SHATTERED GLASS PRIVACY POLICY 

Last Updated: March 18, 2020 

This Privacy Policy describes how Shattered Glass Capital, LLC and its subsidiaries (“Shattered Glass”) collect, use, and disclose information that we collect from you, as well as how we protect and secure your data.  If you have additional questions regarding your rights under this Privacy Policy or any agreement you have entered into with Shattered Glass regarding your data, please contact us at connect@shatteredglassequity.com. 
This Privacy Policy generally applies to Personal Information that Shattered Glass collects, uses, and discloses. However, this Privacy Policy is subordinate to any specific terms and conditions set forth in any terms of use, end user license agreements, or other agreements with Shattered Glass related to a particular product, service, or data that is collected.  

What Types of Information and Data Does Shattered Glass Collect, and When Does It Collect This Data? 
Shattered Glass collects various types of Personal Information. We collect this information when you provide it to us (whether directly or through our subsidiaries and/or representatives) or when you use certain services provided by Shattered Glass. 

"Personal Information" is information that can be used to identify, locate, or contact you as a natural person, as well as other information about you that we tie to Personal Information. Personal Information that we collect includes, but is not limited to, the following types of information: 
•    "Contact Information" that allows us to identify and communicate with you, such as your name, phone             number, address, email, and language preferences.
•    “Personal Information” that allows us to identify and verify your identity either as an Entrepreneur or              Qualified Investor (as defined in our Terms of Service), such as, your tax returns, financial information,          Social Security number, and the like.
•    "Transactional Information" about how you interact with us, our subsidiaries and Sponsoring                          Organizations, including services you request, customer service inquiries, and customer account                     information.
“Non-Personal Information” is any information that does not does not identify a natural person and is not identifiable to a natural person, such as:  
•    Cookies and other tools used in a non-identifiable way;
•    Anonymized information;
•    Aggregated information; and
•    Information about your business operations, including, but not limited to:
•    Operation-specific data, such as location data, when kept in a non-identifiable way; and
•    The name, form, and contact details of legal persons.
In addition to the methods described above, Personal Information and Non-Personal Information may be collected by Shattered Glass from its subsidiaries and authorized Sponsoring Organizations as part of its standard business operations, to provide services to the subsidiaries and authorized sponsoring organizations, and as otherwise agreed pursuant to agreements between [NAME] and such subsidiaries. 

When data is described as “anonymized,” it means that the data is no longer associated with a particular person.  When data is described as “aggregated,” it means that such information has been combined with other data in such a way that no person can be identified or linked to any specific action or information. 

How Shattered Glass Uses Your Information (the "Purposes") 
Subject to the limitations and other rights set forth in this Privacy Policy, Shattered Glass uses your Personal Information in its identifiable form for a variety of purposes, including: 
•    To Provide Requested Services. To fulfill services, and for other services or purposes as you may request          or direct, such as product delivery, maintenance, and the like.
•    Product and Customer Support. To provide support services, to deliver upgrades and product                          improvement communications.
•    General Business Purposes. To provide and accomplish standard business tasks, such as account                    management, product development, contract management, website administration, web-forum                      management, contract fulfillment, analytics, fraud prevention, corporate governance, reporting and legal        compliance.
•    As Disclosed at the Time of Collection. In any other manner that we may describe when you provide the          information to us.
These Purposes may be necessary for Shattered Glass to perform a contract to which you are a party, comply with a legal obligation to which Shattered Glass is subject, protect Shattered Glass’ vital interests or the interests of another natural person, or otherwise pursue Shattered Glass’ legitimate business purposes and objectives.  Shattered Glass may obtain your consent to process your Personal Information, as necessary.   
Shattered Glass collects Non-Personal Information in the same ways it collects Personal Information, described elsewhere in this Privacy Policy.  
Because Non-Personal Information does not personally identify you, Shattered Glass may use and disclose Non-Personal Information for any purpose. In some instances, Shattered Glass may combine Non-Personal Information with Personal Information (such as combining your name with your location data). If Shattered Glass combines any Non-Personal Information with Personal Information, Shattered Glass will treat the combined information as Personal Information. 
In addition, Shattered Glass reserves the right to use anonymized and aggregated Personal Information to improve its products and services, to create and publish reports, to conduct statistical analysis about our customers and products, and for other activities that do not result in the disclosure of your identifiable information. 
When Will Shattered Glass Disclose Your Information, and Who May Receive It? 
Shattered Glass is committed to being transparent regarding the manner in which we use and disclose your information. We may disclose and share your information as follows: 
•    We may share Personal Information with our subsidiaries and business partners, as needed to                       accomplish, and consistently with, the Purposes set forth above, or as you authorize or request.
•    We may also share Personal Information with our service providers to fulfill the Purposes on our behalf.         Our service providers are bound by law or contract to treat your information and data with the same level       of protection that we do and to only use it in accordance with our instructions.
•    We may disclose Personal Information where needed to affect the sale or transfer of our business assets,        to enforce our rights, protect our property, or protect the rights, property, or safety of others, or as                needed to support external auditing, compliance, and corporate governance functions.
•    We will also disclose Personal Information when required to do so by law, such as in response to a                 subpoena, including to law enforcement agencies and courts in the countries where we operate.
As noted above, Shattered Glass reserves the right to use and disclose anonymized and aggregated Personal Information to improve its products and services, to create and publish reports, to conduct statistical analysis about our customers and products, and for other activities that do not result in the disclosure of your identifiable information.  
How Long Will Shattered Glass Keep your Information? 
Shattered Glass keeps different kinds of personal data for different lengths of time, depending on the Purposes for which they are processed and the unique circumstances of your situation.   will hold your Personal Information as long as necessary for the relevant Purpose.  For more information on Shattered Glass’ data-retention policy and how long your data might be retained, please contact us as provided below.  
 
Website Data Collection, Cookies, and Similar Technology 
When you visit our website or use our mobile applications, we may collect certain information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. 
For example, when you visit our website, we may place cookies on your computer. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. We may also use Adobe Flash Cookies, Microsoft Silverlight, and similar technologies which remember your settings, preferences, and usage in a manner similar to browser cookies to personalize and enhance your online experience, but which are not managed through your browser. To manage your Flash and Silverlight cookies, please see Adobe’s and Microsoft’s websites.  
Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions. 
We may collect many different types of information from cookies and other technologies. For example, we may collect information about the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also may record the IP address or derivative of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to Shattered Glass and the website you visit after you leave our site. 
In many cases, the information we may collect using cookies and other tools is only used in a non-identifiable way, without reference to Personal Information. For example, we may use information we collect about website users to optimize our websites and to understand website traffic patterns. In some cases, we may associate the information we collect using cookies and other technology with your Personal Information. Additionally, if the settings on your geo-aware mobile devices permit our mobile applications to collect location information, we may collect that information automatically. This Privacy Policy governs how we use all of this information when we associate it with your Personal Information. 
Your Choices and Data Control 
You can limit the information you provide to Shattered Glass. You can also limit the communications that Shattered Glass sends to you. To opt-out of any marketing emails you may receive, you can visit our website and communicate your choice to the relevant privacy contact. Alternatively, you may opt-out of receiving future marketing emails by clicking "unsubscribe" at the bottom of marketing emails we send you. 

Please note that even if you opt-out of receiving marketing material, we may still need to contact you with important Transactional Information about your account or the services provided. For example, even if you opt-out of marketing emails, we will still send you a confirmation of certain events that occur via the website. 

You can manage cookie preferences and opt-out of having cookies and other similar collection technologies used by adjusting the settings on your browser or interface, commonly known as “Do Not Track” settings. All browsers and interfaces are different, so visit the "help" section of your browser or interface to learn about cookie preferences and other privacy settings that may be available. You can manage how your mobile device and mobile browser share location information with Shattered Glass, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings. In general, Shattered Glass complies and requests that all of its service providers comply with your “Do Not Track” settings you select using your internet browser(s). 
Shattered Glass complies with applicable law regarding your ability to access, correct, and delete your Personal Information. If you have an online account, you may be able to log into your account to access and update certain information you provided to us. For Personal Information that is not linked to an online account, for assisting in opting-out of communications, or if you need assistance updating or deleting your Personal Information, please contact us via email at connect@shatteredglassequity.com. You can also write us at the address in the How to Contact Us section below. If you send us a letter, please provide your name, address, email address, and detailed information about the change you would like to make. 

Information and Data Security 
Shattered Glass has implemented an information and data security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information. 

Privacy Policies of Third Parties 
This Privacy Policy only addresses the collection, use, and disclosure of information and data by Shattered Glass and its subsidiaries. Other websites that may be accessible through this website have their own privacy policies and practices, which govern their use of information that they collect or otherwise obtain from you. Our business partners have their own privacy policies and practices as well. We encourage you to familiarize yourself with the privacy statements provided by all such third parties prior to providing them with information or taking advantage of an offer or promotion. 

Children’s Privacy 
This website is not intended for use by children younger than 18 years old. Shattered Glass will not knowingly collect information from site visitors younger than 18 years.  

Plug-Ins to Social Media and Other Third Party Services 
In addition, Shattered Glass’ websites may also contain links, plug-ins, APIs, and other tools that enable you to share content on our website or your own content through third party social media or other services (such a Facebook, Twitter, Google+, and other services). All use of such third party services, including through links found on our website, shall be considered public information and shall be subject to the terms and conditions of such third party services.  

In addition, Shattered Glass’ websites and software products may incorporate certain mapping software and documentation developed by Google, Inc. and licensed to Shattered Glass. Customer acknowledges and agrees that its use of such mapping software and documentation is subject to Google’s Privacy Policy, which can be found at http://www.google.com/policies/privacy.  

Amendments and Changes 
This Privacy Policy may be amended and updated from time to time to reflect new or different privacy practices. We will place notice on our homepage when we make material changes to this Privacy Policy. Additionally, if the changes will materially affect the way we use or disclose previously collected Personal Information, we may also notify you about the change by sending electronic notice to you (if we have your email address).
Use of Information Outside Your Country of Residence 
The Service is intended for users located in the United States. Our websites are not intended for natural persons residing in the EU or any other country. If you are a natural person residing in the EU and at any time you believe we have violated one of your rights under Articles 15 to 21 of the General Data Protection Regulation (“GDPR”), or if you believe we are in violation of one or more of the provisions of the GDPR, you have the right to lodge a complaint with a Data Protection Authority. More information about the Data Protection Authorities can be found at https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protectionauthorities-dpas_en.
 
Shattered Glass is headquartered in the United States of America. Personal Information may be accessed by or transferred to the United States or to our controlled affiliates and data processors elsewhere in the world for the Purposes described in this Privacy Policy. Your agreement to this Privacy Policy followed by your submission of information through the Service represents your consent and agreement to these practices. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Service. When we access or transfer Personal Information, we do so in compliance with applicable law. Additionally, we protect the privacy and security of Personal Information in the manner described in this Privacy Policy, regardless of where it is processed or stored.
 
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the information below.
 
How to Contact Us
If you have questions or comments about this Privacy Policy or any of our privacy practices, you can contact us at connect@shatteredglassequity.com. You can also reach us via mail at the following address:
 
Shattered Glass Capital, LLC
Attn: Privacy
401 Grand Avenue
West Des Moines, IA 50265
March 18, 2020
Private and Confidential

SHATTERED GLASS EQUITY

401 Grand Ave. West Des Moines, Iowa

515-277-0042

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