Effective on May 25, 2018

Motleysoft’s Commitment to Privacy

MotleySoft.com, a service of MediaPro di Iounok Guennadi (“MotleySoft“) take the privacy and protection of personal information (“Personal Information”) very seriously. By visiting and using the MotleySoft website located at www.MotleySoft.com (“Website”), you acknowledge that you accept the practices and policies outlined in this Privacy Policy (“Privacy Policy”).

We are committed to earning and keeping your trust, while giving you control over the information that is personal to you. Being accountable to you is our responsibility for which we hope to build a lasting relationship. Our commitment to privacy, including processing and protecting personal data, is demonstrated in this privacy policy (“Privacy Policy”).

Key Terms

The following key terms shall be used in this Privacy Policy:

• Information that can no longer be used to identify a particular person (“Anonymous Information”).

• Independent data controller has the same meaning as “controller” under Directive 95/46/EC as of October 24, 1995 or any subsequent data protection legislation such as Regulation (EU) 2016/679 as of May 25, 2018, and is the natural person or legal entity, which alone or jointly with others, carries out processing of personal data (as defined below) as well as determines the purpose and means of the processing of personal data, composition and kinds of personal data to be processed, and determines actions (operations) with the personal data (“Data Controller” or “Controller”).

• Data where certain identifiers are removed to prevent a person’s identity from being directly connected with the information (such as masking certain personal identifiers) (“De-identified Data”).

• Processing is permitted if it is necessary for the purposes of legitimate interests pursued by the Controller (or by a third party), except where the Controllers’ interests are overridden by the interests, fundamental rights or freedoms of the affected end-users which require protection (“Legitimate Interests”).

• Information that can be used to identify you, either alone or in combination with other information available to us, such as your name, shipping and billing address, e-mail address, phone number, identification number (where applicable), date of birth (where applicable), time and location data, bank account information, transaction and payment records, delivery records and other information associated with your account, which is collected by us during delivery of our commerce solution (“Personal Data”).

• Motleysoft may resell products through transactions via its commerce solution, and will generally be the seller and merchant of record for such transactions (“Seller and Merchant of Record”).

• Any applicable data protection safeguards, as may be amended or replaced, for the transfers of data to Controllers established outside of the EU/EEA that do not ensure an adequate level of protection (“Standard Contractual Clauses”).

• Supervisory Authority (or its equivalent under any data protection legislation) is the independent public authority to whom consumers may lodge a complaint (“Supervisory Authority”).

Data Controller, How to Contact Us, and Processing of Your Data

• MediaPro di Iounok Guennadi is the “data controller” of all personal information that is collected and used, is registered in Italy with p.iva 09509960010 and registered office at Via Boston,96 – 10137 Torino.

• How to Contact Us. If you have a question about this Privacy Policy or requests related to your Personal Data pursuant to applicable laws, no matter where you are in the world, please email us at info@motleysoft.com, and we will route your question appropriately. If you prefer to contact us by regular mail, please refer to the contact information as found on the “Contact Us” section of our Website.

• Processing of Your Data. Your commerce request, and therefore your Personal Data, will take place in Italy.

• Appropriate Safeguards for Cross-border Transfer of Your Data. If you are located in the EU/EEA, any transfer of your Personal Data outside of the EU/EEA is protected under Standard Contractual Clauses, or any subsequent data protection safeguards.

Lawful Basis for Processing of Data

In certain jurisdictions, the processing of your Personal Data is lawful only if it is permitted under data protection legislation. In this case, we have a lawful basis for each of our processing activities (unless an exemption applies) as outlined below:

• Consent. By using our Website or otherwise submitting your Personal Data to us, you consent to our collection, use and sharing of your information as described in this Privacy Policy. If you do not consent to this Privacy Policy, please do not use this Website or submit your information through this Website.
• Legitimate Interest. We will process your data based on Legitimate Interest, and particularly where it is used for marketing purposes, such as to collect data from public sources and to contact prospects to start a conversation. We may also process your data based on Legitimate Interest in the employment context.
• Other Lawful Basis. We may also process your data based on another lawful basis such as where the processing is necessary to enter into or perform a contract with you.

Scope of this Privacy Policy

Background and Purpose

This Privacy Policy applies to each Website operated by Motleysoft where this Privacy Policy appears. The purpose of this Privacy Policy is to provide you with information on how we:

• collect Personal Data and other information when you use this Website;
• use, handle and disclose collected information; and
• choices you have about the ways we collect and use the information.

Changes to this Privacy Policy

We may update this Privacy Policy to communicate changes in our data handling practices. When we make changes to this Privacy Policy, we will modify the Effective Date. Our changes will become effective immediately upon posting.

Supplemental Privacy Notices

This Privacy Policy may be supplemented or amended by other privacy notices appearing on the Website. Such privacy notices will explain how we handle information specific to where that privacy notice appears, and should be read together with this Privacy Policy.

How We Protect Your Information

Motleysoft takes reasonable steps to provide a level of security appropriate to the sensitivity of the information we collect. We have implemented physical, technical and administrative security practices and safeguards reasonably designed to protect your Personal Data from unauthorized access and disclosure. When we collect or transmit sensitive information we use industry standard methods to protect that information as required by applicable laws. Although we use reasonable measures to protect your information, we cannot guarantee the security of information provided over the Internet or stored in our databases. You are also responsible for taking reasonable steps to protect your information against unauthorized disclosure or misuse, for example, by protecting your password and signing off when finished using a shared computer or mobile device. We leverage industry best practices to mitigate potential compromises. If the Personal Data under the custody of Motleysoft is (or is likely to be) divulged, damaged or lost, we will immediately take remedial measures, inform the users in a timely manner and report to the competent government agencies as required by applicable laws.

Collection of Information, including Use of Cookies

Information You Manually Provide

We collect Personal Data from you when you use this Website such as:

• when you provide information during a purchase of a product,
• when you request information about or otherwise use the Website,
• when you enter into a contest or promotion, sign-up for a newsletter or related services,
• when you submit an order or purchase, download or register products, or request additional services,
• when you call our customer service, you may voluntarily provide information to our representatives.

Special Categories of Data

Generally, Special Categories of Data will not be collected or processed.

Information from Your Browser or Device

We may also receive information from your web browser. This may include information that does not identify you personally (such as the date and time of your visit). The information we receive depends on the settings on your web browser. If you created a user identity during a visit to this Website, this shall be regarded as giving your consent for processing your Personal Data, if any, and we may link the information provided by your browser to information that identifies you personally, as described below. Please review the settings on your web browser to learn how to change your browser settings. We may also collect limited Personal Data (e-mail address) through web technologies in connection with your use of a Website, as described below.

Cookies and Other Similar Technologies

The information we collect using cookies and similar technologies is not typically personally identifiable, but we may link it to Personal Data that you provide. We use cookies and other similar technologies to collect information and support certain features of this Website. As the Internet evolves, we may use different types of technologies for this purpose. For example, we may use these technologies to collect information about the ways visitors use this Website (such as which pages they visit, links they use). We analyze this information to better understand our visitors’ interests, needs and to improve the content and functionality of the Website. We also use the information to support Website features by not asking you to re-enter information already in our database. We also use this information to personalize your experience when you use the Website and to improve our marketing efforts, including through use of targeted advertising.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies, you may be unable to use all of the Website functionality if your browser rejects our cookies.

Information about Third-Party Cookies and Other Technologies

We do not use third party service providers in connection with this Website (like Alexa Metrics, Google Analytics etc.).

Location Information

When you use a smart phone, mobile device or computer to access our Website, we will not collect information about your physical location.

Use and Sharing of Information

Your Personal Data provided will be processed on our computer servers. In some cases (such as where it is necessary to fulfill our contractual obligations to you) the information may also be made available to third parties providing services to Motleysoft.

How We Use Your Data

We may use your Personal Data for the following purposes:

• to contact you if you have requested communication from us,
• to determine the country where you are located such as for trade compliance, security and fraud prevention,
• to otherwise verify compliance with applicable laws,
• to help verify that data we have about you is accurate,
• to provide you with product updates, special offers and other promotional information, where you have consented to receive it and in accordance with applicable law,
• in connection with keys, access codes or other information so you can access the websites to receive products or services,
• as identified in a supplemental privacy notice posted on the Website.

We may also use your Personal Data for the following purposes where you visit the Website to complete a transaction:

• to process your order, process payment, verify your tax status, contest chargebacks, or notify you of the status of your order,
• for fraud monitoring and prevention purposes,
• to provide you with a personalized shopping experience,
• to register your purchase with the manufacturer or service provider for warranty, technical support or similar purposes,
• to provide notice of your purchase to the provider of an online service for which you purchase a service use right from us,
• to establish an account for future purchases that you have consented to,
• to facilitate the renewal of subscriptions for products or services, and
• to provide you with an effective experience and support (which may, as allowable by law, include contacting visitors who start a checkout process to follow-up on the incomplete session or to see if there was a problem with their use of the Website).

We will take reasonable steps to ensure any person or entity receiving Personal Data for the purposes described above, are obligated to keep the Personal Data secure. If any Special Categories of Data are being collected, received or retained by an external entity, details of such entity will be shared with you if required by applicable law. Our obligations will not, apply to information shared with any Government entity mandated under law to obtain such information or by an order under law for the time being in force.

Automated Processing

In limited situations, we may use your Personal Data to help us make automated decisions to further improve our business. Also, we rely on fraud monitoring to help us reduce the need to manually review orders for fraud. You have the right to avoid any decisions based on automated data processing where they can be characterized as profiling. However, in this case, we reserve the right not to complete your transaction.

Our Use of Anonymous Information

We may use Anonymous Information collected by us. In this case, the following data elements will be anonymized such as first and last name, street address, phone number, email address and other data elements in accordance with applicable law. The Anonymous Information may be used as described here:

• to personalize and support your use of this Website,
• to improve this Website, the customer experience, our advertising systems, and our products and services,
• for fraud prevention purposes,
• for other historical, statistical, research and analysis purposes.

We may also use De-identified Data for the purposes mentioned above, and related purposes as allowed by applicable law.

Our Partners

We will provide certain Personal Data, Anonymous Information or De-identified Data to our Partners to fulfill our obligations to you, and otherwise assist Motleysoft’s use of Personal Data as described in the “How We Use Your Data” section:

• for reporting purposes,
• to allow our Partner or its service provider to register your purchase,
• to facilitate warranty, technical support or after-sales service,
• to allow our Partner or subcontractor to send email or direct mail communications if you have consented to receive them,
• to allow our Partner or its service provider to provide services in connection with this Website (such as customer support or single sign-on functionality), or
• for similar purposes in order to fulfill obligations to you.

Our Service Providers

We utilize other companies to provide certain services to us or on our behalf to help us operate our business such as:

• to host or maintain this Website,
• to process credit card payments,
• to provide fraud monitoring or detection services,
• to perform data integrity checks,
• to offer you a line of credit,
• to provide optimization services,
• to fulfill your order,
• for payment collection,
• to send mail or e-mail,
• to provide customer service.

We will not share your Personal Data with our service providers in connection with their offering of services to us, unless it is required for the purposes of our Legitimate Interests and purposes of fulfilling our obligations as to delivery of our commerce solution to you. These service providers may be contractually required to use any information we share with them only to perform services to us or on our behalf and to protect the confidentiality of your Personal Data. We may also allow these companies to use Anonymous Information for their business purposes.

To Comply With Legal Requirements, Prevent Fraud and Crimes

As permitted by applicable law, we may disclose Personal Data or Special Categories of Data about you when we believe disclosure is appropriate to:

• comply with the law or a regulatory requirement,
• to comply with governmental, administrative or judicial process, requirement or order (such as a court order),
• to cooperate with law enforcement or other governmental investigations or report any activities that may be in violation of legal or regulatory requirements,
• to prevent or investigate a possible crime (such as fraud or identity theft) or breaches (also suspected breaches) of security or of this Privacy Policy,
• to enforce a contract,
• to protect the legal rights, Website or safety of Motleysoft and our employees, Partners, third parties, the public in general or you.

In Connection with a Sale, Merger or related Event

If one of our corporate affiliates or a third party has acquired our business, specific assets or the business of one of our operating divisions (such as part of a sale, merger, reorganization, or similar event), your Personal Data will become owned by that company, unless otherwise provided for by the local legislation. In that event, the acquiring company’s use of your Personal Data will be subject to the governing Privacy Policy, any applicable supplemental privacy notices, and the privacy preferences you have expressed to the governing entity.

Your Choices

We respect your right to make choices about the ways we collect, use and share your Personal Data.

Access to Your Information

If you would like to review, correct, restrict the processing thereof, object to direct marketing, or request erasure of your Personal Data or Special Categories of Data, please send us a request using the information in the “How to Contact Us” section of this Privacy Policy. For example, if there is any error in the Personal Data that you have submitted to us, please contact us and we will take appropriate measures to correct the error.

If you contact us we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements as noted in our data retention policy. When we delete your Personal Data or Special Categories of Data, it will be disposed of in a manner that prevents loss, theft, misuse, or unauthorized access in-line with our data retention policy.

You have the right to report to your local Supervisory Authority where you feel as though your rights under data protection legislation have not been appropriately considered. However, before doing so, please contact us directly as we are committed to working with you to help resolve any concerns about your privacy.

Data Retention Policy

Motleysoft may retain your Personal Data for as long as you continue to use our Website, and thereafter as permitted or required by applicable law or to satisfy our business requirements.

Children’s Privacy

This Website is not directed at nor targeted to children. The Website is available only to individuals who are at least 16 years old. If you have not reached the age of majority or are not able to enter into legally binding agreements in your country, you may not use this Website unless necessary parental consent has been obtained. If you believe that we have received information from a person protected under child protection laws where necessary parental consent was not obtained, please notify us immediately, and we will take reasonable steps to securely remove that information.

Joint Use per Data Protection Legislation

In certain jurisdictions (such as under Japanese data protection legislation), the details of the transmission of your Personal Data to other Motleysoft entities must be included. Therefore, the following categories of Personal Data could be jointly used with certain Motleysoft entities:

• Consumer data (such as name, shipping and billing address, e-mail address, phone number, transaction and payment records, delivery records and other information associated with a consumer’s account), which is collected by us during delivery of our commerce solution;
• Other data which is collected by us when an individual visits our Website or otherwise utilizes our services.

The Joint Users will use the Personal Data for the purposes set forth in "How We Use Your Data" section above. Motleysoft are currently responsible for management of Personal Data subject to the joint use.