SENTINEL PRIVACY POLICY

INFORMATION WE COLLECT

1. Personal Information: Information about a person or household that identifies, relates to, describes, is reasonably capable of being associated with, could be reasonably linked with, or could be used to directly or indirectly identify that person or household (or from those and other information either in our possession or likely to come into our possession). It may also include other information that may be associated with Personal Information, such as Generic Information and Commercial Information (defined below) if that information can be used to identify a person, household, or device.
2. Commercial Information: In some cases, the Services are provided to business entities to help them meet their business needs. As such, we collect information from our commercial clients related to their business, employees, clients, and their purchase of our Services. This information may include their business’ name, address, telephone number, email address, employees and clients’ names and contact information, payment information to facilitate transactions with us, and other information related to their business.
3. Usage and Technical Information: The Services include features that gather information about how users use it. We use this information to compile statistical and performance information related to the Services. This information is typically aggregate and/or deidentified data. In some situations, Usage and Technical Information may be combined with other information in a way that identifies a person. In those situations, Usage and Technical Information will be treated like Personal Information.
4. Personal Information Collected Over the Last 12 Months: The following section describes the categories of Personal Information we may have collected in the preceding twelve months through use of the Services, the categories of sources from which that information may have been collected, the categories of third parties with whom that information may have been shared, and the commercial purpose for collecting that information.

Category of Information	Examples of Information	Sources of Information	Purpose for Collecting the Information	Categories of Recipients
Identifying Information	Real name, alias, signature, email address, phone number, or other identifiers	You, our clients	To provide our Services to our clients and to your clients, verify your identity, maintain our security, and comply with our legal obligations	Our clients, our Service Providers, and government entities (where required by law)
Commercial Information	Real name, email address, records of Services purchased, obtained, or considered	You, your clients, our Service Providers	To provide our Services to our clients and to your clients, maintain our security, and comply with our legal obligations	Our Service Providers and government entities (where required by law)
Usage and Technical Information	Information about your interaction with our Services (e.g. IP address; device information)	You, our Service Providers, other third parties	To operate, maintain, provide, and improve our Services; to detect security incidents; detect, prevent, and address technical issues; secure our network and other devices; and protect our network, property, and personnel	Our Service Providers, marketers, and government entities (where required by law)

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HOW WE COLLECT YOUR INFORMATION

StoneAge collects information in a few ways: you voluntarily provide it to us, we obtain it through the provision of the Services, and we obtain it through third parties.

1. Information You Give Us. We collect information that you decide to share with us. At times, we may require you to provide certain information, including Personal Information, in order to provide you with Services you request. For instance, we may require you to provide your name, email address, or other contact information when you set up an account for the Services. In some circumstances, we will not be able to further our relationship with you (for example, to provide you with our Services if you are a client) without certain Personal Information. We will inform you at the relevant time if this is the case.
2. Information We Obtain through the Use of Our Services. We collect certain information from you through your use of our Services, such as records of the Services we have provided to you. We may also collect information about you from our clients’ use of our Services.
3. Information We Obtain from Third Parties. We may also obtain information about you from third parties, such as our clients who may have an employment relationship with you, or those that help us provide our Services to you.

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HOW WE USE YOUR INFORMATION

We generally use your information for the following business and commercial purposes:

• To provide our Services, including to answer any questions or inquiries you make to us, perform a contract with our clients or Service Providers, and provide customer support to you.
• With your consent, in accordance with that consent. For example, if you request customer support, we will use the information you provide to evaluate your specific request and contact you.
• To comply with applicable laws, in response to a lawful and enforceable request by a law enforcement, judicial, or other public authority, or in connection with an applicable legal obligation.
• For another StoneAge business or commercial purpose. For instance, we may use your information to assist with fraud prevention, report suspected criminal activity to law enforcement, and to help prosecute individuals responsible for malicious, deceptive, fraudulent, or illegal activity.

How We May Share Information We Collect. StoneAge may share your information, including Personal Information, with a variety of parties depending on the purpose for and context in which you provided the information. We generally share the information with the following types of recipients:

• Service Providers: We employ third-party Service Providers, companies, individuals, and agents to facilitate and help us provide our Services to you (“Service Providers”). Such Service Providers perform tasks or functions on our behalf, provide Services-related services, or assist us in analyzing how our Services are used or delivered. For instance, we may disclose information to our database and cloud storage providers that help us maintain the Services.
  
  The Services Providers we share your Personal Information with in the provision of the Services are: Amazon Web Services and MongoDB, Inc.
  
  These third parties are granted access to your information only to perform specific tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Corporate Transitions: Your Personal Information may be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Information may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
• Legal Disclosures: In limited circumstances, we may, without notice or your consent, disclose your Personal Information, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, or to protect the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Information as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Information to such parties.

Personal Information Shared Over the Last 12 Months The following section lists the categories of Personal Information StoneAge may have disclosed and the categories of recipients of such information in the preceding twelve months:

Category of Information	Categories of Recipients
Identifying Information	Our clients, our Service Providers, and government entities (where required by law)
Commercial Information	Our clients, our Service Providers, and government entities (where required by law)
Usage and Technical Information	Our Service Providers, and government entities (where required by law)

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DATA RETENTION

StoneAge will retain your Personal Information only for as long as is necessary to accomplish the purposes set out in this Privacy Policy. We will retain and use your Personal Information to provide our clients with Services, to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, and as required by essential, internal business needs.StoneAge is a global corporation with operations in several countries. We have developed global data practices designed to assure Personal Information is appropriately protected. While our primary data centers are in the USA, UK, and the Netherlands, we may transfer Personal Information to StoneAge offices or representatives outside of our primary data centers. In addition, we may employ other companies and individuals to perform functions on our behalf. If we disclose Personal Information to a third party or to StoneAge employees outside of the USA, UK, and the Netherlands, we will ensure that such party has agreed to abide by the principles of this policy, or can otherwise assure adequate protection of such Personal Information.

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DATA TRANSFER

StoneAge operates in and uses Service Providers located in the United States. If you are located outside of the United States, your information, including Personal Information, may be transferred to the United States. The United States does not provide the same legal protections as other countries and territories.

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INDIVIDUALS FROM THE EUROPEAN UNION

Controller: StoneAge Inc., a Colorado corporation, is the data controller for Personal Information collected under this Privacy Policy. In certain cases, we may partner with certain entities to facilitate the provision of our Services, and in those cases, our partner may become a joint controller with respect to the Personal Information we provide it.

Legal Bases for Processing: We process your Personal Information for one or more of the following general permitted purposes in accordance with the corresponding legal basis.

Legal Basis	Permitted Purpose
Where it is necessary to perform our contract with you or to take steps at your request to enter into the contract	For example: to perform our Services if you are a client.
Where it is necessary for compliance with a legal obligation	For example: to protect our and our clients’ Personal Information, and other information, property, and assets, to cooperate with our regulators and other public authorities (including by responding to their requests for information, undertaking internal investigations, and complying with our reporting and other professional obligations), and to comply with any other obligation to which we are subject under applicable rules and law.
Where it is necessary for the purposes of our or another party’s legitimate interests, except where these are overridden by your interests, rights or freedoms	For example: to ensure compliance with our internal policies; for general security and business continuity purposes; for business management and financial planning (including management of suppliers, business process improvement and quality purposes, management reporting and reviewing records, accounting and auditing, and corporate due diligence); for managing insurances, complaints, and potential and actual claims; to ensure the effective provision of Services to clients and enhance our international business and cross-border offerings; for training and continuing professional development purposes; to organize corporate events and to carry out market research campaigns; to protect, manage, and improve our Services and other services StoneAge offers; and for any other legitimate purpose communicated to you at the time of collection of your Personal Information. We consider that our legitimate interests and these uses are proportionate, and compatible with your interests, legal rights or freedoms. Details of the balancing test undertaken in respect of such collection and use is available upon request.
Where you provide consent	For example: To respond to your inquiries and requests for information about StoneAge and our Services, to the extent applicable laws in certain jurisdictions require your consent for advertising, marketing, and public relations purposes, and where you otherwise provide us with your consent. Please note that you may withdraw your consent to processing Personal Information at any time through the contact procedures provided below.

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CHILDREN’S PRIVACY

The Services are intended for adult users, and are not meant to be used by anyone under the age of 18 (“Children”). As such, Children may not use our Services. If you are under 18, do not attempt to use any of our Services, and do not provide us any Personal Information about yourself.

We do not knowingly collect or sell the Personal Information of Children. If you are a parent or guardian and you are aware that your child has violated this Privacy Policy and provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Children without verification of parental consent, we will take steps to remove that information from our systems.

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CONTACT US

If you have questions about this Privacy Policy or our practices related to the collection and use of Personal Information, please contact StoneAge at [email protected]. With a copy to [email protected].

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SECURITY

While no data transmission on the internet is 100% secure from intrusion, we maintain reasonable physical, electronic, and procedural safeguards to protect your information. However, it is possible that third parties may unlawfully intercept or access transmissions or private communications despite our efforts to prevent this, and we therefore make no guarantees regarding the security of user information.

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CHANGES TO THIS POLICY

This Privacy Policy is subject to revision. If we make any changes to this Privacy Policy, we will change the “Last Updated” date above.

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