Last updated May 2, 2024

PRIVACY POLICY OF ELEVATE REPUTATION MANAGEMENT, LLC

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Dear Interested Party, ELEVATE REPUTATION MANAGEMENT, LLC. has great respect for the privacy of Users.

The data that may be communicated through the Site will be treated with the utmost care and with all the tools necessary to ensure their security, in full compliance with current legislation placed to protect the confidentiality of data. We wish to inform you that the "European Regulation 2016/679 on the Protection of Individuals with regard to the Processing of Personal Data and on the free movement of such data" (henceforth "Regulation" or "GDPR") provides for the protection of individuals with regard to the processing of data of a personal nature as a fundamental right. Therefore, pursuant to Article 13 of the GDPR, we would like to inform you of the following.

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1. WHAT IS ELEVATE REPUTATION MANAGEMENT, LLC AND HOW IT WORKS

ELEVATE REPUTATION MANAGEMENT, LLC offers its users a software platform called ELEVATE.REVIEWS, accessible through the website of the same name which, through a series of features and interactions with external providers, allows Customers to:

(a) Centrally manage the reviews of their end customers, also selecting a carousel of the best reviews that they can display on their landing pages;

b) Actively communicate with end customers in order to request the opportunity to review the venue and/or product/service purchased;

c) Monitor the progress of reviews and scores (or "ratings"), which will also be aggregated among the various service providers;

ELEVATE REPUTATION MANAGEMENT, LLC, in accordance with the GDPR Regulations, acts as:

- Data Controller, with respect to the data of Users who own businesses of various kinds and/or further business activities (hereinafter "Merchants") and browsing data, in particular the data referred to in points a) and b) of Article 2 of this Policy.

- Processor for the data of end customers (i.e. those who review the Merchant's business) conferred by Merchants in the context of requesting, creating and organizing reviews. The processing carried out by ELEVATE REPUTATION MANAGEMENT, LLC in relation to these categories of data is governed by the "Data Processor Addendum" pursuant to Article 28 of the Regulations. The Addendum constitutes an integral part of the contractual relationship between ELEVATE REPUTATION MANAGEMENT, LLC and The Merchant, together with this notice and the terms and conditions.

ELEVATE REPUTATION MANAGEMENT, LLC does not use the data provided by Merchants for its own purposes, such as marketing, market research, communication to third parties, or dissemination. It is understood that Merchants ensure that end customers have been adequately informed that their data will also be processed through external data processors and, in particular, by ELEVATE REPUTATION MANAGEMENT, LLC.

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2. GLOSSARY

"Addendum" is the document that governs the relationship between the Merchant and ELEVATE REPUTATION MANAGEMENT, LLC regarding privacy. "Personal Data" means any information concerning an identified or identifiable natural person, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more characteristic elements of his or her physical, physiological, genetic, mental, economic, cultural, or social identity.

ELEVATE.REVIEWS is the company ELEVATE REPUTATION MANAGEMENT LLC

- 214 OVERLOOK CIRCLE, SUITE 200, BRENTWOOD, TN 37027

"Processor" the natural person, legal entity, public administration and any other entity that processes personal data on behalf of the Controller.

"Controller" the natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including security measures.

"User(s)" and/or "Customer(s)" "Data Subject(s)" the individual who visits the website elevate.reviews and uses the service, i.e. the one to whom the Personal Data refers who, unless otherwise specified, coincides with the Data Subject.

3. CATEGORIES OF DATA

The Controller collects directly from its Users, Personal Data and other information as part of the online registration processes on the website elevate.reviews, in order to provide the services requested by Users (typically these are data such as e-mail address, first name, last name, contact telephone number of a contact person).

The subject of processing may be personal data of Users such as:

a. Data provided in the basis of registration and the data necessary for payment.

ELEVATE REPUTATION MANAGEMENT, LLC will process personal data necessary to register properly on the site to allow access to the platform and the use of related services. This data is provided directly by the Data Subject and may include personal data and contact details, including but not limited to first name, last name, date of birth, e-mail address and telephone number. ELEVATE REPUTATION MANAGEMENT, LLC will also process data necessary for the payment of non-free services by the registered User, including any billing information. If the User authorizes it, or through the use of cookies, ELEVATE REPUTATION MANAGEMENT, LLC may store authentication or payment and billing data, which the User may delete at any time and will be used only for the purposes of contract performance.

b. Automatically collected data.

The computer systems and applications dedicated to the operation of the elevate.reviews website detect, in the course of their normal operation, certain data (the transmission of which is implicit in the use of Internet communication protocols) potentially associated with identifiable users. The data collected include the IP addresses and domain names of the computers used by Users connecting to the site, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.. ) and other parameters regarding the operating system, browser and computer environment used by the user, name of the internet service provider (ISP), date and time of visit, web page of the visitor's origin (referral) and exit.

c. Data provided voluntarily by the User.

The voluntary and explicit sending of electronic mail to the addresses indicated in the different access channels of this site does not imply a request for consent and involves the acquisition of the sender's address and data, necessary to respond to requests, as well as any other personal data included in the message. These data are understood to be voluntarily provided by the User at the time of the request for the provision of the service. By entering a comment or other information, the User expressly accepts this document, and in particular agrees that the contents entered may also be freely disseminated to third parties. On the contrary, specific summary information will be reported or displayed on the pages of the site set up for particular services on request (forms). The user must therefore explicitly consent to the use of the data in these forms in order to send the request.

d. Data processed as Data Processors.

ELEVATE REPUTATION MANAGEMENT, LLC processes the data provided by Merchants as a data processor and in accordance with the requirements contained in the Addendum. In particular, ELEVATE REPUTATION MANAGEMENT, LLC guarantees to comply with the instructions of the Merchant and not to use such data for its own purposes, such as marketing, market research, communication to third parties or dissemination.

e. Cookies.

The site uses cookies. The data collected through cookies may be used to access parts of the site or for statistical purposes or to make the browsing experience more pleasant and more efficient in the future, trying to assess user behavior and to modify the proposition of offering content according to their behavior. Cookie Policy included following the Privacy Policy.

f. Plug-ins.

The site also incorporates/incorporates social media plug-ins and/or buttons to enable easy sharing of content on your favorite social networks. Such plug-ins are programmed not to set any cookies when you access the page, to safeguard your privacy. Eventually cookies are set, if so provided by the social networks, only when the user makes actual and voluntary use of the plug-in. Keep in mind that if the user browses while being logged into the social network then he/she has already consented to the use of cookies conveyed through this site at the time of registration with the social network. The collection and use of information obtained by means of the plug-in is governed by the respective privacy policies of the social networks, to which please refer.

4. SOURCE OF PERSONAL DATA

Personal data held by the Owner are collected directly from the Data Subject. End-customer data are uploaded by Merchants as part of the use of services.

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5. PURPOSE DATA PROCESSING AND LEGAL BASIS

The processing of Users' data has the following purposes and legal basis:

1. Registration and access to services

Purpose: authentication and use of the site. Legal basis: contractual fulfillment.

2. Payment processing.

Purpose: access to certain purposes of the service. Legal basis: contractual fulfillment.

3. Storage of Users' payment data.

Purpose: to speed up the purchase process. Without consent, nothing will be stored. Legal basis: consent of the User.

4. Communication to business partners and/or third parties

Purpose: Communications for marketing, promotional and/or commercial purposes. Legal basis: consent of the User.

5. Newsletter

Purpose: to send e-mail about news and topics of interest. Legal basis: consent of the User.

6. Sending direct marketing communications

Purpose: updates on the Owner's products and services. Legal basis: legitimate interest of the Owner.

7. Service maintenance and improvement.

Purpose: Use of aggregated and anonymous data to improve the service. Legal basis: legitimate interest of the Owner.

8. Detecting or preventing fraudulent activities.

Purpose: To detect, prevent or stop fraudulent activities on the site. Legal basis: legitimate interest of the Owner and legal obligation.

9. Compliance with court orders Purpose: to comply with legal obligations.

Legal basis: legal obligation.

10. Accounting records.

Purpose: to comply with legal obligations. Legal basis: legal obligation.

11. Automatically collected data.

Purpose: to ensure and improve the web browsing experience. Legal basis: the legitimate interest of the Data Controller.

12. Data voluntarily provided by the User,

Purpose: is the purpose inherent in the request to enter that data. Legal basis: consent of the User.

13. For cookies and plug-ins: see the cookies policy below

The provision of personal data for the purposes referred to in point 1 and 2 of this article is necessary to allow you to register on the platform and to conclude the contract. Therefore, in the absence of the aforementioned data, you will not be able to use our services.

Consent for the purposes referred to in point 3, 4 and 5 is optional and does not entail any negative consequences for Users' experience.

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6. DATA RECIPIENTS

To the extent relevant to the stated processing purposes, Users' data may be disclosed to partners, consulting companies, private companies, third-party technical service providers, hosting providers, IT companies, communications agencies.

If the suppliers process personal data on behalf of the Data Controller, they will be appointed as data processors ex art. 28 GDPR.

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7. DATA TRANSFER TO A THIRD COUNTRY

The elevate.reviews website may share some of the data collected with services located outside the European Union area. In particular, through social plug-ins and the Google Analytics service. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of the EU Regulation 2016/679, so it does not require specific authorizations.

8. PERIOD OF CONSERVATION

According to the principle of storage limitation (art.5, GDPR), the verification of the obsolescence of the stored data in relation to the purposes for which they were collected is carried out periodically.

In particular:

(a) automatically collected data are processed, for the time strictly necessary, for the sole purpose of

derive statistical information on the use of the site and to check its regular operation,

also for security purposes or according to the deadlines stipulated by legal regulations;

b) the data voluntarily provided by the user will be kept for a period of time not exceeding the achievement of the purposes for which they are processed or according to the deadlines provided by the

legal regulations.

9. RIGHTS OF THE DATA SUBJECT

The Data Subject always has the right to request from the Data Controller access to his/her data, rectification or erasure of data, restriction of processing or the possibility to object to processing, to request data portability, to revoke consent to processing by asserting these and other rights under the GDPR by simple communication to the Data Controller. The Data Subject may also lodge a complaint with a supervisory authority.

The Interested Party may forward these requests to the following e-mail address: info@elevate.reviews

10.DATA PROCESSING METHODS.

The personal data provided by the Users will be subject to processing operations in compliance with the aforementioned regulations and the obligations of confidentiality that inspire the activity of the Data Controller. The data will be processed both with computer tools and on paper media as well as on any other type of suitable media, in compliance with the adequate security measures pursuant to Article 5 par. 1 letter F of the GDPR.

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11.FINAL NOTES AND WAY OF UPDATING

The information is provided only for the elevate.reviews website and not also for other websites that may be consulted by the user through links contained in this site. The policy may be subject to change due to the introduction of new legislation in this regard, therefore the User is invited to periodically check the Privacy Policy in order to be updated on the latest legislative changes.

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COOKIE POLICY OF ELEVATE REPUTATION MANAGEMENT, LLC

Data Subject,

Cookies are small text files sent by the site to the Data Subject's terminal (usually the browser), where they are stored and then transmitted back to the site the next time the same User visits. A cookie cannot retrieve any other data from the User's hard drive or transmit computer viruses or acquire e-mail addresses. Each cookie is unique to the User's web browser. Some of the functions of cookies may be delegated to other technologies. In this document the term 'cookies' is intended to refer both to cookies, properly so called, and to all similar technologies. By means of cookies, it is possible to record information related to preferences, such as pages browsed or file downloads from the site or other similar actions performed while browsing the site.

FIRST- OR THIRD-PARTY COOKIES

Cookies can be first-party or third-party cookies:

- "First Party" means cookies developed by the Site Owner itself,

- "Third Party" means cookies developed by Third Parties than the Site Owner.

NATURE OF COOKIES

Relative to the nature of cookies, there are different types:

Technical cookies

Technical cookies are those used for the sole purpose of "carrying out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide such service" (see Article 122(1) of the Code). They are not used for any further purposes and are normally installed directly by the website owner or operator.

They can be divided into:

- navigation or session cookies, which ensure normal navigation and use of the website

website (allowing, for example, to make a purchase or authenticate to access restricted areas

reserved areas); they are in fact necessary for the proper functioning of the site;

- analytics cookies, assimilated to technical cookies where used directly by the site operator to collect information, in aggregate form, on the number of users and how they visit the site itself, in order to improve the performance of the site;

- functionality cookies, which allow the User to navigate according to a set of criteria

selected (for example, products selected for purchase, language, etc.) in order to improve the service rendered to the same. Users' prior consent is not required for the installation of such cookies.

Profiling cookies

Profiling cookies are aimed at creating profiles related to the User and are used in order to send advertising messages in line with the preferences expressed by the same in the context of web browsing.

The consent of the Data Subject is required for the use of profiling cookies.

According to Order No. 229 of May 8, 2014, the User must be able to authorize or deny consent to the installation of profiling cookies if they are present.

In the case of third-party cookies, the site does not have direct control over individual cookies and cannot control them (it can neither install them directly nor delete them). However, the User can manage these cookies through the browser settings (follow the instructions below), or the sites indicated in the "Cookie Management" section.

The User is therefore invited to check the relevant cookie policies on the Third Party sites.

The updated list of cookies in use on the platform can always be accessed through the following process:

1. Click on the lock icon next to the url;

2. Select the "Cookies" button;

3. View the various categories and subcategories of cookies in use;

4. Opt "block" or "remove" from each unwanted cookie.

COOKIE DURATION

Cookies have a lifetime dictated by the expiration date (or a specific action such as closing the browser) set when they are installed.

Cookies can be:

● temporary or session "session cookies": these are used to store temporary information, allow you to link actions performed during a specific session, and are removed from your computer when you close your browser;

● permanent "persistent cookies": these are used to store information, such as the login name and password, so that the user does not have to type them in again each time he or she visits a specific site. These remain stored on the computer even after closing the browser.

The so-called session cookies, once the connection to this website is terminated, are not stored. The computer systems used for this website use temporary cookies and permanent cookies.

COOKIE MANAGEMENT

Users can disable cookies on websites by downloading special software such as Ghostery (https://www.ghostery.com) for your browser and disabling the use of individual cookies. Or they can activate the "anonymous browsing" mode - this is a function that allows you to browse without leaving a trace of your browsing data in your browser. This function only allows them not to keep their browsing data in the browser.

Alternatively, they will be able to disable/delete cookies by accessing the configuration panel of your browser.

ACCEPTANCE AND WAIVER OF COOKIES

By continuing to browse this site, closing the information wrapper or clicking anywhere on the page or scrolling down to highlight further content, you agree to the Cookie Policy and cookies will be set and collected. If you do not accept cookies by quitting browsing, any cookies already registered locally in your browser will remain registered there but will no longer be read or used by us until you later accept the policy. Users will always have the option to remove such cookies at any time through the aforementioned methods.