assigned to your browser or device.

Requestor Information

STATE OF RESIDENCE (drop down)

Are you the consumer? (drop down)

• Yes, I am making a requestrelated to personal information about me.
• No, I am acting as anauthorized agent for the consumer. I understand I will be required to provideadditional documentation before this request can be processed.

Specify the request(s) - check all that apply (check box)

• Request to know categories of personal information We have collected, used, disclosed, and/or sold about the consumer.
• Request to obtain specific pieces of personal information We collected about the consumer.
• Request to delete personal information We have collected about the consumer.
• Request to be removed from SMSText Messaging List.

(FORM FIELDS)

Full Name:

Email Address:

Residential Address:

Telephone Number:

Past Order Number(s), if any:

Check box: By submitting this form, I hereby certify that the information entered into this form is complete, accurate, and up-to-date, and that I am the consumer who is the subject of the request or have been authorized by that consumer to act on his/her behalf, as indicatedabove. I understand that it may be necessary for Virscidian to verify theidentity of the consumer and/or authorized agent for this request, andadditional information may be requested for this purpose. I further understandthat Virscidian may have no legal duty to respond to his request.

Submit Button Here

AUTO RESPONSE EMAILS BASED ON STATE OF RESIDENCE:

Each request should be acknowledged and set reasonable expectations forthe consumer.

Subject: Your Data Privacy Request

Thank you for contacting Us. We have received your data subject access request. Your request will be processed in accordance with our Privacy Policy, which you may review here. It may be necessary for Us to verify the identity of the consumer and/or authorized agent for this request, and additional information may be requested for this purpose. We may make such requests, if any, by contacting you at the address and telephone number you provided. Failure to promptly and fully respond to such requests may result in delay.

Your privacy is important to us and we look forward to reviewing your request. Thanks again for contacting Virscidian!

REMOVED FROM SMS TEXT MESSAGING LIST:

Subject: Your SMS REMOVAL REQUEST

Your request has been received. You may unsubscribe from our SMS Text Messaging List by texting “UNSUBSCRIBE” to the following number from the number you wish to unsubscribe: XXXX-XX. Standard text messaging rates apply.

Thank you for contacting Virscidian!