PRIVACY POLICY

The protection and privacy of your data, including personal data, is very important to Chainbridge Solutions Inc (“Chainbridge Solutions” or “we”).

This Privacy Policy (the “Policy”) covers three distinct categories of data.

The first category is data processed through Chainbridge Solution’s software which is provided to our customers in either an on-premise version, which is hosted on the customer’s premise, or a customer-hosted version which is hosted in an offsite location or with a third party in the customer’s account (collectively, the “Hosted Software”).

For Hosted Software

Chainbridge Solutions does not process or see any of the data you process through the Hosted Software as the data does not leave your hosted system or your on-premise data center.

The second category is data processed through Chainbridge Solution’s software, which Chainbridge Solutions hosts in its cloud-based environment, in an account for the customer (the “Cloud Software”). For Cloud Software, Chainbridge Solutions is a Processor of your data.

The third category is information received from our www.ChainbridgeSolutions.com website (the “Site”).

By utilizing the Hosted Software, the Cloud Software, and/or the Site (collectively the “Service”), you expressly acknowledge and accept this Policy, and such consent grants us the faculty to treat your personal data or any personal data you process through the Hosted Software or the Cloud Software (“Personal Data”) as set forth herein and in accordance with the laws, regulations and other applicable legislation applicable to your use

Collection and Usage of Information processed through the Hosted Software

Chainbridge Solutions does NOT collect or store any information or data you process through the Hosted Software.

The data you process through the Hosted Software is solely managed and controlled by you. Chainbridge Solutions does not collect, retain, or store your data. You are the data controller and processor and responsible for adherence to all personal data laws and regulations including any required security of such personal data.

Collection and Usage of Information processed through Cloud Software

The data you process through the Cloud Software is managed and controlled by you. You are the data controller and Chainbridge Solutions provides access to the Cloud Software to you for your use. Chainbridge Solutions is a deemed a data processor for the Cloud Software you utilize

The data you process in the Cloud Software is retained in your cloud instance and is managed by Chainbridge Solutions. Chainbridge Solutions does not collect or retain any copies of your data separate from your cloud instance.

Chainbridge Solutions Cloud Software can be deployed, based on the customer’s preference, in various cloud platforms including: (1) the Google Cloud Platform; (2) Amazon Web Services; (3) Microsoft Azure.

Collection and Usage of Site Information

Website: Chainbridge Solutions uses third parties (e.g. Google Analytics) to track user flow on our Site and for such purposes uses a cookie.

How We Use the Information

We use the information we collect for: (1) personalizing your experience; (2) communication and marketing; (3) research and development of features and products; (4) safety and security; (5) legal rights and business interest; and (6) where you provide consent for a specific purpose. How we use the information we collect also depends in part on which services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the Personal Information we collect about you.

1. To provide the Site and personalize your experience: We use Personal Data to provide support and to operate and maintain the Site. Where you use multiple Services, we may combine information about you and your activities to provide an integrated experience, such as to allow you to find information from one Service while searching from another or to present relevant product information.

2. Communication: We use your contact information to send certain communications via email, including responding to your comments, questions and requests, providing customer support, and sending you technical notices or updates, security alerts, and administrative messages.

3. We may use a third-party email marketing platform, for sending product related emails. You can control whether you want to receive these communications by opting-out whenever you receive such a communication from Chainbridge Solutions by using the included opt-out link in any such communication.

4. For research and development: We are always looking for ways to make our Services smarter, faster, better integrated, more secure and useful to you. We use collective learnings about how people use our Services and feedback provided to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services.

5. For safety and security: We use information about you and your use of the Services to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of our policies.

6. To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

7. With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials with your permission.

8. Legal basis for processing: We collect and process information about you only where we have legal basis for doing so. The legal basis depends on the Services you use and how you use them. This means we collect and use your information only where:

– we need it to provide you with the Services;

– it satisfies a legitimate interest which is not prohibited by your data protection rights, such as for research and development or to protect our legal rights;

– you give us consent to do so for a specific purpose; or

– we need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time through exercise of your Personal Rights as set forth below. However, this will not affect any processing of your information that has already taken place.

Security, Storage and Data Retention

Security and Storage for Information processed through the Services:

Hosted Software: Chainbridge Solutions does NOT collect or store any information or data you process through the Hosted Software. You are responsible for security, storage and data retention of the information and data you process through the Hosted Software.

Site: We use various service providers to host the data we collect from the Site, and we use technical measures to secure such data. We ensure a variety of security measures are implemented by such service providers, including firewalls, Secure Socket Layer (SS L) technology, encryption and authentication tools, to help protect your information. We protect your Personal Data with the same or better security measures than we protect our company data.

Personal Data Retention

Chainbridge Solutions will retain Personal Data, in accordance with the above, for as long as needed to provide the Services to you. Chainbridge Solutions will also retain Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce this Policy and our agreements.

How We Share Information

Chainbridge Solutions does not sell or rent your Personal Data to any third party without your consent. We do share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services as outlined below

Service Providers: We work with third-party service providers to provide application development, hosting, maintenance, newsletters, support, logs, marketplace, backup, storage, virtual infrastructure, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.

With your consent: We share data about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.

Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Chainbridge Solutions, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

We may transfer your Personal Data to third parties in the following situations:

When you have given us consent to do so;

In response to subpoenas, court orders, or legal process by disclosing your data and other related information, if necessary or to establish or exercise our legal rights or defend against legal claims; or

In order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Chainbridge Solutions End User License Agreement, or as otherwise required by law.

We collect information and store that information with our service providers in the United States. Whenever we transfer your information, we take steps to protect it.

Information for Data Subjects Related to Personal Data

Information for Data Subjects Related to Personal DataFor the Hosted Software or Cloud Software , Chainbridge Solutions is considered a processor. Chainbridge Solutions may use sub-processors. In such instances, Chainbridge Solutions has entered into appropriate data processing agreements, or, for HIPPA related data, business associate agreements with our sub-processors setting forth the protection of Personal Data. Such third-party processors are controlled by data processing agreements or business associate agreements providing the same protections of your Personal Data as set forth herein.

For Personal Data collected from the Site, Chainbridge Solutions is considered a controller. Chainbridge Solutions may use third party processors. Such third-party processors are controlled by data processing agreements providing the same protections of your Personal Data as set forth herein.

Only Chainbridge Solutions authorized employees and subcontractors have access to Personal Data relevant to the activities and services they provide to Chainbridge Solutions. As previously indicated, all subcontractors used by Chainbridge Solutions are contractually bound to the same data security and privacy standards that apply to our employees through either data processing agreements or business associate agreements.

Business Transfers: We may share or transfer information we collect under this Policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Standard Services if a transaction takes place, as well as any choices you may have regarding your information.

Links to Other Sites

While using the Services, you may be exposed to content or functionality that is hosted by a third-party supplier. If you click on or access such third-party content or functionality, the privacy policy and terms of use for such thirdparty content or functionality will control as such other sites have their own privacy policies and personal data collection, use, and disclosure practices. We strongly advise you to familiarize yourself with the privacy policies provided by these other sites prior to providing them with any information. Chainbridge Solutions is not responsible for the privacy practices or the content of other websites.

Changes to this Privacy Policy

From time to time, we may update this Policy to clarify our practices or to reflect new or different privacy practices, such as when we add new features to the Service. Chainbridge Solutions reserves the right to update or modify this Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Policy shall indicate your agreement with the terms of such revised Policy. If you disagree with any changes to this Policy, you will need to stop using the Apps or Services and deactivate your account.