FLUEID PRIVACY NOTICE

Effective April 30, 2025

Flueid Software Corporation (“Flueid” or “we”) respects and is committed to protecting your privacy. This Privacy Notice explains how we collect, use, store, share and protect personal information, when (1) you access or use our websites, mobile applications, web-based applications, or other digital platforms where this Notice is posted ("Sites"); (2) when you use our products and services ("Services"); (3) you communicate with us in any manner, including by e-mail, in-person, telephone, or other communication method ("Communications"); (4) we obtain your information from third parties, including service providers and business partners ("Third Parties"); and (5) you interact with us to conduct business dealings, such as the personal information we obtain from business partners and service providers and contractors who provide us certain business services ("B2B"). Personal information is sometimes also referred to as personal data, personally identifiable information or other like terms to mean any information that directly or indirectly identifies you or is reasonably capable of being associated with you or your household. However, certain types of information are not personal information and thus, not within the scope of our Notice, such as: (1) publicly available information; and (2) de-identified and aggregated data that is not capable of identifying you. If we use de-identified or aggregated data, we commit to maintain and use the information in a non-identifiable form and not attempt to reidentify the information, unless required or permitted by law.

Types of Information Collected

Depending upon how you interact with our Sites and Services, the nature of your Communications, and the nature of our interaction with Third Parties, we may collect the following information from and about you:

Personal Information

Flueid may collect the following categories of personal information:

• contact information ( e.g., name, address, phone number, email address);
• demographic information ( e.g., date of birth, gender, marital status);
• identity information ( e.g. Social Security Number, driver’s license, passport, or other government ID number);
• financial account information ( e.g. loan or bank account information);
• physical traits, including protected characteristics (e.g. age, sex, race and ethnicity);
• commercial information (e.g. records of products or services purchased, obtained or considered);
• Internet or other electronic network activity with our Sites and Services (e.g. browser systems, device type, and operating information);
• professional or employment-related information (e.g. work history and education history);
• biometric information, such as fingerprints;
• geolocation data, such as current location, zip code and/or time zone.

We may collect Personal Information about you in three ways:

Directly

Based on your access or use of our Sites and Services, which may include, without limitation:

• applications or other forms completed through our Sites which contain your personal information;
• personal information you provide when you access or use our Sites and Services;
• personal information you provide when you conduct B2B dealings with us; and
• details of your transactions through our Sites.

Automated

Based on your access or use of our Sites and Services, which may include, without limitation:

• Internet Protocol (IP) address and operating system;
• browser version, language, and type;
• domain name system requests; and
• browsing history on the Site, such as date and time of your visit, and visits to the pages within the Site.

From Third Parties

Which may include, without limitation:

• data analytics providers for the purpose of receiving statistical data about your activity on our Sites;
• information we receive from consumer reporting agencies and/or governmental entities, either directly from these entities or through others; and
• information we receive from other sources, as permitted by applicable laws, rules, and regulations.

Use of Personal Information

Flueid uses personal information for the following purposes:

• To provide the Sites and Services to you;
• Conduct business transactions with you;
• Operate the Site (e.g. payment process, Site administration, data analysis and statistical analysis);
• To analyze Site usage and improve our products and services;
• To communicate with you about our, our affiliates’, and others’ products and services, jointly or independently.

When Information Is Disclosed

We may disclose your personal information in the following circumstances:

• with your consent, which may be procured in writing or orally, and online via “click through agreements” or through acceptance of Flueid’s Terms of Use by use of our Sites;
• through business transactions (e.g. mergers, corporate reorganizations, financing, sale of assets and bankruptcy);
• to enable us to detect or prevent criminal activity, fraud, material misrepresentation, or nondisclosure;
• to nonaffiliated service providers who provide or perform services or functions on our behalf and who agree to use the information only to provide such services or functions;
• to nonaffiliated third-party service providers with whom we perform joint marketing, pursuant to an agreement with them to jointly market financial products or services to you;
• to law enforcement or authorities in connection with an investigation, or in response to a subpoena or court order; or
• in the good-faith belief that such disclosure is necessary to comply with legal process or applicable laws, or to protect the rights, property, or safety of Flueid, its customers, or the public.

The law does not require your prior authorization and does not allow you to restrict the disclosures described above. Additionally, we may disclose your information to third parties for whom you have given us authorization or consent to make such disclosure. We do not otherwise share your personal information with nonaffiliated third parties, except as required or permitted by law. We do share personal information among affiliates (other companies owned by Flueid) to directly market to you. Please see “Choices with Your Information” to learn how to restrict that sharing.

By submitting personal information to Flueid, you expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the above described proceedings.

Cookies and Related Technology

We may use browser cookies, beacons, pixel tags, scripts, and other similar technologies from time to time to support the functionality of our Sites and Services. A cookie is a piece of information contained in a very small text file that is stored in your Internet browser or elsewhere on your hard drive. Cookies are transferred from our Sites to your computer, phone or tablet, and allow us to identify your device whenever you return to our Sites. These technologies provide a better experience when you use our Sites and Services, and allow us to improve our services. We may also use analytic software, such as Google Analytics and others, to help better understand how our Sites function on your device(s) and for other analytical purposes. To learn more about how Google uses data when you use our Sites, see How Google uses data when you use our partners' sites or apps. You can opt-out of Google Analytics by installing Google's opt-out browser add-on here https://tools.google.com/dlpage/gaoptout.

Below is an overview of the types of cookies and related technology we deploy, and your choices.

Browser Cookies

A browser cookie is a small file placed on the hard drive of your computer. That cookie then communicates with servers, ours or those of other companies that we authorize to collect data for us and allows recognition of your personal computer. You may use the tools available on your computer or other device(s) to set your browser to refuse or disable all or some browser cookies, or to alert you when cookies are being set. However, if you refuse or disable all browser cookies, you may be unable to access certain parts or use certain features or functionality of our Sites. Unless you have adjusted your browser settings so that it refuses all cookies, we may use cookies when you direct your browser to our Sites.

Beacons

Our Sites and e-mails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us to, for example, to count users who have visited those pages or opened an e-mail and for other website-related statistics. Beacons in e-mail marketing campaigns allow us to track your responses and your interests in our content, offerings and web pages. You may use the tools in your device to disable these technologies as well.

Third Party Technology

Our service providers, advertising partners, and ad networks may also use cookies and beacons to collect and share information about your activities both on our Sites and on other websites and applications. In addition, third parties that are unaffiliated with us may also collect information about you, including tracking your browsing history, when you use our Sites. We do not have control over these third-party collection practices. If you wish to minimize these third-party collections, you can adjust the settings of your browsers or install plug-ins and add-ins.

Your Choices

You may wish to restrict the use of cookies or completely prevent them from being set. Most browsers provide for ways to control cookie behavior, such as the length of time they are stored. If you disable cookies, please be aware that some of the features of our Sites may not function correctly. To find out more on how to manage and delete cookies, visit www.aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising, you may visit the following sites:

• http://networkadvertising.org
• http://optout.aboutads.info
• http://youradchoices.com

Security of Your Information

We maintain physical, electronic, and procedural safeguards to protect your personal information.

When we provide personal information to our affiliates or third-party service providers as discussed in this Privacy Notice, we require that these parties agree to process such information in compliance with our Privacy Notice or in a manner that complies with applicable privacy laws. The use of your information by a trusted business partner may be subject to that party’s own Privacy Notice. Unless permitted by law, we do not disclose information we collect from consumer or credit reporting agencies with our affiliates or others without your consent.

In addition to the other rights herein, we have the right to share and use, for any purpose, the collected Personal Information that is in an aggregated, anonymized form, such that you are not identified (collectively, “De-identified Data”).

We reserve the right to transfer your personal information and any other information, in connection with the sale or other disposition of all or part of the Flueid business and/or assets, or in the event of our bankruptcy, reorganization, insolvency, receivership or an assignment for the benefit of creditors. You expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the above described proceedings. We cannot and will not be responsible for any breach of security by any third party or for any actions of any third party that receives any of the information that is disclosed to us.

We may disclose your personal information for any purpose disclosed by us when you provide the information. We may also disclose your personal information with your permission or as directed by you.

Choices With Your Information

If you do not want Flueid to share your information among our affiliates to directly market to you, you may send an “opt out” request by email, phone, or physical mail as directed at the end of this Privacy Notice. We do not share your personal information with nonaffiliates for their use to direct market to you.

Whether you submit personal information to Flueid is entirely up to you. If you decide not to submit personal information, Flueid may not be able to provide certain services or products to you.

For California Residents: We will not share your personal information with nonaffiliated third parties, except as permitted by California law. For additional information about your California privacy rights see the additional “California Residents” section below.

For Nevada Residents: You may be placed on our internal Do Not Call List by calling (888) 934-3354 or by contacting us via the information set forth at the end of this Privacy Notice. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: (702) 486-3132; email: BCPINFO@ag.state.nv.us.

For Oregon Residents: We will not share your Personal Information with nonaffiliated third parties for marketing purposes, except after you have been informed by us of such sharing and had an opportunity to indicate that you do not want a disclosure made for marketing purposes.

For Vermont Residents:

We will not disclose information about your creditworthiness to our affiliates and will not disclose your Personal Information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.

Information From Children

The Flueid Website is not intended or designed to attract persons under the age of eighteen (18). We do not collect Personal Information from any person that we know to be under the age of thirteen (13) without permission from a parent or guardian.

International Users

Flueid’s headquarters is located within the United States. If you reside outside the United States and choose to provide Personal Information to us, please note that we may transfer that information outside of your country of residence. By providing Flueid with your Personal Information, you consent to our collection, transfer, and use of such information in accordance with this Privacy Notice.

Your Consent To This Privacy Notice; Notice Changes; Use of Comments or Feedback

By submitting Personal Information to Flueid, you consent to the collection and use of the information in accordance with this Privacy Notice. We may change this Privacy Notice at any time. The Privacy Notice’s effective date will show the last date changes were made. If you provide information to us following any change of the Privacy Notice, that signifies your assent to and acceptance of the changes to the Privacy Notice. We may use comments or feedback that you submit to us in any manner without notice or compensation to you.

Accessing and Correcting Information; Contact Us

If you have questions, would like to correct your Personal Information, or want to opt-out of information sharing for affiliate marketing, send your requests to privacy@flueid.com, or by phone to (888) 834-8434, or by mail to:

Flueid Software Corporation
11801 Domain Blvd 3rd Floor
Austin, TX 78758
Attn: General Counsel

California Residents

If you are a California resident, you may have certain rights under California law, including but not limited to the California Consumer Privacy Act of 2018 (“CCPA”). All phrases used in this section shall have the same meaning as those phrases are used under California law, including the CCPA. Please also note that nothing in this disclosure should be construed to concede that Flueid or any of its affiliates is a “business” as that term is defined under the California Consumer Protection Act (the “CCPA”).

Right to Know

You have a right to request that we disclose the following information to you: (1) the categories of Personal Information we have collected about or from you; (2) the categories of sources from which the Personal Information was collected; (3) the business or commercial purpose for such collection and/or disclosure of your Personal Information; (4) the categories of third parties with whom we have shared your Personal Information; and (5) the specific pieces of your Personal Information we have collected. To submit a verified request for this information, you may submit your request to privacy@flueid.com or call (888) 834-8434. You may also designate an authorized agent to submit a request on your behalf, which requires submission of written proof of such authorization to privacy@flueid.com.

Right of Deletion

You also have a right to request that we delete the Personal Information we have collected from you. This right is subject to certain exceptions available under the CCPA and other applicable law. To submit a verified request for deletion you may submit your request to privacy@flueid.com or call (888) 834-8434. You may also designate an authorized agent to submit a request on your behalf, which requires submission of written proof of such authorization to privacy@flueid.com.

Verification Process

For either a request to know or delete, we will verify your identity before responding to your request. To verify your identity, we will generally match the identifying information provided in your request with the information we have on file about you. Depending on the sensitivity of the Personal Information requested, we may also utilize more stringent verification methods to verify your identity, including but not limited to requesting additional information from you and/or requiring you to sign a declaration under penalty of perjury.

Right to Opt-Out

We do not sell your Personal Information to third parties, and do not plan to do so in the future.

Right of Non-Discrimination

You have a right to exercise your rights under California law, including under the CCPA, without suffering discrimination. Accordingly, Flueid will not discriminate against you in any away if you choose to exercise your rights under the CCPA.

Collection Notice

The following is a list of the categories of Personal Information we may have collected about California residents in the 12 months preceding the date this Privacy Notice was last updated, including the business or commercial purpose for said collection, the categories of sources from which we may have collected the Personal Information, and the categories of third parties with whom we may have shared the Personal Information:

Categories of Personal Information Collected

The categories of Personal Information we may have collected include, but may not be limited to: real name; signature; alias; SSN; physical characteristics or description, including protected characteristics under federal or state law; address; telephone number; passport number; driver’s license number; state identification card number; IP address; policy number; file number; employment history; bank account number; credit card number; debit card number; financial account numbers; commercial information; internet or other electronic network activity; geolocation data; audio and visual information; professional or employment information; and inferences drawn from the above categories to create a profile about a consumer.

Please note that because the above list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of Personal Information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the “Contact” section above.

Categories of Sources

Categories of sources from which we may have collected Personal Information include, but may not be limited to: the consumer directly; public records; governmental entities; non-affiliated third parties; social media networks; affiliated third parties.

Business Purpose for Collection

The business purposes for which we may have collected Personal Information include, but may not be limited to: completing a transaction for our Products; verifying eligibility for employment; facilitating employment; performing services on behalf of affiliated and non-affiliated third parties; debugging to identify and repair errors that impair existing intended functionality on our Websites, applications, or products; protecting against malicious, deceptive, fraudulent, or illegal activity.

Categories of Third Parties Shared

The categories of third parties with whom we may have shared Personal Information include, but may not be limited to: advertising networks; internet service providers; data analytics providers; service providers; government entities; operating systems and platforms; social media networks; non-affiliated third parties; affiliated third parties.

Categories of Personal Information We Have Sold In The Past Year

We have not sold any Personal Information of California residents to any third party in the 12 months preceding the date this Privacy Notice was last updated.

Categories of Personal Information Disclosed For A Business Purpose In The Past Year

The following is a list of the categories of Personal Information of California residents we may have disclosed for a business purpose in the 12 months preceding the date this Privacy Notice was last updated: The categories of Personal Information we have collected include, but may not be limited to: real name; signature; alias; SSN; physical characteristics or description, including protected characteristics under federal or state law; address; telephone number; passport number; driver’s license number; state identification card number; IP address; policy number; file number; employment history; bank account number; credit card number; debit card number; financial account numbers; commercial information; internet or other electronic network activity; geolocation data; audio and visual information; professional or employment information; and inferences drawn from the above categories to create a profile about a consumer.

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