Privacy Policy — Ratetopix

Ratetopix Corp Privacy Policy

Effective: May 1, 2021

Introduction

This Privacy Policy describes how Ratetopix™ collects, uses and otherwise processes information

that you disclose to us or that we gather in connection with your use of our mobile applications,

website, and other products and services (“Services”).

The terms “Ratetopix”, “we”, “our”, and “us” refer to Ratetopix Corp, a Florida corporation. The

terms “you” and “your” refer to you, as a user of our App, website or other Services.

When you use our Services, you consent to our collection, use, storage, disclosure, transmission

and other processing of your information as described in this Privacy Policy. If you do not want

us to collect, use or otherwise process your information as described in this Privacy Policy, please

do not use our Services. Minors (under 18 years of age) or persons who lack the legal capacity to

contract may only use our Services with the permission and under the direct supervision of the

adult owner of the account. Children under 13 years of age are not permitted to use our Services.

This Privacy Policy will be updated from time to time and the effective date of the current version

will be shown at the top of the page and/or in the footer. This Privacy Policy may be made available

in multiple languages, but the English language version shall govern your relationship with us and,

in the event of any conflict among versions of this Privacy Policy, the most recently updated

English language version shall govern and control.

We are in the business of rating people, places, activities and things based on ratings that users of

our mobile applications (“App” or “Apps”) share via the Apps. The ratings are anonymized,

aggregated and projected on a heatmap to show how an item is trending based on the ratings

(“Heatmap”). The anonymized, aggregated ratings coupled with demographic data may be

provided in statistical data reports

(“Statistical Reports”). User-posted ratings, reviews,

sentiments and feedback and other content are available on the Apps for public consumption

(“User Content”).

Our Apps should be available for you to download on your device from a participating mobile app

distribution platform/marketplace (“App Platform”). If you are an iOS or Android device user,

our iOS App is available on the Apple AppStore and our Android App is available on the Google

Play Store. Other Apps may become available on other App Platforms. You may be able to follow

us on social media sites. Your use of your devices on these App Platforms and your use of social

media sites will be subject to the privacy policy, terms of use, cookie policy and other policies and

legal requirements of those platforms and sites. We do not control and are not responsible for the

content, ads, data processing, privacy policies or practices of those platforms and sites.

All trademarks, tradenames and other intellectual property associated with the Apps are the

property of Ratetopix and its licensors. Reference to Apple, Google, iOS, Android and third party

products and services are not meant to indicate any partnership, joint venture, or other relationships

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between Ratetopix and those companies or any sponsorship of Ratetopix, our Services or User

Content by any of those companies.

Information we Collect and for what Purposes

App Profile Data: In order to establish your username and password for using the App, you are

asked to provide your email address, phone number, date of birth, gender, city, state, country, and

zip code. We do not ask for your name or street address to establish your App profile. We use your

username and password that you establish with us to grant you access to and use of the App. We

use date of birth to determine if you are of the required age to use our Apps, because we do not

knowingly permit persons under 13 years of age to use our Apps. We use your email address for

communications with you. To unsubscribe from the App, you can delete the App. To discontinue

communications from us, you can unsubscribe from communications by pressing the unsubscribe

option in an email you receive from us.

User Content: This includes the content you post via use of the Apps and/or our website, including,

your ratings, reviews, sentiments, feedback, and texts (and later upgrades of the Apps may allow

posting of graphics, photos and videos). Your content is intended for public viewing and

consumption with no payment or other compensation to you and no privacy right or protection is

granted herein to your content. Other users of the Apps may review or comment on your posts,

may reshare your posts, may create similar posts and share their reviews and comments for other

users to see, comment on and/or reshare. Based on your activity or lack thereof on our Apps, other

users can determine whether you are active or not on our App. You are responsible for the content

you post, including its legality, reliability, and appropriateness. Your posts must comply with the

content guidelines in our Terms of Use. Your content must be your original creation. If you use

any third-party content, you must duly obtain their permission to use their content. We use data

analytics software to combine the ratings you provide with certain anonymized demographic

information from your App profile data (age, gender, city, state, country and zip code) and to

aggregate the data and we use the anonymized, aggregated data on the Heatmap and in the

Statistical Reports which we will commercially exploit.

Communications: If you provide a profile on our website or communicate with us via email or

otherwise, you may provide us with your name and email address. We use this data to communicate

with you, if you ask a question or if you request to otherwise communicate with us. When you

receive an email from us through our website or our App, you can select the unsubscribe option in

said email and our system will stop sending you emails from the Service from which you

unsubscribed, except to communicate or record the exercise of your option to unsubscribe or for

other legally permitted purposes.

Transaction Data: If you purchase our Statistical Reports, we will collect and use the transaction

data, including the transaction date, item purchased, price, payment method, and delivery

information.

Use by Service Providers and Successors: Our employees and contractors who have a bona fide

need to access our servers and review our data to manage, support, maintain and upgrade our

websites, Apps and other systems will have access to and use of your information in order provide

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said services. In connection with the sale of our assets or a merger or reorganization, we may

disclose and/or transfer your information to the buyer or our successor, in which event we will

require adequate safeguards from said buyer or successor for the protection of your information

similar to those set forth in this Privacy Policy.

Processing in and outside the USA: We are based in the United States but provide Services

internationally. Our employees and contractors are located in several countries and they will have

access to the information we process at or from their locations. Generally, information that we

collect in the United States will be processed primarily within the United States. We also utilize

third-party tools and services, through which some of your information may be transmitted or

otherwise processed within and outside the United States, including the following: (a) internet and

other communications lines and facilities for transmission of data; (b) cloud-based storage services

whose servers may be located in multiple countries, for storage, access and other processing; (c)

email and document file hosting services whose servers may be located in multiple countries; and

(d) vendors and service providers to manage, support, maintain and upgrade our websites, Apps

and other systems.

Information we do not Collect: We do not knowingly collect or otherwise process personal

information of children.

Marketing: We do not currently market our Services. In the event we use any of your personal

information to market our Services to you, we will secure your consent for such use where required

and you will also have the opportunity to opt out of our use of your personal information for

marketing purposes.

Ads: App Platforms and social media sites usually post ads that will be viewed by App users. You

may be able to set your user preferences on your devices to opt out from or manage advertising

preferences. We do not control what device settings or preferences App Platforms and other sites

make available to you to manage targeted in-application and other advertising. Your use of your

devices on these App Platforms and your use of social media sites will be subject to the privacy

policy, terms of use, cookie policy and other policies and legal requirements of those platforms

and sites. We do not control and have no responsibility for the ads and content that the App

Platforms post or permit third parties to post on their platforms or while you are using our Apps

and we do not undertake any obligation to monitor or sensor those ads and content. You are solely

responsible for setting your user preferences on your devices to control what content is viewed

through your devices.

Payment Information: We do not currently sell any products or Services to you. If and when we

sell any Services or products, such as a Statistical Report, (1) you will be directed to pay through

a third-party payment service that will processes your payment and for which we do not see or

process your payment card information or (2) we will issue an invoice that you pay by making an

electronic funds transfer directly to a bank account, in which event we do not see or process your

bank or other payment information.

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Information Protections and Risks

Protections: We have committed to maintaining technical, organizational and physical safeguards

to protect your personally identifiable information that we collect and use, against unauthorized

access, use, reproduction, alteration, disclosure, dissemination and destruction, taking into account

the nature of the data, our use of the data and the threats posed, including the following: (1)

implementing an information security policy; (2) utilizing storage and transmission encryption

technology to protect personally identifiable information at rest and in transit; (3) requiring all of

our employees and contractors to be bound by written confidentiality and non-disclosure

agreements; (4) limiting access to personally identifiable information to only those of our

employees and contractors who have a bona fide need to know that information in order to perform

their job functions; (5) providing periodic training to our employees and contractors to educate

them on our data security requirements; (6) when we select third-party tools and services, including

webservers and cloud storage facilities, using diligent efforts to select nationally and

internationally known and reputable providers, including those who give assurances of network

security; (7) anonymizing information using data analytics tools; and (8) our IT support team

regularly monitoring and testing our systems infrastructure to detect and manage vulnerabilities.

Risks: Unfortunately, no data transmission over the Internet, no electronic storage of data and no

website, system or facility is fully secure or immune from cyberattack or compromise. You

understand that any message or information you send to us may be read or intercepted by others.

Accordingly, and despite our efforts to protect your information, we cannot guarantee or warrant

absolute security of your information.

How Long do we Keep your Information

We retain your ratings, reviews and sentiments and posts indefinitely, including for as long as you

maintain a username and password or an account on any of our Apps or for as long as we deem

appropriate to satisfy our legal rights and obligations. We retain your name and email address until

you opt out or unsubscribe to communications from us or for a longer period to satisfy our legal

rights or obligations. We may retain your personal information for the period necessary to fulfill

the purposes for which the information was given to us and for a reasonable time period thereafter

or indefinitely to support our compliance with this Privacy Policy and applicable laws, including

retaining evidence of your consent and your opt out, unsubscribe, erasure and other rights requests.

We may delete your information if we believe that the information is incomplete, inaccurate, or

that our continued use and storage of such information is contrary to our obligations. In some

instances, we may anonymize, pseudonymize or aggregate your information so that the data is no

longer identified with you, but the data may remain in our archives for research or statistical

purposes and may remain indefinitely for such purposes or if we determine it is not practical or

possible to delete it.

Cookies

We do not use Cookies: As of the date of release of this Privacy Policy, we do not use cookies or

other tracking technologies on our website to track your activities on our website. If we use cookies

on our website, you will see a pop-up notice to that effect and would have an opportunity to accept

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or refuse the use of cookies with respect to your use of the website; and, if you reject the use of

cookies, you may not be allowed to proceed further on the website or your use of the website will

be limited.

Third-party Cookies: App Platforms and social media sites and other sites you visit may use

cookies and other tracking technologies pursuant to their cookie policies, privacy policies, and

accessing those platforms or sites. We do not control the App Platforms or other sites’ use of

cookies and other tracking technologies. You may be able to reject or opt out from the use of

cookies or to delete cookies from your browser.

Consent & Parental Responsibility

Consent to Process: You consent to our use and other processing of your information pursuant to

this Privacy Policy. Do not disclose your information to us unless you have freely given your

consent for us to process your information pursuant to this Privacy Policy. Your consent may be

given in several ways, including when you download any of our Apps or complete or update your

profile on any of our Apps, by you clicking an “opt-in”, “I agree”, “I consent” or other similar

buttons on our App or website, or when you transact business with us. In some instances, you will

give your consent to another individual, entity or company, such as your employer or other

controller of your information from whom we receive your information and, in these instances, we

will assume that your consent was freely given to such entity and that said consent includes your

consent for us to process your information pursuant to this Privacy Policy.

Children & Parental Responsibility: We do not knowingly permit persons under 13 years of age

to use our Apps or website. We do not knowingly collect or otherwise process personal information

of children. Do not provide your consent or personal information if you are under thirteen (13)

years of age. In any event, we have no obligation and we do not intend or desire to contract with

you unless you are of the age set by applicable law for you to be bound by a contract with us.

Minors (under eighteen (18) years of age, but not younger than 13 years of age) or persons who

otherwise do not have the legal capacity to contract to use our Services may only use our Services

through an account owned by their parent or legal guardian with said parent or legal guardian’s

consent and direct supervision. Said parent or legal guardian is responsible for any and all activity

on our Apps or website conducted by a minor or persons who otherwise do not have the legal

capacity to contract.

California Residents

The State of California enacted the California Consumer Privacy Act of 2018 (“CCPA”) that gives

California residents certain rights related to the collection, use and sharing of their personal

information. The CCPA only applies to certain companies and activities. As of the date of this

information and will not do so in the future without giving you the required notice and opportunity

to opt out of the sale. Ratetopix does not offer financial incentives to others in connection with the

collection, use or disclosure of your personal information. To the extent that the CCPA becomes

applicable to Ratetopix, California residents will have certain rights with respect to their personal

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information, including the right to (1) request to know what personal information Ratetopix has

collected about you and to access that information and (2) request the deletion of your personal

information, subject to certain exceptions that allows us to retain said information. We will not

discriminate against you for exercising your rights under the CCPA. Under the California Shine

the Light Law, California residents have the right to request certain companies to disclose what

personal information the companies share with third parties for those third parties’ marketing

purposes. Ratetopix does not disclose your personal information to third parties for marketing

purposes.

Nevada Residents

Nevada enacted SB 220 under which website operators are required to provide a way for Nevada

consumers to opt out of certain sales (as defined in the statute) of certain personally identifiable

information about them that the website operator collects. Ratetopix does not sell your personal

information and will not do so in the future without giving you the required notice and opportunity

to opt out of the sale. When and to the extent that this law becomes applicable to Ratetopix, you

may submit your requests to the Data Security Office via the email provided below in this Privacy

Policy.

Virginia Residents

Virginia enacted the Consumer Data Protection Act (“CDPA”) to go into effect January 1, 2023.

The CDPA applies to certain data controllers who target Virginia consumers and processes

personal data of a stated threshold volume of Virginia consumers. Ratetopix does not target

Virginia consumers and does not sell your personal information and will not do so in the future

without giving you the required notice and opportunity to opt out of the sale. As of the date of this

applicable to Ratetopix, Virginia residents will have the right

(1) to know what personal

information Ratetopix has collected about them and for what purpose, (2) to correct inaccuracies

in their personal data, (3) to have personal data deleted, (4) to obtain portable copies for automated

transfer, and (5) to opt out of targeted advertising, profiling, and sale of personal data.

10.

European Residents Subject to GDPR

The European Union General Data Protection Regulation (“GDPR”) imposes certain obligations

upon certain companies conducting business in the EU and provides certain rights for data subjects

with respect to their personal data. The GDPR defines the term “personal data” as follows: any

information relating to an identified or identifiable natural person (data subject); an identifiable

natural person is one who can be identified, directly or indirectly, in particular by reference to an

identifier such as a name, an identification number, location data, an online identifier or to one

or more factors specific to the physical, physiological, genetic, mental, economic, cultural or

social identity of that natural person.

Generally, we are authorized to, and will, process your personal data if at least one of the following

applies: (1) you gave consent to process your personal data for one or more specific purposes; (2)

processing is necessary for the performance of a contract to which you are a party or in order to

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take steps at your request prior to entering into a contract; (3) processing is necessary for

compliance with a legal obligation to which the data collector, controller or processor is subject;

(4) processing is necessary in order to protect your vital interests or the vital interests of another

natural person; and (5) processing is necessary for the purposes of the legitimate interests pursued

by the data collector, controller or processor, except where such interests are overridden by your

interests or fundamental rights and freedoms which require protection of personal data, in

particular where the data subject is a child.

Data subjects have the following rights, subject to certain conditions and limitations: (1) to consent

to the processing of their personal data; (2) to request access to their personal data that is being

processed; (3) to request rectification (correction) of their personal data; (4) to be forgotten (i.e.,

to have their personal data erased) in certain instances; (5) to restrict further processing of their

personal data; (6) to notification of disclosure, rectification or erasure of their personal data; (7) to

portability (i.e., to have their personal data transferred to them or to another data controller); (8) to

object to certain processing of their personal data, including in connection with the data

controller’s pursuit of certain legal rights, profiling or marketing; (9) to object to their personal

data being subject to automated decision making about them, such as profiling; and (10) to

withdraw their consent to process their personal data. If we erase your personal data from our

system, upon such erasure we will be unable to recreate your personal data.

In the event the GDPR transfer requirements apply to our extraterritorial transfer your personal

data, we will utilize standard contract clauses, rely on the EU adequacy decisions, obtain your

consent or other requirements provided by the GDPR or otherwise satisfy the required conditions

for said transfers. A data subject may lodge a complaint with a supervisory authority, if the

processing of their personal data infringes the GDPR. We would appreciate the opportunity to

address your complaint before you escalate the matter to a supervisory authority proceeding, so

please contact us with your complaint so that we can address it as soon as possible to mitigate any

resulting damages. You may contact our Data Security Office with respect to your legal rights

affecting our use of your personal data.

11.

Other Jurisdictions

The laws of each jurisdiction for the protection of data privacy may vary and may not offer the

same level of data privacy protection as the laws in your home jurisdiction. We will implement

reasonable safeguards to protect your data in accordance with applicable law. By using our

Services or transferring your personal information to us you consent to our collection and use of

your personal information as provided in this Privacy Policy.

12.

Overriding Requirements

Applicable laws may provide compelling, legitimate grounds for processing personally

identifiable information, personal data, and user content for the establishment, exercise or defense

of legal claims, which override your interests, rights and freedoms. The data privacy laws in some

countries may be less stringent than the laws of your country and the government, law enforcement

and courts of some countries may be able to access your personally identifiable information,

personal data and user content in certain circumstances. Some court orders, subpoenas,

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administrative agencies’ orders, or contracts may require us to take certain actions with respect to

personally identifiable information, personal data and user content, including disclosing your

personally identifiable information or personal data, that may be contrary to your requests and

instructions and we may have to defer to the foregoing laws, orders or contracts in certain

circumstances. Where we deem appropriate and permissible, we will seek protective orders to

protect your personally identifiable information or personal data from such compelled disclosures.

As a processor, we may be required to follow the instructions of the controller. A third-party

contract under which we receive your personally identifiable information or personal data (e.g., a

contract with your employer) or applicable laws may require us to retain business records, which

may include personally identifiable information or personal data, for a period that is longer than

the period allowed under other laws or regulations or that you prefer. We reserve the right to

disclose, modify, delete, take down, block, and otherwise use your personally identifiable

information, personal data and user content as we deem appropriate to comply with applicable

laws, regulations, directives, orders, subpoenas, rules, legal process, and contractual obligations

and in responding to claims and complaints relating to infringement, identity theft, misuse and

misappropriation.

13.

Presumption of Authenticity

We will rely on the data we have in our file to verify the accuracy of and honor or respond to your

requests or instructions regarding your personal data. We will assume that your request or

instruction is authentic if it uses your name or email address that you provided to us or that was

provided to us by a third party who had apparent authority to share your data with us, such as your

employer. We rely on you to notify us of any inaccuracy in your information and to promptly

correct your profile information or request rectification of your information. In some instances, we

will request additional data from you to verify the authenticity of your requests, including your

request to delete or modify your personally identifiable information or personal data, such as your

name, username and password, and email address.

14.

Communications - Data Security Office

All requests and complaints regarding our processing or use of your personally identifiable

information or personal data must be directed to our Data Security Office using the information

provided below. We will respond to your requests for the exercise of your rights in the time

required under applicable laws, giving due regard to our overriding obligations.

Ratetopix Corp

Data Security Office

mail@ratetopix.com