QNOPY Privacy Notice

Last Revised – Effective Date: January 1, 2024

QNOPY, Inc. (“QNOPY,” “us,” “we” or “our”) is committed to safeguarding your privacy. This Privacy Notice (“Notice”) informs you of our policies regarding the collection, use, disclosure, and protection of Personal Information when you use our products, visit our website, apply for a job with us, or otherwise engage with us (collectively, our “Services”) and the choices you have associated with that information. Please read this Notice carefully before using our Services.

1. CHANGES TO THIS NOTICE

We may update this Notice from time to time. When we make changes to the Notice, we will update the date listed above. The updated terms are effective as of the listed date. We encourage you to check regularly for updates to this Notice. Your continued use of our Services after an updated Notice is posted reflects your consent to the updated terms. We will let you know via email and/or a prominent notice on our Service if we make a material change to our Notice prior to the change taking effect.

2. ABOUT QNOPY AND THE TYPE OF PERSONAL INFORMATION WE MIGHT COLLECT

QNOPY is a technology company that provides a mobile application and database for digitizing field and lab data for clients and customers working in the environmental industry. When using Services, our customers and clients (“Customers”) and their authorized users (“Authorized Users”) may input, load or transfer electronic data into the QNOPY software platform. “Customer Data” may include information that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household (collectively, “Personal Information”). Personal Information does not include de-identified or aggregated information, or public information lawfully available from governmental records.

We may collect the following categories of Personal Information from and/or about you directly or indirectly when you interact with the Services:

Category	Description
Identifiers	including your name, address, phone number, email address, job title, company name and username/password when you create an account.
Commercial Data	including information about your use of our products.
Financial Data	including bank account information, bank account balance, information from the business’ accounting software, accounts payable, and recurring revenue subscription software.
Professional or Employment-Related Data	when you apply for a job with us, including your job history, professional certifications, compensation information, references, educational information, and information required for or generated during a background check.
Technical Data	including internet protocol (“IP”) address, cookies, java script, web beacons, clear gifs, HTTP headers, your login data, browser type and version, time zone setting and location, mobile carrier, browser plug- in types and versions, operating system and platform, and other technology on the devices you use to access our Services.
Usage Data	on how you navigate our website, including the content and features you use or view on the website, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We may also collect data the online services you visit immediately before and after you access our Services, and the search terms you enter on our website. We may combine information collected through means such as cookies or third-party analytics tools with Personal Information we already have about you.
Geolocation Data	to the extent you have configured your device to permit us to collect such information.
Marketing and Communications Data	including your communication preferences in receiving information from us.
Social Media Applications Data	including your public profile, social media relationships and “likes” when you engage with us on social media or use our social media plug-ins.
Sensitive Personal Data	only if a background check is required for employment, such as your social security number.

3. HOW WE MAY USE YOUR PERSONAL INFORMATION

We may use your Personal Information for any of the following business purposes / legal basis:

To register you as a user and to provide our Services;

To maintain the QNOPY software platform and provide our Services;

To authenticate and verify your identity;

To evaluate whether you are eligible to use QNOPY’s Services;

To process payments;

To market our Services to you;

To detect, prevent and address technical issues with our Services;

To notify you about changes to our Services;

To allow you to participate in interactive features of our Services when you choose;

To provide you with customer support;

To conduct employment recruiting, evaluate your application for employment, and conduct appropriate due diligence (as applicable);

To perform analytics and risk assessments, including monitoring the use of the Services;

To improve our brand, website, and Services, including developing new products and services;

With your permission, to send you communications with special offers and promotions. If you don’t want to receive these, you may unsubscribe at any time;

To enforce our agreement with you;

To prevent fraud and protect the security and integrity of our Services;

To investigate and defend against any third-party claims or allegations;

To pursue legitimate interests, such as research and development, processing for statistical purposes, and performing activities carried out in the public interest;

To provide you, or permit selected third parties to provide you, with information about products and services we offer that are similar to those that you have already purchased, provided you have not opted out of receiving that information. For example, to send you newsletters and promotions using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS) with your consent, push notifications, and other means;

To enhance the accuracy of the information we hold about you;

To fulfill our legal obligations under applicable law, regulation, court order, or other legal process, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities;

To protect your, our, and others’ rights, property and safety;

To enforce our agreement with you or our policies; and

To resolve disputes.

4. HOW WE COLLECT YOUR PERSONAL INFORMATION

From our Customers. We process Customer Data at the direction of our Customers and have no direct control or ownership of the Personal Information that we receive or process. If you are an Authorized User of one of our Customers and would no longer like to be contacted by one of our Customers that use our Services, please contact the Customer that you interact with directly. Customers are responsible for complying with regulations or laws that require providing notice, disclosure and/or obtaining consent prior to transferring the data to QNOPY for processing purposes.

From you directly. We may collect Personal Information directly from you. This information may be collected when you register to use our Services; when you use the Services, or another application that the Services are embedded in (for example, as a mobile application provided by QNOPY’s Customer); when you contact a member of the QNOPY support team; when you use your work PC or your iOS or Android device to access the Services; or when you access our website.

From passive collection. As is true of most websites and web-based applications, we gather certain information automatically. This information may include IP addresses, browser type, Internet service provider (ISP), referring/exit pages, the features viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, usage, change history, and/or clickstream data to analyze trends in the aggregate and administer our website.

5. HOW WE MIGHT DISCLOSE AND SHARE YOUR PERSONAL INFORMATION

We may disclose and share your Personal Information to the following categories of entities for one or more of the business purposes described above in Section 3:

Our affiliates and subsidiaries;

Our service providers and vendors that assist us in providing you with the Services;

Our marketing partners, including social media platforms;

Our third-party analytics providers in order to improve the functionality, features or delivery of our Services;

Our business partners or investors, or potential business partners or investors;

Our professional service providers, including consultants, bankers, attorneys, insurance agents or accountants; or

Other entities as permitted by law, for example, in the event of a transfer of ownership or assets, in the event of bankruptcy, where needed to comply with the request of law enforcement or a regulatory agency (or other legal process), or to protect our interests or safety of our other Customers, or the safety of other visitors to our website or mobile app.

6. OUR USE OF COOKIES AND OTHER DIGITAL TECHNOLOGIES

Our Services use a variety of digital technologies, including cookies, web beacons, pixels, and cookies to automatically collection information about how our Services are used. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about how you engage with our Services. The use of a pixel tag allows us to see that a user has used a certain feature of our mobile app or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded. You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. If you do not accept the use of certain of these digital technologies, however, you may not be able to use all features of our Services.

Examples of Cookies we use:

Type	Description
Session Cookies	We use Session Cookies to operate our Service.
Preference Cookies	We use Preference Cookies to remember your preferences and various settings.
Security Cookies	We use Security Cookies for security purposes.

If you consented to our use of cookies but later wish to opt out, you may change your choice at the Cookie Settings link at any time. In addition, you may modify your browser settings in order to block the cookies.

7. LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

8. CHILDREN’S PRIVACY

Our Services are directed to individuals 18 years or older. If you are under the age of 18, you are not eligible to use our Services.

9. RETENTION OF PERSONAL INFORMATION

We will retain the Personal Information that we process on behalf of our Customers for as long as needed to provide Services to our Customer, and as necessary to comply with our legal obligations, resolve disputes and/or enforce our agreements.

10. INTERNATIONAL DATA TRANSFERS / ONWARD TRANSFERS OF PERSONAL INFORMATION

Since we operate globally, it may be necessary to transfer, store and process Personal Information in other countries in which we or our affiliates, subsidiaries or service providers (including the sub- processors) maintain facilities, such as the United States, India, the European Union and the United Kingdom. The data protection and other laws of these countries may be different than those in your jurisdiction of residence.

For EU and UK data subjects, please note that we may transfer your Personal Information to countries outside of the European Economic Area (“EEA”) or the United Kingdom (“UK”). In these instances, we will take steps, as required by applicable law and market practice, to ensure that a similar level of protection is given to Personal Information, including, when applicable, through contractual means (for example, when the GDPR or UK law applies, we will rely on the standard contractual clauses approved by the European Commission for data transfers, the UK International Data Transfer Addendum (“IDTA”), or transfer data only to recipients located in jurisdictions which were granted an “adequacy decision” with regard to their level of protection of Personal Information by the European Commission). For more information about international data transfers of the Personal Information, please refer to our Data Processing Agreement.

11. DATA SECURITY

We are committed to making reasonable efforts, in accordance with market best practices and legal requirements, to ensure the security, confidentially and integrity of Personal Information. We take great care in implementing and maintaining the security of our website, software and any system and server we store Personal Information. We employ market best practice security measures to provide the safety of the Personal Information and prevent unauthorized use of any such information. Although we take steps to safeguard such information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access. If a password is used to help protect your accounts and Personal Information, it is your responsibility to keep your password confidential.

12. YOUR RIGHTS RELATED TO YOUR PERSONAL INFORMATION

You have certain rights relating to your Personal Information, subject to local data protection laws. Depending on the applicable laws, these rights may include the right to:

Access your Personal Information held by us;

Know more about how we process your Personal Information;

Rectify inaccurate Personal Information and, taking into account the purpose of processing the Personal Information, ensure it is complete;

Erase or delete your Personal Information;

Restrict our processing of your Personal Information;

Transfer your Personal Information to another controller, to the extent possible;

Object to any processing of your Personal Information;

Opt out of certain disclosures of your Personal Information to third parties;

Know what categories of Personal Information are shared for delivering advertisements on non- QNOPY websites, applications, and services and the categories of recipients of such Personal Information;

Opt out of the sharing of your Personal Information for delivering advertisements on non-QNOPY websites, applications, and services;

Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects;

Withdraw your consent at any time (to the extent we base processing on consent); and § Not be discriminated against for exercising your rights as described above.

An individual that seeks to exercise any of the rights described above should first direct the inquiry to QNOPY’s Customer (as the data controller), or second by emailing the request to privacy@qnopy.com. We will process your request as soon as reasonably practicable, or within a reasonable timeframe, provided we are not otherwise prevented from doing so on legal grounds. If we are unable to meet your request, we will let you know why. For example, it may be necessary for us to deny your request if it would have an unreasonable impact on the privacy or affairs of other individuals, or if it is not reasonable and practicable for us to process your request in the manner you have requested. In some circumstances, it may be necessary for us to seek to arrange access to your Personal Information through a mutually agreed intermediary (for example, our Customer).

13. WE NEVER SELL YOUR PERSONAL INFORMATION

We will never sell your Personal Information to third parties.

14. DO NOT TRACK DISCLOSURES

Privacy regulations in the United States, such as the laws of California and Delaware, require us to indicate whether we honor your browser’s “Do Not Track” settings concerning targeted advertising. We adhere to the standards set out in this Notice and do not monitor or respond to Do Not Track browser requests since there is no standard for how online services should respond to such signals.

15. NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018, as amended by the Consumer Privacy Rights Act of (“CCPA”), requires us to explain the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140(o)), that we collect, the reason we collect the Personal Information, where we obtain the Personal Information, and the other entities with whom we may share the Personal Information. Under the CCPA, Personal Information is defined as any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

We generally collect the following categories of Personal Information in providing our Services:

Identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;

Characteristics of protected classifications under California or federal law, such as gender;

Commercial information such as records of products or services purchased, obtained, or considered by you;

Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our website, length of visit and number of page views, click- stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;

Professional or employment-related information;

Your geolocation, to the extent you have configured your device to permit us to collect such information; and

Inferences about your preferences, characteristics, behavior and attitudes.

For more information about the Personal Information we collect and how we collect it, please refer to Sections 2, 4 and 6 above.

We collect Personal Information for the business purposes described in Sections 3 and 6 above.

The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.

The categories of other individuals or entities with whom we might share your Personal Information are listed in Section 5 above.

QNOPY is comprised of several separate legal entities that may be considered “third party affiliated entities” for purposes of California Civil Code Section 1798.83. California law requires us to inform California residents who have provided us with Personal Information that they may request of us information about our disclosures to third parties (including QNOPY’s affiliated entities) for their direct marketing purposes. To do so, contact us at privacy@qnopy.com and indicate in the subject line “California Privacy Rights.”

16. HOW TO CONTACT US

If you have any questions about this Notice, or wish to make a complaint about our data handling practices, you may contact:

QNOPY Privacy Team QNOPY, Inc.
5 Concourse Pkwy., Ste. 3000 Atlanta, GA 30328
+1 (866) 766-7924
Email: privacy@qnopy.com