Privacy Statement, effective as of June 11, 2020

At InOutBoard.com, Inc. trust is our #1 value. This InOutBoard Privacy Statement ("Privacy Statement") describes our privacy practices for the activities set out in this Privacy Statement. Please read this Privacy Statement carefully to learn how we collect, use and otherwise process information relating to individuals ("Personal Data"), and to learn about your rights and choices regarding our processing of your Personal Data.

A reference to “InOutBoard,” “we,” “us,” “our,” or the “Company” is a reference to InOutBoard.com, Inc.

1. Responsible InOutBoard entity

InOutBoard is the controller of your Personal Data as described in this Privacy Statement, unless expressly specified otherwise.

For the avoidance of doubt, this Privacy Statement does not apply to the extent we offer our customers various cloud products and services through which our customers may create their own websites and applications running on our platforms, sell or offer their own products and services, send electronic communications to other individuals, and collect and analyze Personal Data from individuals.

2. Processing activities covered

This Privacy Statement applies to the processing of Personal Data collected by us when you:

• Visit our websites that display or link to this Privacy Statement;
• Visit our branded social media pages;
• Visit our offices;
• Receive communications from us, including emails, phone calls, texts or fax;
• Register for, attend and/or otherwise take part in our events, webinars; or
• Participate in community and open source development.

Our websites and services may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties' privacy statements, which you should review to better understand those third parties' privacy practices.

3. What Personal Data do we collect?

3.1 Personal Data we collect directly from you

The Personal Data that we collect directly from you includes the following:

• If you express an interest in obtaining additional information about our services, request customer support, use our "Contact Us" or similar features, register to use our websites, sign up for an event or webinar, or download certain content, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, email address or username and password;
• If you make purchases via our websites or register for an event or webinar, we may require that you provide to us your financial and billing information, such as billing name and address, or credit card number;
• If you use and interact with our websites, we automatically collect information about your device and your usage of our websites or emails through cookies, or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data (please see the "What device and usage data we process" section, below);
• If you use and interact with our services, we automatically collect information about your device and your usage of our services, through log files and other technologies, some of which may qualify as Personal Data (please see the "What device and usage data we process" section, below);

If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information set out in the “Contacting us” section below.

4. What device and usage data we process

We use common information-gathering tools, such as tools for collecting usage data, cookies and similar technologies to automatically collect information that may contain Personal Data from your computer or mobile device as you navigate our websites, our services or interact with emails we have sent to you.

4.1 Device and usage data

As is true of most websites, we gather certain information automatically on connection with the use of the website by individual users. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our websites and to guarantee their security and continued proper functioning.

In addition, we gather certain information automatically as part of your use of the cloud products and services. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches and other actions you take, operating system and system configuration information and date/time stamps associated with your usage. This information is used to maintain the security of the services, to provide necessary functionality, as well as to improve performance of the services, to assess and improve customer and user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to assess capacity requirements, to identify customer opportunities and for the security of InOutBoard generally (in addition to the security of our products and services). Some of the device and usage data collected within the services, whether alone or in conjunction with other data, could be personally identifying to you. Please note that this device and usage data is primarily used for the purposes of identifying the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers (where we act as a processor).

4.2 Cookies and other tracking technologies on our website and in email communications

We use cookies and similar technologies such as tags and JavaScript, alone or in conjunction with cookies, to compile information about the usage of our websites and interaction with emails from us.

When you visit our websites, we may place a cookie on your browser and/or device, which collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track usage, determine your browsing preferences and improve and customize your browsing experience.

We use both session-based and persistent cookies on our websites. Session-based cookies exist only during one session and disappear from your computer when you close your browser or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. To change your cookie settings and preferences for the site you are visiting, click the Cookie Preferences link in the footer of the page. You can also control the use of cookies at the individual browser level, but choosing to disable cookies may limit your use of certain features or functions on our websites and services.

The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies:

Type of Cookies	Description	Managing Settings
Required cookies	Required cookies are necessary for basic website functionality. Some examples include: session cookies needed to transmit the website, authentication cookies, and security cookies. If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into the websites and to process your online transactions and requests.	Because required cookies are essential to operate the websites, there is no option to opt out of these cookies.
Functional cookies	Functional cookies enhance functions, performance, and services on the website. Some examples include: cookies used to analyze site traffic, and cookies used for market research. Functional cookies may also be used to improve how our websites function and to help us provide you with more relevant communications, including marketing communications. These cookies collect information about how our websites are used, including which pages are viewed most often. We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications. For example, we use Google Analytics ("Google Analytics"), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can learn about Google's privacy practices by going to www.google.com/policies/privacy/?partners/ Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites from which visitors have navigated to our websites, and the pages on our websites to which visitors navigate. This information is used by us to improve our websites. InOutBoard may also utilize HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.	To manage the use of functional cookies on our websites, consult your individual browser settings for cookies. Note that opting out may impact the functionality you receive when using our websites. To opt out from data collection by Google Analytics, you can download and install a browser add-on, which is available here. To learn how to control functional cookies using your browser settings click here To learn how to manage privacy and storage settings for Flash cookies click here

4.3 Opt-Out from the setting of cookies on your individual browser

You may opt-out from the collection of non-essential device and usage data on your web browser (see "What device and usage data we process" section above) by managing your cookies at the individual browser level. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the website.

While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. Therefore, we do not currently commit to responding to browsers' DNT signals with respect to our websites. InOutBoard takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

5. Purposes for which we process Personal Data and the legal bases on which we rely

We collect and process your Personal Data for the purposes and on the legal bases identified in the following:

• Providing our websites and services: We process your Personal Data to perform our contract with you for the use of our websites and services and to fulfill our obligations under applicable terms of use/service; where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with content you access and request (e.g., to download content from our websites);
• Promoting the security of our websites and services: We process your Personal Data by tracking use of our websites and services, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others;
• Providing necessary functionality: We process your Personal Data to perform our contract with you for the use of our websites and services; where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to provide you with the necessary functionality required during your use of our websites and services;
• Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
• Handling contact and user support requests: If you fill out a “Contact Me” web form or request user support, or if you contact us by other means including via a phone call, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
• Managing event registrations and attendance: We process your Personal Data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, to perform of our contract with you;
• Managing payments: If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you;
• Developing and improving our websites and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your valid consent;
• Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights, and is necessary for our legitimate interests to protect against misuse or abuse of our websites, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with a judicial proceedings, court order or legal process, and/or to respond to lawful requests.

Where we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.

6. Who do we share Personal Data with?

We may share your Personal Data as follows:

• With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, customer support and data enrichment for the purposes and pursuant to the legal bases described above; such service providers comprise companies located in the countries in which we operate (available here: https://www.inoutboard.com/company/contact-me/);
• We may also share your Personal Data with other affiliates within the InOutBoard corporate group to the extent this is necessary to fulfill a request you have submitted via our websites, or for customer support, marketing, technical operations and account management purposes; a list of companies within the InOutBoard corporate group is available here;
• If we are involved in a merger or reorganization, sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by another company, we may transfer some or all of your Personal Data to such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any such transfer of Personal Data to an unaffiliated third party as processing of your Personal Data will be required for the purposes set out in "Purposes for which we process Personal Data and on which legal bases" section above.

7. Children

Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section, below, and we will take steps to delete such Personal Data from our systems.

8. How long do we keep your Personal Data?

We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the "Purposes for which we process Personal Data and the legal bases on which we rely" section, above). We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.

9. Your rights relating to your Personal Data

9.1 Your rights

You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws and, in particular, if you are located in the EEA, these rights may include:

• To access your Personal Data held by us (right to access);
• To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification);
• To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
• To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing);
• To transfer your Personal Data to another controller, to the extent possible (right to data portability);
• To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
• Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites or in our services; and
• To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

9.2 How to exercise your rights

To exercise your rights, please contact us by using the information in the “Contacting us” section, below. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a InOutBoard customer, we recommend you contact your company’s system administrator for assistance in correcting or updating your information.

Some registered users may update their user settings, profiles and organization settings by logging into their accounts and editing their settings or profiles.

To update your billing information, discontinue your account and/or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the “Contacting us” section, below.

9.3 Your rights relating to Customer Data

As described above, we may also process Personal Data submitted by or for a customer to our cloud products and services. To this end, if not stated otherwise in this Privacy Statement or in a separate disclosure, we process such Personal Data in the role of a mere processor on behalf of a customer (and/or its affiliates) who is the responsible controller of the Personal Data concerned (see the "Responsible InOutBoard entity" section above). We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those set forth in this Privacy Statement. If your data has been submitted to us by or on behalf a InOutBoard customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable customer directly. Because we may only access a customer’s data upon instruction from that customer, if you wish to make your request directly to us, please provide to us the name of the InOutBoard customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.

9.4 Your preferences for marketing communications

If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from InOutBoard by clicking on the “unsubscribe” link located on the bottom of InOutBoard marketing emails, by replying or texting ‘STOP’ if you receive InOutBoard SMS communications, or by unsubscribing here.

Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions, service announcements or security information.

10. How we secure your Personal Data

We take precautions including organizational, technical and physical measures to help safeguard against the accidental or unlawful destruction, loss, alteration and unauthorized disclosure of, or access to, the Personal Data we process or use.

While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in the “Contacting us” section, below.

11. Changes to this Privacy Statement

We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Privacy Statement. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.

We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.

12. Contacting us

To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement or our privacy practices please fill out this form or mail us at:

InOutBoard Data Protection Officer
PO Box 3816
Bluffton, SC 29910
Email: support@inoutboard.com

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.