Steelhead Technologies, Privacy Policy Effective Date: January 1, 2022

GENERAL

The purpose of this privacy policy (this “Policy”) is to describe the types of personal information (defined below) that Steelhead Technologies Inc. (“we” or “us” or “our”) collects about individual persons accessing our website (each a "user" or "you") at gosteelhead.com or app.gosteelhead.com (collectively with any other websites that we operate, including but not limited to any mobile website or mobile application related or connected thereto, and all related web pages, the “Site”) and our various software and service offerings as described on the Site (collectively with the Site, the “Service”). This Policy Is also intended to explain the conditions under which we use and disclose that information, and your rights in relation to that information. Changes to this Policy are discussed at the end of this document. Each time you use the Site, however, the current version of this Policy will apply. Accordingly, each time you use the Site you should check the Effective Date of this Policy (which appears at the beginning of this document) and review any changes since the last time you used the Site.   By accepting the terms of this Policy, you consent and agree to our use of information (including personal information) as described herein, subject to the terms of and your rights under the Policy. This Policy does not describe all technical or other information collect or stored (such as product descriptions or specifications) which is not related to individual users.  In addition to the provisions of this Privacy Policy, information we collect is governed by our Licensing Agreement and any applicable service or other agreement(s) to which you agree in connection with your use of the Service. The Site is hosted in the United States of America and is subject to U.S. state and federal law. If you are accessing our Site from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Site, you consent to that transfer and use of your personal information in accordance with this Policy. You also agree to abide by the applicable laws of applicable states and U.S. federal law concerning your use of the Site and your agreements with us. Any users accessing our Site from any jurisdiction with laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the Site in a manner lawful in their jurisdiction. If your use of the Site would be unlawful in your jurisdiction, please do not use the Site.

BY USING OR ACCESSING THE SITE, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION

  • Users of the Site Generally “Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, we gather from users of the Site, Non-Personally-Identifying Information of the sort that web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, while navigating and immediately after leaving the Site. Although such information is not Personally-Identifying Information, it may be possible for us to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. We analyze Non-Personally-Identifying Information gathered from users of the Site to help us better understand how the Site is being used. By identifying patterns and trends in usage, we are able to better design the Site to improve users’ experiences, both in terms of content and ease of use. From time to time, we may also release the Non-Personally-Identifying Information gathered from Site users in the aggregate, such as by publishing a report on trends in the usage of the Site.
  • Web Cookies A “Web Cookie” is a string of information which assigns you a unique identification that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user submits a query to the website. We use cookies on the Site to keep track of services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Site, and to facilitate purchase procedures. We also use Web Cookies to track the pages that users visit during each Site session, both to help us improve users’ experiences and to help us understand how the Site is being used. As with other Non-Personally-Identifying Information gathered from users of the Site, we analyze and disclose in aggregated form information gathered using Web Cookies, so as to help us, our partners, and others better understand how the Site is being used. SITE USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE BSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE SITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. SITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.  
  • Third-Party Advertisers We may use third-party advertising companies to serve ads when you visit the Site. These companies may use information (not including any Personally-Identifying Information) about your visits to the Site and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third-party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the following links: http://networkadvertising.org/managing/opt_out.asp, http://preferences-mgr.truste.com/, or http://www.aboutads.info/choices/. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.  We may allow advertisers to choose the characteristics of users who will see their advertisements, and we may use any of the Non-Personally Identifying Information we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. We do not identify you to the advertiser.  
  • Web Beacons A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. We may use Web Beacons on the Site and in emails to users of the Site to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information. They are a technique we may use to compile aggregated statistics about Site usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.  
  • Analytics We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Site, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads).
  • Aggregated and Non-Personally-Identifying Information We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Site and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Site and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.  
  • Mobile Device Additional Terms o Mobile Device. If you use a mobile device to access the Site or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address. o Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our Service, except that it may be possible for us to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data. o Push Notifications. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings. o Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally-Identifying Information you submit within the mobile application. SOCIAL MEDIA We may provide you the option to connect your account on the Site to your account on some social networking sites for the purpose of logging in, uploading information or enabling certain features on the Site. When logging in using your social network credentials, we may collect the Personally-Identifying Information you have made publicly available on the social networking site, such as your name, profile picture, cover photo, username, gender, friends network, age range, locale, friend list and any other information you have made public. Once connected, other users may also be able to see information about your social network, such as the size of your network and your friends, including common friends. By connecting your account on the Site to your account on any social networking site, you hereby consent to the continuous release of information about you to us. We will not send any of your account information to the connected social networking site without first disclosing that to you. Each social network may further allow you to set privacy controls around your information on their system, and our collection of information will always follow such controls and permissions. This feature is subject to continuous change and improvement by us and each social networking site involved, and therefore the available features and shared information are subject to change without notice to you. We may use hyperlinks on the Site which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons none, of your data will be sent to the respective social network’s plugin provider. So for example, when you click on the Facebook’s “Like” button on the Site, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Site. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.

COLLECTION, USE, AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION WE COLLECT, OR YOU MAY PROVIDE TO US

As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. When you use the Service, we may collect a range of Personally-Identifying Information from and about users of the Service. Much of the Personally-Identifying Information collected by us about users is information provided by users themselves when (1) registering for the Service, (2) logging in to the Site or the Service with social network credentials, (3) participating in polls, contests, surveys or other features of our Service, or responding to offers or advertisements, (4) communicating with us (including but not limited to e-mail communications), or (5) signing up to receive newsletters from us. That information may include each user’s name, address, company name, job title, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic or relevant information as determined by us from time to time. If you participate in one of our surveys, we will collect the information you provide. If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. When you order products or services through the Service, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information. In certain circumstances, we may request that you provide us with photocopies of your ID and other related documents for fraud prevention purposes and to verify your identity. While using the Service, you may have the opportunity to provide us with personal information of other individuals (such as their name, email address, telephone number), for purposes of enabling you to use the Service to transmit information, messages, files or data to those individuals.  In order to enable such transmissions, such individuals must first register with us to use the Services.  You hereby represent, warrant and agree that you will not provide us with any third party personal information unless you have all necessary rights, consents, authorizations and permissions to do so and to permit us to use that information for the purposes noted above, and you hereby authorize us to use such information for those purposes. We may use your Personally-Identifying Information and other information we obtain from your activities on the Site and using the Service to, among other things, resolve disputes between you and us, or between you and another user of the Service, troubleshoot problems, collect fees owed to us by you for use of the Service, to collect consumer data regarding the Service, to inform you about offers and promotions of our or third parties products and services, to customize your experience relative to the Service, to enforce our Licensing Agreement, and to protect against error or misuse of the Site. Users of the Site are under no obligation to provide us with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from purchasing and using the Service.

BY REGISTERING WITH OR USING THE SITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE, AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION WE COLLECT, OR YOU MAY PROVIDE TO US” SECTION.

  • General Use In general, the Personally-Identifying Information you submit to us may be used to respond to requests that you make relative to the Service, or to aid us in serving you better.  We may use your personal information in several ways, including but not limited to the following:
  • Online Postings Certain Personally-Identifying Information collected from users may be disclosed as a matter of course as a result of your use of the Site and Service, including but not limited to posting reviews or user testimonials. We may provide areas on the Site where you can post reviews, user testimonials, and other information relating to your activities on the Site. Such postings are governed by our Terms of Use. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.

USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF PERSONALLY IDENTIFYING INFORMATION.

In addition to the foregoing, postings made by you are subject to the following restrictions. By posting on the Site, you agree that you will not under any circumstances:

  • Post any information that is abusive, threatening, obscene, defamatory, libelous, pornographic, or racially, sexually, religiously, politically, or otherwise objectionable and offensive;  
  • Post any communication or solicitation designed or intended to obtain another user’s account information or password.
  • Employ spam messages, or post any fake news or fake content, or refer to any site where such content is contained;
  • Post any communication for any unlawful purpose or for the promotion of illegal activities;
  • Post any communication for any other purpose than stated in this Policy;
  • Post any communication for any commercial purpose;
  • Post any communication attempting to harass, abuse or harm another person or group;
  • Post any communication regarding another user’s account without permission;
  • Publish or link to malicious content intended to damage or disrupt another user’s browser or computer; Any Posting made in violation of the foregoing violates this Policy and may result in the termination or suspension of your access to the Service, and may also result in our pursuit of damages and other remedies from you to the fullest extent permitted by law.  
  • Our Communications We may occasionally use your name and email address to send you notifications regarding new services offered by the Site that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the Service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.  
  • Our Disclosures We will disclose Personally-Identifying Information under the following circumstances:   By Law or to Protect Rights: When we believe disclosure is appropriate, we may disclose Personally-Identifying Information in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or our safety, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use, the Licensing Agreement, or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us. Marketing Communications: Unless users opt-out from receiving our marketing materials upon registration, we may email users about products and services that we believe may be of interest to them. If you wish to opt-out of receiving marketing materials from us, you may do so by following the unsubscribe link in the email communications, by going to Iccount settings (if applicable) or contacting us using the contact information below. Third-Party Marketing Communications: Unless users opt-out from receiving marketing materials upon registration, we may provide users’ email information to third parties, so that those third parties may directly contact them about additional products and services. To cease having your email information provided to third parties, you may do so by going to your account settings (if applicable) or contacting us using the contact information below. Even after opting-out, you may continue to receive marketing emails from third parties to whom we already has provided your email information. You will be responsible for directly contacting such third parties to request cessation of further marketing emails. Third-Party Service Providers: We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Site’s functionality and supporting contests, sweepstakes, surveys and other features offered through the Site. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose. Business Transfers; Bankruptcy: We reserve the right to transfer all Personally-Identifying Information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personally-Identifying Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. Personally-Identifying Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.  
  • Changing Personally-Identifying Information; Account Termination You may, at any time, review or change your Personally-Identifying Information by going to your account settings (if applicable) or contacting us using the contact information below.  Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity relative to the Service and in accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some Personally-Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your Personally-Identifying Information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account. • General Use We use the Personally-Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Site (1) to deliver the products and services that you have requested; (2) to facilitate the creation of and secure your account for our Service; (3) to manage your account and provide you with customer support; (4) to identify you as a user in our system; (5) to communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, our affiliate companies or other third parties including but not limited to newsletters, surveys, offers, and other promotional materials; (6) to develop and display content and advertising tailored to your interests on the Site and other sites; (7) to resolve disputes and troubleshoot problems relative to the Service; (8) to measure consumer interest in our services; (9) to inform you of updates and to provide status information related to the same; (10) to provide you with the Service or updates thereto; (11) to respond to your inquiries and other requests relative to the Service; (12) to customize your experience and provide improved administration of the Service; (13) to detect and protect us against error, fraud and other criminal activity; (14) to enforce our Terms of Use; and (15) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on the Site, enroll you in the discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed to manage our business.  

COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY

We contractually prohibits our contractors, affiliates, vendors and suppliers from disclosing Personally-Identifying Information received from us, other than in accordance with this Privacy Policy. However, third parties are under no obligation to comply with this Privacy Policy with respect to Personally-Identifying Information that users provide directly to those third parties, or that those third parties collect for themselves. These third parties include but are not limited to advertisers, utilities, widgets and a variety of other third-party applications that may be accessible through the Service. We neither own nor control the third-party websites and applications accessible through the Service. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third party, or using a third-party application, whether by means of a link on the Site or the Service, directly through the Site or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website or application, and should take those steps necessary to, in those users’ discretion, protect their privacy. SECURITY We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse.  However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.   We are dedicated to protecting all information on the Service as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.  GOVERNING LAW; VENUE This Policy is governed by the laws of the State of Michigan and the United States, without giving effect to any conflicts of law principles. We, and user by accessing the Site and/or using the Service, agree that the forum, jurisdiction and venue to bring any claims, controversies, or disputes arising from or related to this Policy shall be exclusively in either the state courts for Houghton County, Michigan or the United States District Court for the Eastern District of Michigan, and we and the user expressly agree to submit to the exclusive venue and jurisdiction of such courts.  

PRIVACY POLICY CHANGES

We may, in our sole discretion, change this Privacy Policy from time to time. Any and all changes to our Privacy Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. We will always post new versions of the Privacy Policy on the Site. However, we may, as determined in our sole discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information. CHILDREN The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. Any person who provides Personally-Identifying Information through the Service represents to us that he or she is 13 years of age or older. The Service is not directed to any person under the age of 18. If we learn that Personally-Identifying Information has been collected from a user under 18 years of age on or through the Service, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 18 who has become a member of the Service or has otherwise transferred Personally-Identifying Information to the Service, please contact us using our contact information below to have that child's account terminated and information deleted.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below under the “CONTACT” section.

NOTICE TO RESIDENTS OF COUNTRIES OTHER THAN THE UNITED STATES OF AMERICA

We are headquartered and operated in the United States of America. Personally-Identifying Information may be accessed by us or transferred to us in the United States of America or to our affiliates, business partners, or service providers elsewhere in the world in connection with the Service. By providing us with Personally-Identifying Information, you consent to this transfer.

DO-NOT-TRACK POLICY

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, neither the Site nor the Service currently respond to DNT browser signals or mechanisms.

CONTACT

If you have any questions regarding our Privacy Policy, please contact our Privacy Officer via email at dean@gosteelhead.com.or by mail to: Steelhead Technologies, Inc. Attn: Dean Halonen 300 Hecla Street Laurium, MI 48813