Privacy Policy

Effective Date: 21 April 2021

This Privacy Policy (“Privacy Policy”) describes how Microshare.com (hereinafter, “Microshare,”

“we” or “us”) processes personal data about you that we collect through our website at

https://microshare.io, as well as any other applications operated and controlled by us from which

you are accessing this Privacy Policy (the “Site”). This Privacy Policy is included with and

supplements our Terms of Use. The services that we may provide to you via the Site are referred

to herein as the “Services.” This Privacy Policy explains our online information collection and use

practices, and the choices you can make about the way we use such information. This Privacy

Policy does not apply to information that we collect offline, such as by telephone, facsimile, postal

mail, personal delivery, or other offline means or media. It is important that you take the time to

read and understand this Privacy Policy so that you can appreciate how we use your personal

information.

REMEMBER IF YOU USE OR ACCESS THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY. AS WE

UPDATE OR EXPAND THE SERVICES, WE MAY CHANGE THIS PRIVACY POLICY UPON NOTICE TO

YOU, HOWEVER, PLEASE REVIEW IT FROM TIME TO TIME.

1. Important Notices

A. EU Privacy Rights. For users that are citizens of the European Union (“EU”), this Privacy

Policy is subject to the provisions of the General Data Protection Regulation (“GDPR”) and other

applicable privacy laws. In such case, we are a data “Controller” and you are a “Data Subject”

with certain protected privacy rights concerning your “Personal Data.” We will take commercially

reasonable steps to maintain compliance with GDPR requirements. Your Personal Data may

identify you as a person, and thus is often referred to as Personally Identifiable Information (“PII”).

B. California Privacy Rights. The California Consumer Privacy Act (“CCPA”) of 2018

enhances privacy rights and consumer protection for residents of California. Under the CCPA,

California residents have the rights to: 1) know what Personal Data are being collected about

them; 2) know whether their Personal Data are sold or disclosed, and to whom; 3) say ‘no’ to the

sale of their Personal Data; 4) access their Personal Data; and 5) not be discriminated against for

exercising their privacy rights under the CCPA. California law allows California residents to request

information regarding our disclosures in the prior calendar year, if any, of their PII to third parties.

To make such a request, please contact us at info@microshare.io. Please include enough detail

for us to locate your file; at a minimum, your name, email and username, if any. We will attempt

to provide you with the requested information within thirty (30) days of receipt. We reserve our

right not to respond to requests sent more than once in a calendar year, or requests submitted to

an address other than the one posted in this notice. Please note that this law does not cover all

information sharing. Our disclosure only includes information covered by the law.2. Who Collects Your Information?

We do. We collect information from you via the Services, and we are responsible for protection

of that information.

3. What Information Do We Collect?

A. Requested Information. On various pages on the Services, we may request specific PII

about you in order to register you for an account to use our Services, add you to our email list, or

fulfill your requests for information. You may choose not to provide your PII, but then you might

not be able to take advantage of some of the features of our Services. We only collect basic

Personal Data about you that does not include any special types of information (e.g., health-

related). The types of Personal Data we collect and save include:

• Contact and account registration information such as name, email address, physical

address, phone number, business name, business URL;

• Information that you may provide in using our Services;

• Information you provide such as feedback, comments or other messages;

• Technical information collected in our logs (e.g., your IP address, page URLs and

timestamp, etc.); and

• Device information such as the mobile phone provider associated with the device you are

using to access the Services, your device’s unique identifier, the type of device and its

operating system, the pages or features accessed most frequently, how pages or features

• of the Services are used, search terms entered, and similar analytics about use of the

Services.

B. Anonymous and Aggregate Information. We may use data capture, syndication, analysis

and similar tools to extract, compile, synthesize and analyze non-PII data collected via your access

and use of the Service (“Anonymous Data”). We may further aggregate and combine your de-

identified Anonymous Data with that of others (“Aggregated Data”). To the extent that we collect

any Anonymous Data or Aggregated Data, we shall own such Anonymous Data or Aggregated

Data and may use it for any lawful business purpose without a duty to account to you for such

use, provided that Anonymous Data is used only in an aggregated form, without specifically

identifying the source of the Anonymous Data. Without assuming any obligations or liabilities of

yours, we agree to use commercially reasonable efforts to comply with applicable laws and

regulations respecting the dissemination and use such Anonymous Data or Aggregated Data.

C. Location Information. We may collect, maintain, process and use your location data,

including the real-time geographic location of your mobile device (“Location Data”) as necessary

to provide the Services. By using or activating any location-based services on a mobile device,

you agree and consent to our collection, maintenance, publishing, processing and use of your

Location Data in order to provide you with the Services. We do not collect Location Data in a

form that personally identifies you. You may withdraw your consent to our use of your Location

Data at any time by turning off the location-based services on the mobile device you are using,

or by not using any location-based features. Turning off or not using location-based features mayimpact the functionality of the Services as delivered to you. Location Data provided by the

Services is used for basic navigational purposes only, and is not intended to be relied upon in

situations where precise location information is needed or where erroneous, inaccurate or

incomplete Location Data may lead to death, personal injury, property or environmental damage.

Any use of real-time route guidance via the Services is at your sole risk. You understand that

Location Data provided by the Services may not be accurate. We do not guarantee the availability,

accuracy, completeness, reliability or timeliness of Location Data displayed by the Services.

4. Why Is My Information Being Collected?

We need to collect your Personal Data so that we can provide the Services, respond to your

requests for information and demonstrations, add you to our emailing lists, and process your

requests for access to our Services. We also collect Aggregate Data to help us better design the

Services. We collect log information for monitoring purposes to help us to diagnose problems

with our servers, administer and troubleshoot the Services, calculate usage levels, and provide

support to you.

5. How Do We Use the Information We Collect?

A. We use the Personal Data you provide for the purposes for which you have submitted it

including:

• Responding To Your Inquiries and Fulfilling Your Requests. We may use your PII to

respond to your inquiries and to fulfill your requests for information.

• Creating and Maintaining Your User Account. We use your PII to create and maintain

an account for you to allow you to purchase and use the Services we make available.

• Communicating With You About Our Services. We may use your PII to send you

marketing information about new Services and other items that may be of interest to you.

We may also contact you on behalf of our third party business partners about a particular

offering of theirs that may be of interest to you.

• Improving Our Services. We may use your information to make our platform more stable

and user-friendly, to analyze Services issues, and to develop new marketing programs

relating to the Services.

• Sending Administrative Emails. We may use your PII to send you email messages to: (a)

confirm your account and your other PII, (b) process transactions that you make using our

Services, (c) provide you with information regarding the Services, or (d) inform you of

changes to this Privacy Policy, our Terms of Service, or our other policies.

B. We may use Anonymous Data and Aggregate Data to improve the design and content of

our Services, enable us to personalize your Internet experience, analyze how our Services are used,

analyze industry trends, as well as offer new products.

6. Do We Share Your Personal Data?

A. In general, we will not share your Personal Data except: (a) for the purposes for which you

provided it; (b) with your consent; (c) as may be required by law (e.g., in response to a court orderor subpoena, or in response to a law enforcement agency request); (d) as we think necessary to

protect our organization or others from injury (e.g., when we believe that someone is causing, or

is about to cause, injury to or interference with the rights or property of another); or (e) on a

confidential basis with persons, partners or organizations with whom we contract to carry out

internal site operations or as necessary to render the Services (“Service Providers”).

B. Although it is not our practice to sell your Personal Data, the CCPA further restricts

us from selling your Personal Data if you click the “Do Not Sell My Personal Information”

link on the Services.

C. We may share Anonymous Data or Aggregate Data with others, including affiliated and

non-affiliated organizations such as advertisers.

D. Finally, we may transfer your Personal Data to our successor-in-interest in the event of an

acquisition, sale, merger or bankruptcy.

7. Are There Other Ways My Personal Data Could Be Shared?

You may elect to share certain Personal Data with individuals (e.g., other members) or with the

public via your use of the Services. In this case, you will control such sharing via settings that we

provide. For example, the Services may make it possible for you to publicly share information via

social media such as Facebook or Twitter. Be aware that when you choose to share information

with friends, professionals, public officials, or with the public at large, you may be disclosing

sensitive information, or information from which sensitive information can be inferred. Always

use caution when sharing information through the Services. You understand and agree that we

are not responsible for any consequences of your sharing of information through and beyond the

Services.

8. How Can You Access and Control Your Information?

A. After registering for an account within the Services, you may log-in to the account and

edit your Personal Data in your profile. The Services also provide you with checkboxes to “opt

out” of data sharing activities or receipt of marketing communications from us or our alliances

that you may have previously selected. We do not automatically add you to any marketing emails

lists, but rather must obtain your consent via your “opt in” choices before doing so. For

instructions on how you can further access your Personal Data that we have collected, or how to

correct errors in such information, please send an e-mail to info@microshare.io. We will also

promptly stop using your information and remove it from our servers and database at any time

upon your request. To protect your privacy and security, we will take reasonable steps to help

verify your identity before granting access, making corrections or removing your information.

B. If you are an EU citizen and believe that we have misused your Personal Data, you have

the right to contact the European Data Protection Supervisor (“EDPS”) to ask the EDPS for advice

on how to exercise your rights or to ask the EDPS to investigate a complaint. For more

information, see EDPS Complaints.9. How Do We Store and Protect Your Information?

A. After receiving your Personal Data, we will store it on our systems for future use. We have

physical, electronic, and managerial procedures in place to safeguard and help prevent

unauthorized access, maintain data security, and properly use the information we collect.

Unfortunately, no data transmission or data storage solution can ever be completely secure. As a

result, although we take industry-standard steps to protect your information (e.g., strong

encryption), we cannot ensure or warrant the security of any information you transmit to or receive

from us or that we store on our or our Service Providers’ systems.

B. If you are using the Services from outside of the USA, you understand that your connection

will be through and to servers located in the USA, and the information you provide will be securely

stored in our web servers and internal systems located within the USA. By accessing or using the

Services or otherwise providing information to us, you consent to the processing, transfer and

storage of information in and to the USA, where you may not have the same rights and protections

as you do under your local law.

C. We store Personal Data for as long as reasonably required for its purpose or for additional

periods required by law (if any). We and our Service Providers will delete your account information

and Personal Data when you or when we delete your account. We may store information longer

for legitimate business reasons (for example, Personal Data may remain in backups for a

reasonable period of time), or as legally required. Otherwise, we store your Personal Data until

you request us to remove it from our servers. We store our logs and other technical records

indefinitely.

10. How Do We Use Cookies And Other Network Technologies?

A. Cookies. To enhance your online experience with us, our web pages may presently or in

the future use “cookies.” Cookies are text files that our web server may place on your hard disk

to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other PII

unless you choose to provide this information to us. Once you choose to provide PII, however,

this information may be linked to the data stored in a cookie. You can set your browser to notify

you when you receive a cookie, providing you with as much control as you wish as to the decision

to accept/reject the cookie, and deletion of the cookie upon leaving our Services. Please note,

however, that if your browser does not accept cookies, you may not be able to take advantage of

all of the features of our Services. If you would like more information about cookies and how to

control and delete cookies in various browsers, such as Internet Explorer, Firefox, Safari and

Chrome, please visit https://aboutcookies.org/.

B. GIFs. We or our service providers may also use “pixel tags,” “web beacons,” “clear GIFs,”

“embedded links” and other commonly-used information-gathering tools in connection with

some Site pages and HTML-formatted email messages. We use these tools for such purposes as

compiling aggregate statistics about Services usage and response rates. A pixel tag is an

electronic image (often a single pixel), that is ordinarily not visible to Site visitors, and may be

associated with cookies on visitors’ hard drives. Pixel tags allow us and our Service Providers to

count users who have visited certain pages of the Site, to deliver customized services, and to helpdetermine the effectiveness of our Services. When used in HTML-formatted email messages, pixel

tags can inform the sender of the email whether and when the email has been opened.

C. Clickstreams. As you use the Internet, you leave a trail of electronic information at each

website you visit. This information, which is sometimes referred to as “clickstream data”, can be

collected and stored by a website’s server. Clickstream data can reveal the type of computer and

browsing software you use and the Uniform Resource Locator (“URL”) or IP address of the website

from which you linked to the Site. We may use clickstream data as a form of non-PII to determine

how much time visitors spend on each page of our Site, how visitors navigate through the Services,

and how we may tailor our web pages to better meet the needs of visitors. We will only use this

information to improve our Services.

D. Do Not Track. Many modern web browsers give you the option to send a “Do Not Track”

signal to the websites you visit, indicating that you do not wish to be tracked. At this time, the

Services do not specifically respond to “Do Not Track” signals.

E. User Behavior Tracking. We may track the webpages and links our users visit within our

Services, in order to determine what Services are most popular. We may use such tracking data

to deliver customized content and advertising to users whose behavior indicates they are

interested in a particular subject area. We may also collect user data to enable “heat mapping”

capabilities that track the areas of a webpage where users most frequently move the mouse or

click. These tracking activities make it possible to monitor and analyze web traffic and evaluate

user behavior to customize our Services.

11. Collection of Information by Others

We may provide links to certain third party websites that you may click-on from our Services.

Please check the privacy policies of these other websites to learn how they collect, use, store and

share information that you may submit to them or that they collect.

12. Children and Young People’s Information

We do not knowingly collect any information from any minors, and we comply with all applicable

privacy laws including the GDPR, CCPA, USA Children’s Online Privacy Protection Act (“COPPA”)

and associated Federal Trade Commission (“FTC”) rules for collecting Personal Data from minors.

Please see the FTC’s website (www.ftc.gov) for more information. Our Services will not knowingly

accept Personal Data from anyone under 13 years old in violation of applicable laws, without

consent of a parent or guardian. In the event that we discover that a person under the age of 13

has provided PII to us without parental consent, we will make efforts to delete the person’s

information in accordance with the COPPA. If you have concerns about our Site or other Services,

wish to find out if your child has accessed our Services, or wish to remove your child’s Personal

Data from our servers, please contact us at info@microshare.io.

13. Changes to this Policy

Because our business needs may change over time, we reserve the right to modify this Privacy

Policy. If at any time in the future we plan to use your PII in a way that differs from this Privacy

Policy, we will revise this Privacy Policy as appropriate. In the event of a change to our Privacy Policy, we will email the updated policy to the email address that you provided to us. Your

continued use of the Services following our notice of changes to this Privacy Policy means you

accept such changes.

14. Our Contact Information

If you have any questions or concerns about this Privacy Policy, please contact us via e-mail at

info@microshare.io.

Copyright © Microshare.com. All rights reserved. The Services are protected by United States and

international copyright, trademark, and other applicable laws. This includes the content,

appearance, and design of the Services, as well as the trademarks, product names, graphics, logos,

service names, slogans, colors, and designs.