CCPA Privacy Notice

Updated: October 2021

This privacy notice (“Privacy Notice”) for California Residents under the California Consumer Privacy Act of 2018 (“CCPA”) supplements the information contained in the Privacy Policy and solely applies to our Users who are residents of the State of California (as such is defined under the CCPA) (“Consumers” or “you”). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.Furthermore, this Privacy Notice is an integral part of our Privacy Policy and therefore, any capitalized terms used herein but not defined herein shall have the meaning ascribed to them in the Privacy Policy.

To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.

1. Categories of Personal Information We Collect

Under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular consumer, household, or device. The categories of Personal Information that we collect(and have collected within the last 12 months), depending on your interaction with us (i.e., a User, a Visitor, End-User or Partner) are included in the table below.

Category	Examples	Is Collected or not?
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender, identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	No
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

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2. How We Collect Information

Depending on the nature of your interaction with us we may collect information as follows:

2.1. Automatically –we may use cookies or similar tracking technologies to gather some information automatically.

2.2. Provided by you voluntarily –we will collect information if and when you choose to provide us with the information, such as your communications with us, as part of the registration, etc. all as detailed in this Privacy Notice.

3. Use of Personal Information

We may use or disclose the Personal Information we collect from you for the commercial and business purposes included in our Privacy Policy, and as summarized below, as follows:

3.1. To provide our Services.

3.2. To fulfill or meet the reason you provided the Personal Information. For example, if you contact us with an inquiry and share your name and contact information, we will use such PersonalInformation to respond to your inquiry.

3.3. To provide, support, personalize, and develop our Website and Services, as well as improve our Services.

3.4. For security and fraud detection purposes, and to maintain the safety, security, and integrity of our Website and Services.

3.5. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

3.6. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether asa going concern or as part of bankruptcy, liquidation, or similar proceeding.

We will not collect additional categories of Personal Information from you or use the Personal Information we collected for a materially different, unrelated, or incompatible purpose other than those we informed you of without providing you notice of such.

4. Sharing Data With Third Parties

We may disclose our Consumers PersonalInformation to the following third parties:

4.1. Third parties who assist us in operating and providing the Services and conducting our business, such as fraud prevention, cloud hosting services, marketing, account maintenance and technology services;

4.2. our affiliates and connected companies, such as subsidiaries, sister-companies and parent companies and in the event of a merger or acquisition our affiliated companies or acquiring companies will assume the rights and obligations as described in this Privacy Notice.

4.3. Any governmental and semi governmental authority, in order to satisfy any applicable law, regulation, legal process, subpoena, or governmental request, solely to the extent required.

4.4. Service Providers and any third party in order to enforce this Privacy Notice, including the investigation of potential violations thereof, solely to the extent required;

5. Disclosures of Personal Information For a Business Purpose

In the preceding twelve (12) months, the Company has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers;

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e));

Category F. Internet or other similar network activity.

We disclose your Personal Information for a business purpose to the following categories of third parties: data aggregators, and service providers (e.g. cloud hosting servers etc.).

When we disclose Personal Information fora business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

6. Sales Of Personal Information

In the preceding twelve (12) months, the Company has not sold Personal Information.

7. Your Rights Regarding Your Personal Information

The CCPA provides Consumers with specific rights regarding their Personal Information. Please review our Privacy Rights Policy in order to learn more about the rights you may have under applicable law.

If you wish to exercise any or all of the above rights, please fill out the Data Subject Request form (“DSR”) and send it to us at: support@ownid.com.

Once we receive a Request from you, we may ask you to provide us with more information or documentation to verify your request. We aim to respond to your verified Request without undue delay and in any event according to the time frame set forth under applicable laws. If we require more time to respond to your request, we will inform you of the reasoning behind the extension period and the duration of such period in writing. Our response will also explain the reasons why we are unable to comply with are quest, if applicable.

8. Amendments

As required under the CCPA, we will update this Privacy Notice every 12 months. The last revision date will be reflected in the “RecentlyUpdated” note located at the header of this Privacy Notice.

9. CONTACT US

If you have any questions about this Privacy Notice, please contact us at: support@ownid.com.

We will make our best efforts to replay as soon as possible.