Privacy Policy - August 16, 2021

1. OVERVIEW OF POLICY

This Privacy Policy (this “ Policy ”) is provided by Imbassy, LLC (also “ we ” or “us ” or “our ”) regarding our activities on Users’ (also “ user ” or “you” or “ your”) data processing.

Data processing involves the collection, use, disclosure, and security of users’ data. We comply with data processing rules set by the GDPR because we understand the risk involved when your data is accessed by unauthorized individuals or parties. For GDPR purposes, Imbassy, LLC is your data controller.

By submitting personal data during your subscription to our various offerings, you agree to the processing practices as described in this Policy. If you do not agree with how we process your data, you may not use our access offerings or access our website.

2. DATA COLLECTION

When you opt in to subscribe to our offerings, we collect certain personal data from you which is necessary to fulfill your request. The data we collect from you includes but are not limited to:

• Personal data such as name, email address, phone number, and other contact data;

• Tracking data such as your Internet Protocol Address (“ IP Address”), browser type, device information, and location information;

• History of previous transactions;

• Statistical information;

• Cookie data that we collect automatically;

• Data you provide when you Contact Us;

3. HOW WE USE COLLECTED DATA

We use the different types of data we collect for the following purposes;

• Your contact data such as name, email address and phone number are used to contact you regarding updates, news, promotions (“newsletters”) and to respond to your requests;

• Non-personal information such as IP Address, browser type, location, and device type are collected automatically in order to pin-point your location and to enforce our Terms and Conditions;

• Cookie information helps us to track some activities about you in order to make your experience on the website easy and to tailor adverts that match your preference;

• Statistical data helps us identify where to improve on the website and what features need to be developed;

4. DISCLOSURE OF DATA

We do not share your data with any third party for marketing activities neither do we sell your data for direct marketing; however, we may be obligated to disclose your information to:

a. Third-party service providers: Third party service providers are groups, entities, or individuals that perform one task or the other for us. Third party service providers are obligated to use your data for the task given to them only. They are not permitted to use your data for anything else.

b. Regulating Authorities: Where we have the legal obligation to share your data subject to suspected fraudulent activities, we may disclose your data to government agencies, regulating bodies, and law enforcement.

c. Business Transfers: Business transfers refers to activities of bankruptcy, merger, acquisition, or consolidation. We may be required to disclose or transfer your information to any Agency we merge with or consolidate with (whatever the case may be).

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies are pieces of data that Imbassy, LLC sends to your browsing device in order to track and store some data about you. Cookies track and store activities such as your preference, where you navigate to mostly, what features you use most, and login information. Certain browsers automatically accept cookies while some ask upon opening this page. Nevertheless, you can deactivate cookies by going through your browser setting, but you will be restricted to some features. The types of Cookies we use include session cookies, essential cookies, and performance cookies. Session cookies help us to remember users when they come back to the website. Essential cookies aid smooth and easy navigation on the website and are also responsible for your ability to access all the website features. Performance cookies, on the other hand, enable Imbassy, LLC to monitor statistics and other activities such as what feature is accessed most by users.

We also use other tracking technologies such as Google Analytics to track your activities and tailor the best adverts which we believe matches your interest. If you do not want Google Analytics, you may install the Google Analytics opt-out browser add-on on your browser.

6. MARKETING

Imbassy, LLC may send you marketing emails such as promotions, offers, and interests to your submitted email (“Marketing Emails”). The content of Marketing Emails may include things which we feel may be of interest to you. You may opt-out of Marketing Emails by using the unsubscribe link/button in any of the Marketing Emails sent to you.

7. DATA SECURITY

We employ both physical and technical measures to keep your data out of the reach of unauthorized individuals. We store any data we collect from you and limit the number of people who may access it. However, you should be aware that no matter how secure the measures we take are, it may not be enough. We cannot guarantee you that your information will be totally safe from hackers, and, therefore, will not be liable for any privacy/data lost to theft. You are also implored to keep your login data confidential.

8. DATA RETENTION

The data we collect from you will be retained for as long as you are subscribed to our offerings. Partial data will be retained for seven (7) years after you terminate your subscriptions. This is to comply with regulatory requirements and enforce our Terms and Conditions.

9. USER RIGHTS UNDER GDPR

You have the following right regarding the processing of your data;

• Modify or update your data in your account area. You may update your personal data by going through your account setting or asking us to do it for you;

• The right to request for a printable copy of the data we hold about you;

• You may request the deletion of the personal data we hold about you. Send your deletion request to our email address at ops@imbassy.com;

• The right to stop us from further processing your data; and

• The right to report us to any regulating authority near you if you believe the processing of your data is wrong.

10. LEGAL BASIS FOR DATA PROCESSING

We process your data because of the following reasons;

• You have consented to the processing;

• Processing your data is needed to provide you the Services;

• We process in order to comply with regulatory requirements;

• Processing your data is for our legitimate interest;

• We also process your data in order to safeguard other users’ lives;

• Processing is in the public interest.

11. MINOR

Imbassy, LLC is made available to individuals who are at least 18 years of age. We do not knowingly permit individuals below the age of 18 (“Minors”) to use our Services. By using our Services, you warrant and represent that you are not a minor and can enter into this contract with Imbassy, LLC. If we learned that you are a Minor, then you have violated our Terms and Conditions, and we may refuse or terminate your participation on our website without liability to you.

12. THIRD PARTY LINKS

Our website may contain links or adverts from third party partners. We do not control the content on these links; neither do we control their privacy practices. If you desire to access a third party link or advert on our website, you should read their respective privacy policies to know their data processing practices. Imbassy, LLC will not be liable to you for any privacy lost due to the third party link or advert you accessed through our website.

13. GOVERNING LAW

This Policy is governed and construed by international laws without regards to conflict of law and its provisions.

14. UPDATES

This Policy is subject to frequent modifications, updates, revisions, amendments, and changes (collectively “Updates”) as the case may be at our discretion (with or without notice to you). The Updates shall be carried out by posting the updated version of this Policy on this page and updating the date above.

15. PAYMENTS

We use Stripe for payment, analytics, and other business services. Stripe collects identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy.

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