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PRIVACY POLICY

surfer, Inc., (“surfer”, “we," “us,” “our”), takes the security and privacy of your personal information very seriously. We want you to be familiar with how we collect, use, and disclose information relating to you, your computer, or your device and that enable your identification (the “Personal Information”). This Privacy Policy describes our practices with information that we collect through our websites, applications, and our network-connected products and services that link to this Privacy Policy (collectively, the “Platform”). This Privacy Policy only addresses information collected directly through or from the Platform – it does not address or govern any information-gathering, use, or dissemination practices related to information collected from you other than directly through or from the Platform, such as from telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media. By accessing and using the Platform, you agree to the terms and conditions of this Privacy Policy.

If you have any questions concerning this Privacy Policy, please contact surfer HUB by e-mail at: info@hellosurfer HUB.com.


1. INFORMATION WE COLLECT

a. Information You Provide

Some elements of the Platform will ask you to submit Personal Information in order for you to benefit from the specified features or to participate in a particular activity. For example, we may request Personal Information from you when you purchase products on the Platform, including your name, billing address, shipping address, payment information (including credit card number), email address, and phone number. You may also have the opportunity to submit other data and information about yourself and your surroundings, such as your present location or another location of interest. You will be informed what information is required to utilize these features of the Platform, and what information is optional.

If you contact us, we will keep a record of that correspondence. You may also voluntarily provide information to us if you complete a survey or answer questions about your experience with the Platform.

We may combine the information you submit through the Platform with other information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, including publicly available information sources (such as publicly available social media profiles) as well as our service partners and data licensors, in compliance with applicable laws. We may inform you of other information collected by or through the Platform at the point of collection.

b. Passive Information Collection, Use, and Choices

As you navigate the Platform, certain Personal Information may be passively collected, meaning it is gathered without your actively providing it. We may collect and store such information automatically whenever you interact with the Platform. This is done using the following technologies in the following ways:

i. Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.

ii. Through your device: If you access the Platform through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the Platform.

iii. Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Platform, pages visited, and language preferences. We and our service providers use this information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Platform. More specifically, we use cookies to:

·recognize your computer or device to make your use of the Platform easier, such as to remember your locations of interest and other preferences with the Platform;

·gather statistical information about use of the Platform in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it;

·select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Platform and on other websites, applications, and online services that you use; and

·track consumer responses to online advertisements. To learn more about cookies, please visit http://www.allaboutcookies.org.

iv. Using Monitoring Tools: The Platform may utilize pixel tags, web beacons, clear GIFs, Flash Shared Objects, HTML5 Local Storage, HTML5 Mini Databases, and other similar technologies (collectively, “Pixel(s)”), both on certain aspects of the Platform and in HTML-formatted e-mail messages to you. These monitoring tools are used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Platform usage and response rates, and tracking the activities of users of the Platform and e-mail recipients.

v. IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Platform, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Platform usage levels, helping diagnose server problems, and administering the Platform.

vi. Analytic Tools: We also use tools and third-party services to collect information about usage of the Platform, including Google Analytics. You can learn more about Google Analytics, and its privacy practices, at the Google Analytics Help Page. Generally speaking, Google Analytics collects information on how often users visit the Platform, what aspects of the Platform they visit when they do so, and what other websites users visited prior to accessing the Platform. The Platform makes use of Google Analytics services for Demographics and Interest Reporting as well as Display Advertising features, including Remarketing, Google Display Network Impression Reporting, and DoubleClick Campaign Manager integration. You may opt out of Google Analytics for Display Advertising or customize Google Display Network ads through the Google Ads Settings page. You may also prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on.

vii. Location-Based Features: We may use information about your location to determine our retail store closest to your location, conduct analytics, and improve the Platform and to provide certain location-based features and services, as further described in this Privacy Policy and as otherwise described to you at the point of collection. To provide these location-based features, in addition to the information about your location that you voluntarily submit through the Platform, we may also access information about your location using automated means. We generally will collect information about your latitude, longitude, and the date and time when you accessed the Platform. We may disclose location information as described in Section 2(a) of this Policy. Some services on the Platform may continuously track your location information to allow our third-party advertising partners to deliver advertisements that are relevant to your current location. Depending on how you access the Platform, your web browser or your mobile device operating system may inform you that the Platform would like to collect your location and request permission to do so. If you allow such access, the Platform will collect your location information. If you decline, you will need to manually enter your location information to utilize certain features of the Platform.

If you are uncomfortable with the idea of your Personal Information being collected and used in these ways, most computer systems, devices, and web browsers offer privacy settings and options, such as disabling cookies, resetting your IDFA, and turning off location-based services. See Section 2(d) below for more information on opting out of Interest-Based Advertising. We do not override these settings or options and encourage you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products, or benefits of the Platform, you may be required to provide us with certain information. If you do not wish to provide that information through the Platform or if you opt to utilize the aforementioned privacy features, you may be unable to obtain certain content, features, services, products, or benefits of the Platform. Changing these settings will not prevent you from seeing advertisements and offers, but those advertisements and offers may not be tailored to your interests and needs.

c. Social Media and Other Third-Party Platforms

You may engage with our content, such as video, applications, and other offerings, on or through social media services or other third-party platforms, such as Facebook, Twitter, and Pinterest. When you engage with our content on or through social media services or other third-party platforms, plug-ins, integrations, or applications, we may have access to certain information in your profile with that service or platform. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third-party platform or social media account user files, photos and videos, your list of friends or connections, people you follow and who follows you, and your posts and “likes." For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.


2. HOW WE USE AND DISCLOSE INFORMATION

a. Overview of Use and Disclosure

We use Personal Information for the purposes described in this Privacy Policy and as otherwise described to you at the point of collection. Except as otherwise provided herein, we do not sell, trade, or rent your personal information to others. Specifically, we may use Personal Information from or about you:

i. to provide the requested services and process transactions with you;

ii. to communicate with you and respond to your inquiries;

iii. to customize the content or services on the Platform for you and to present products and offers tailored to you;

iv. to send you important information regarding our relationship with you or regarding the Platform, such as changes to our terms, conditions, and policies, and other administrative information;

v. to promote our products and services, and the products and services of our third-party business partners; and

vi. for our business purposes, such as data analysis, audits, developing new products, enhancing the Platform, improving our products and services, identifying Platform usage trends, and determining the effectiveness of our promotional campaigns.

We may use any information that does not personally identify you, your computer, or your device, for any purpose.

In order to provide the features and services made available through the Platform and accomplish the goals described in this Privacy Policy or at the point when we collect the information, we disclose your Personal Information as described below and as specifically described elsewhere in this Privacy Policy or at the point we collect information from you:

1. to our affiliates and subsidiaries for the purposes described in this Privacy Policy;

2. to unaffiliated third parties (such as data brokers, marketing companies, and IT service providers), including by sharing or selling demographic information, location data, advertising and device identifiers, IP address, and usage statistics to our advertising partners and other third parties, some of whom may use it to offer promotions to you for other products and services;

3. to our third-party service providers who provide services to us, such as website hosting and moderating, mobile application hosting, data analysis, payment processing, infrastructure provision, IT services, customer service, e-mail and direct mail delivery services, auditing services, and other services, in order to enable them to provide those services; and

4. to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

b. Third Party Payment Processor

We use a third-party payment processor to assist us in processing your personally identifiable payment information securely. The information collected for payment purposes, such as your credit card number and expiration date, are collected by the third-party payment processor. Such third-party processor’s use of your Personal Information is governed by its own separate privacy policy, which may or may not contain privacy protections as protective as this Privacy Policy. We will inform you which payment processor is used when processing your payments.

c. Uses and Disclosures to Comply with Laws

In addition, we use and disclose Personal Information collected through the Platform as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

d. Interest Based Advertising

We work with a variety of third-party business partners, including advertisers, advertising networks, and advertising and analytics companies that use various technologies to collect data about your use of the Platform, which may include location data. surfer HUB and our third-party business partners may use the aforementioned technologies to:

i. track how you use the Platform, how you arrived at the Platform, and what you do after you leave the Platform;

ii. record and link your devices, including your personal computer and mobile device (this is called cross-device linking); and

iii. provide you with advertisements relevant to your interests, taking into account your use of the Platform and the other websites and online services that you use. Note that these advertisements may be delivered to you on the Platform, on third-party websites and applications, and on a computer or device other than the device from which the information was collected. For example, we provide data about your use of the Platform to Facebook for advertisement targeting purposes.

This is called “Interest-Based Advertising” or “Online Behavioral Advertising.” While we work with our third-party business partners to improve your experiences with the Platform, we do not control their business practices.

If you wish to opt-out of participating in Interest Based Advertising, you can use some or all of the methods below. If you use more than one device, you should renew your opt-out choices on each such device.

1. Visit http://www.aboutads.info/choices (for web-based advertising), and http://www.aboutads.info/appchoices (for mobile advertising). To learn more, please visit the website operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices;

2. For mobile advertising, use your phone operating system’s opt-out setting. For instructions on how to “Limit Ad Tracking” on iOS, please visit https://support.apple.com/en-us/HT202074. For instructions on how to opt out of interest-based ads on Android, please visit https://support.google.com/ads/answer/2662922?hl=en; and

3. In accordance with industry self-regulatory principles, you should see an active link in or around surfer HUB advertisements that are delivered on other sites using information collected on the Platform, and in or around third-party advertisements that are delivered on the Platform using Interest Based Advertising programs. Clicking on this link will provide information about the companies and data practices that were used to deliver the ad and will also describe how you may opt-out of these advertising programs.

The Platform does not process Do-Not-Track (DNT) headers transmitted by Web browsers. Our third-party web analytics companies collect information about your online activities over time. These third parties do not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.


3. INFORMATION RELATED TO MINORS

The Platform is not intended for persons under the age of 18. We do not knowingly collect personal information online from persons in this age group. We reserve the right to delete any information identified as having been provided by such persons at our discretion.


4.THIRD-PARTY WEBSITES AND SERVICES

The Platform may also contain links to or utilize the features of third-party websites and other online services, including third-party payment processors, for your convenience with locating information, products, or services that may be of interest. If you access a third-party service from a link on the Platform, any information you disclose to that third party is not subject to this Privacy Policy. In addition, it is possible that these links may be used by third parties or others to collect personal or other information about you.

Some aspects of the Platform may also allow you to interface with other websites, social media, and other online services, such as Facebook. We will diligently work to identify these aspects of the Platform to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services, as described in more detail in in Section 1(e) of this Policy. If you interface with the Platform through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services.

We are not responsible for the privacy practices of other online services, including other websites, advertisers, payment processors, and social media. It is your sole obligation to review and understand the privacy practices and policies of third parties. We do not control the use of cookies or the collection of information by these third parties, nor how they manage such information. The availability of, or inclusion of a link to or interface with, any third-party service on the Platform does not imply endorsement of it by us or by our affiliates. Your use of those other sites and services is subject to the privacy policies of those sites and services, and not this Privacy Policy.


5. SECURITY

The security of your Personal Information is important to us and we are committed to handling that information carefully. We use reasonable and appropriate organizational, technical, and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately notify us of the problem.


6. DATA RETENTION

We generally retain Personal Information for so long as it may be relevant for the purposes identified in this Privacy Policy or at the time the information is collected, unless a longer period of time is required by law.


7. YOUR DATA RIGHTS AND CHOICES

Registered users can update their profile information on the Platform.

We want to communicate with you only if you want to hear from us. If you have signed up to receive electronic newsletters or promotional emails from surfer HUB, including new ideas, special offers, and event information, or to otherwise receive communications about our services, you will have the right at any time to opt out of receiving marketing emails or to specify which, if any, communications you would like to receive from us. Should you ever decide to delete your account, you may do so via the Platform or by emailing info@hellosurfer HUB.com. You can opt-out of the use of certain cookie-related processing by following the instructions above (Passive Information Collection, Use, and Choices).

If you would like to opt-out of receiving marketing via email, click the unsubscribe link on the footer of marketing emails. If you would like to opt-out of receiving communication via postal mail, contact info@hellosurfer HUB.com. surfer HUB will continue to send you non-promotional, service emails concerning your account, such as emails relating to available upgrades, billing and payment information, outstanding balance on your account, and other emails relating to your account and/or your use of the Platform.

At your request, surfer HUB will confirm what Personal Information it collects or holds about you, and will correct, update and/or remove such information. You may contact surfer HUB for any of the foregoing at info@hellosurfer HUB.com. You are solely responsible for maintaining your account with updated and accurate information. If you ask that surfer HUB stops using or sharing your Personal Information, we will honor that request. However, surfer HUB may retain records of your Personal Information for a period of time; for example, to follow-up on a request, resolve a dispute or for similar reasons or in order to comply with applicable federal, state, or local law. In addition, some personal information may also continue to be stored on back-up files for financial, legal, or technical reasons.


8. RIGHT TO CHANGE PRIVACY STATEMENT

surfer HUB reserves the right at any time to modify, alter, or update this Privacy Policy. Your use of the Platform following any changes means that you agree to follow and be bound by the Privacy Policy as changed, subject to limitations under applicable law. Any change to this Privacy Policy shall be effective as to any user who has visited the Platform before the change was made. Please review this policy periodically, and especially before you provide any Personal Information to us. The Privacy Policy was last updated on the date indicated above.


9. CALIFORNIA

California Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who are California residents to request and obtain from us once a year, free of charge, information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request to the email address identified above.