This Privacy Policy was last updated: 5th December 2022 and is effective from 5th December 2022.

Welcome and thank you for your interest in the SimpliTime website (the “Website”) and the software services and content made available on the Website (the Website and such services and content collectively, the “SimpliTime Services”) by SimpliTime, Inc. (“SimpliTime” or “We”). This Privacy Policy describes our policies and procedures regarding the collection, use and disclosure of your personal information on or through the Website and through all services and/or features made available on or through the Website (the Website and all services available on or through it, the “SimpliTime Services”). SimpliTime values the privacy of the visitors to the Website and users of SimpliTime Services (individually, “User” and collectively, “Users”), and makes it a priority to protect any personally identifiable information that it obtains from its Users.

This Privacy Policy describes what information SimpliTime gathers from you, how SimpliTime uses that information, and what SimpliTime does to protect that information. By using SimpliTime Services (whether or not you register for an account for SimpliTime Services), you expressly consent to the information handling practices described in this Privacy Policy. If you do not want information about you to be used in the manner set forth in this Privacy Policy, please do not access, browse or otherwise use SimpliTime Services or any part thereof.

This Privacy Policy is incorporated into and is subject to the SimpliTime Terms of Use. Your use of SimpliTime Services or any part thereof and any personal information you provide on or through SimpliTime Services are subject to the terms of this Privacy Policy and SimpliTime’s Terms of Use.

The Information SimpliTime Collects:

User-provided Information: When you register for an account for SimpliTime Services or at any later time, you may provide to SimpliTime what is generally known as “personally identifiable information” (such as your name, password, age, gender, email address, postal mailing address, zip code, and home/mobile telephone number). From time to time, SimpliTime may also ask you to provide other information if you so choose and if SimpliTime deems it necessary or helpful in the provision of SimpliTime Services or any part thereof. If you choose to provide such information, during registration or otherwise, you are giving SimpliTime the permission to use and store it consistent with this policy.

Information available from Facebook and social networking services: SimpliTime may, now or in the future, permit you to register for an account for, or sign in to, the SimpliTime Services by providing some or all of the required account information through certain third-party social networking and/or authentication services, such as Facebook Connect and Google OpenID. SimpliTime may access and use any information from your applicable social networking service account that you have configured to be made available to third parties in this manner, including your personally identifiable information. All such information will be stored and used consistent with this Privacy Policy. If you do not wish such information to be provided to SimpliTime, you may update, correct, or delete your applicable social networking service account information and preferences at any time by making the appropriate choices in the settings for such social networking service account. However, if you do so, you may not be able to sign in to SimpliTime Services and access certain services or features available thereon through such social networking service account.

“Cookies” Information: When you visit the Website, whether or not you register for an account, SimpliTime may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. Cookies remember information about your activities on a website. SimpliTime may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Website. Persistent cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. However, without cookies you may not have access to certain services or features available on SimpliTime Services. Third party content displayed in connection with SimpliTime Services may also contain cookies set by such third party. SimpliTime does not control these cookies and you should check the privacy policy of such third party to see whether and how it uses cookies.

“Automatically Collected” Information: When you access or use the Website or any other part of SimpliTime Services, SimpliTime’s servers may automatically record certain information from your browser by using different types of technology, including standard log files, “clear gifs” or “web beacons.” Such “server logs” may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Website. Additionally, SimpliTime may record certain information regarding your use of features SimpliTime may make available on or through the Website, such as information regarding the services you have used, the business or investment areas of interest to you or you have invested in, the investors or technical experts you have followed on or through the Website, your past activities, projects or proposals, and the like.

Third Party Web Beacons: SimpliTime may also implement third party content, such as textual or graphical links, on the Website that uses “clear gifs,” “web beacons,” or other similar techniques, which allow the third-party content provider to read and write cookies to your browser, or implement similar tracking mechanisms, in connection with your viewing of that third party content displayed on the Website or otherwise made available through SimpliTime Services. This information is collected directly by such third party, and SimpliTime does not participate in that data transmission. Information collected by third parties in this manner is subject to that third party’s

own data collection, use, and disclosure policies and SimpliTime is not responsible for, reviews or controls those policies.

Your communications: When you send email or other communications to SimpliTime, SimpliTime may retain such email or other communications and collect information associated with such email or other communications such as the content, date and time of such messages.

Information from Other Sources: SimpliTime may also obtain your information, including personally identifiable information, from other Users, and third parties and sources other than SimpliTime Services. If SimpliTime combines or associates information from other sources with personally identifiable information that it collects through SimpliTime Services, it will treat the combined information as personally identifiable information in accordance with this Privacy Policy.

The Way SimpliTime Uses Information:

SimpliTime uses the information that you provide or that it collects in order to establish and enhance the services provided to you. SimpliTime generally uses such information to operate, maintain, enhance, and provide all of the features and services found on SimpliTime Services. SimpliTime uses such information to understand and analyze the usage trends and preferences of its Users, both individually and as part of certain categories of Users, in order to engage and provide better service to each such User, to improve the way SimpliTime Services work and look, and to create new features and functionality.

SimpliTime may use the information that you provide or that it collects in order to periodically provide you with email, text, or automated phone call alerts or reminders about new data or content provided through SimpliTime Services. SimpliTime may also use your personally identifiable information to provide you with information, newsletters or offers about SimpliTime’s features and services that may be of interest to you. SimpliTime may also send information or offers to groups of Users on behalf of other Users or third parties. However, you will always have the option to opt out of receiving such information.

SimpliTime may use the email address you provide at registration to provide you with any notices SimpliTime is required to provide you in accordance with SimpliTime’s Terms of Use.

SimpliTime may use “cookies” information to: (a) remember some of your information so that you will not have to re-enter it during your visit or the next time you visit the Website; and (b) monitor aggregate site usage metrics such as total number of visitors and pages viewed or statistical tracking of actions users take when interacting with SimpliTime Services.

SimpliTime’s employees, agents and contractors must have a legitimate business reason to obtain access to the personally identifiable information you may provide to register for an account for SimpliTime Services. We may share your personally identifiable information with third parties that provide services to us, including outside contractors or agents who help us manage our information activities, but they may only use your personally identifiable information to provide us with a specific service and not for any other purpose.

When SimpliTime Discloses Information to Third Parties:

SimpliTime Services enable you to share your User Submissions (as that term is defined in the Terms of Use with other Users. Any personally identifiable information that you choose to include in, or that is associated with, such User Submissions will be accessible by such other Users. Once you make your personally identifiable information available to others in any of these ways, it may be collected and used by the recipients without restriction. Therefore, SimpliTime strongly recommends that you think carefully about what information you transmit or post to or through SimpliTime Services.

SimpliTime may disclose your personally identifiable information to other Users if you direct and authorize SimpliTime to communicate in that manner with such Users on your behalf, for example for the purpose of entering into a transaction related to educational content, etc.

SimpliTime may also disclose your personally identifiable information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright law) or respond to a court order, judicial or other government subpoena, or warrant. In some cases, SimpliTime may make such disclosures without first providing notice to you.

SimpliTime also reserves the right to disclose User information that it believes, in good faith, is appropriate or necessary to take precautions against liability; to protect SimpliTime from fraudulent, abusive, or unlawful uses; to investigate and defend itself against any third party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of SimpliTime Services; or to protect the rights, property, or personal safety of SimpliTime, its Users, or others. In the event that SimpliTime is acquired by or merged with a third-party entity, it reserves the right, in any of these circumstances, to transfer or assign the information that it has collected from its Users as part of such merger, acquisition, sale, or other change of control. However, in such cases, SimpliTime will provide you notice before your personally identifiable information is transferred to and becomes subject to the privacy policy of a different entity. SimpliTime Services may make certain automatically collected information about your interactions and activities on the Website, such as the educational content you have accessed in the past, publicly available on the Website. Any such publicly available information will be accessible by other Users. SimpliTime may disclose automatically collected and other aggregate non-personally-identifiable information to third parties in order to assist such parties in understanding the usage, viewing, and demographic patterns related to certain investment issues, and the content, services, and/or functionality available on or through SimpliTime Services. Your Choices: You may, of course, decline to share any or all of your personally identifiable information with SimpliTime, in which case SimpliTime may not be able to provide to you some of the features and functionality found on or through SimpliTime Services. If you register for an account for SimpliTime Services, you may update, correct, or delete your account information and preferences at any time by going to your account settings page. Most browsers are initially set up to accept cookies, but you can choose to configure your browser to refuse all cookies or to indicate when a cookie is being sent. Links to Other Sites: SimpliTime Services may be linked to internet websites operated by third parties not affiliated with SimpliTime. These third-party websites may use technology to send, directly to your browser, some of the links that appear on the Website. These third parties may automatically receive your IP address if this happens. These third parties may also use other technologies (such as cookies, JavaScript, or Web Beacons) to personalize the content they send to you. You should consult the respective privacy policies of these third-party websites. SimpliTime’s Privacy Policy does not apply to, and SimpliTime cannot control the activities of, such other third-party websites. Please be aware that SimpliTime does not warn you when you have chosen to link through to another website from the Website. Our Commitment to Children’s Privacy: SimpliTime does not knowingly collect personally identifiable information on or through SimpliTime Services from persons under 13 years-of-age without their parent’s or legal guardian’s consent. SimpliTime Services are available only to Users who are at least 18 years old or have their parent’s or legal guardian’s consent to use the SimpliTime Services. If SimpliTime learns that personally identifiable information has been collected from persons under 13 years-of-age through SimpliTime Services without their legal guardian’s consent, then SimpliTime will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with SimpliTime Services or SimpliTime has received any personally identifiable information of that child without your consent, then you may alert SimpliTime at info@simplitime.com and request that SimpliTime delete that child’s personal information and/or account from its systems. Our Commitment to Data Security: SimpliTime uses certain physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. SimpliTime cannot, however, ensure or warrant the security of any information you transmit to SimpliTime, and you do so at your own risk. Once SimpliTime receives any information from you, it makes commercially reasonable efforts to ensure the security of its systems. However, this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of SimpliTime’s physical, technical, or managerial safeguards. If SimpliTime learns of a security systems breach, then it may attempt to notify you electronically so that you can take appropriate protective steps. SimpliTime may post a notice on or through SimpliTime Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. International Visitors: SimpliTime Services may be accessed and/or used by Users located outside the United States. If you choose to use SimpliTime Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personally identifiable information outside of those regions to the United States and by providing your personally identifiable information on or through the Service you consent to that transfer. Changes and Updates to this Privacy Policy: This Privacy Policy may be revised periodically without further notice to you and this will be reflected by a “Last modified” date above. Please revisit this page to stay aware of any changes. Your continued use of SimpliTime Services constitutes your agreement to this Privacy Policy and any future revisions.

Contact Information:

Please contact SimpliTime with any questions or comments about this Privacy Policy, your personal information, or your consent choices by email at: info@simplitime.com or by mail at: Attn: SimpliTime, Inc., 54 Coppergate Ln, Warwick, NY 10990