Privacy Policy

Effective date: July 01 2024

Introduction

Adaptive Search FZ-LLC (the “Company”, “we”, “us”, “our”) is providing this Privacy Notice (the “Notice”) to describe
how we collect, use, protect and share your personal information to ensure that the relationship between us and our
customers is based on trust. We are guided by fair information principles that include respect for the rights and
freedoms of visitors to our website.

In this Notice, personal information means any information that identifies you or is linked to you.

This
policy is organized into the following sections and topics:

The personal Information we collect about you
How and why we share your personal information
How we protect your personal information
Cookies and other trackers
Children’s privacy
Privacy Rights
Additional U.S. state privacy rights and choices
How can you exercise your privacy rights?
Additional information for the residents of the European Union, European Economic Area, the United Kingdom
Changes to this Notice
Contact information

The personal information we collect and how we use it

Personal information you provide directly to us.

When you contact us directly, for example, by sending us an email or filling out a form on our site, we collect some
or all of the following categories of personal information:

Any personal information or contact information you provide in your message to us, including your name, email, phone
number and the contents of your message when you fill out a contact us form or send an email. We use this information
only to respond to your inquiry.

If you exercise your rights to opt out of the sale or sharing of your personal information, or opt out of targeted
advertising or profiling, or you request a deletion or correction, we receive some personal information about you. We
use this only to fulfill your request.

Personal information we collect automatically.

We receive certain categories of personal information automatically when you use our website:

When you visit our site, we automatically receive your Internet Protocol, or IP address. We use this to deliver
content and advertising to your device, and it also permits us to determine your general geographic region. We do not
keep your entire public IP address (though it may be shared with some of our business partners. We also receive
information about the type of browser and device you are using to access the site and settings and preferences stored
in your browser, such as your preferred language. We use this to ensure we display content and advertising in the best
way for you.

We sometimes place small pieces of code called cookies on your computer that allow us to recognize your browser or
device and follow its activity on our site. We may also receive pixels or other tracking devices or identifiers from
the page or service from which you access our site. We do not use this information to create a profile of you or
your online behavior. We use these identifiers and trackers to collect information about user behavior on our site
generally and to recognize your device if you have visited our site before. This allows us to understand and improve
our site and develop new sites and products. It also provides us with information about how engaging and effective
our advertisements are so that we can report that to advertisers. For example, we observe how many users click on an
advertisement and report on that to the advertiser.

Personal information we collect from third parties

Sometimes the web page you were visiting before you visited our site sends us information about that site, such as
its web addresss, or URL. Sometimes information about your search or other previous online activity is included. This
helps us understand what drives users to our site.

Social media sites or other services may include their own user identifiers. We cannot directly identify you through
these identifiers, though the site that created them may use them to link your activity on our site to the information
they have about you.

Advertisers may send us information about the general types of users they expect to engage with their advertisements.
However, we do not collect or process any sensitive or special categories of personal information such as information
about your health, your race, your religion, or your political affiliation.

Our site is directed to general audiences. We do not knowingly collect or process any information of children.

We also rely on third-party service providers to help us determine the general geographic area you are visiting our
site from based on your IP address.

How and why we share your personal information

We share the following categories of personal data with the following categories of third parties for the following
purposes:

We share information about your browser, device, and behavior with service providers that help us deliver content and
advertising to you. When a company we work with is a “service provider” or processor, rather than a third party or
controller, we ask it not to retain or use for its own purposes the information it processes on our behalf.

We share aggregate information about user interaction with advertisements with our advertisers and their business
partners (“advertising partners”) to help them improve their ad selection and delivery. We pass class C IP addresses,
which do not identify individual users or devices, to advertising partners in some cases to help deliver
advertisements to you.

We share personal information with regulators, law enforcement, and other government authorities when required to do
so by law.

We share personal information with authorities or others when necessary to protect the safety, rights, or freedom of
our users or others.

We share personal information when we need to use it to defend or assert our legal rights or assist others in doing
so.

Universal opt-out signals

We honor certain universal opt out signals, including “Global Privacy Controls” that can be set in some browsers
where we are required to do so by applicable law.

Do Not Track

We do not honor “Do Not Track” signals that do not meet the requirements of universal opt out signals in the
applicable jurisdiction, or where we are not required by law to honor them.

Google Analytics

We sometimes use Google Analytics for site analysis. For more information about Google Analytics go to http://www.google.com/policies/privacy/partners (“How
Google uses data when you use our partners’ sites or apps”). Users who don’t want their data collected and disclosed
to Google Analytics can install the Google Analytics opt-out browser add-on. To opt out of Google Analytics, go to https://tools.google.com/dlpage/gaoptout.

How we protect your personal information

We seek to protect personal information using technical and organizational measures based on the type of personal
information and applicable processing activity. We are committed to minimizing personal information collection to the
information that is necessary for some defined purpose. As part of our effort to safeguard personal information
collected from you, we implement information security measures, including:

Having comprehensive security policies and procedures.
Limiting the amount of personal information that we collect to strictly necessary only.
Using ssl or other secure connection technologies when receiving or sending personal information beyond internal
networks.
Deleting personal information when it is no longer needed or in accordance with our standard data retention
schedule.
Performing regular information security risk assessments.
Mitigating risks by following a risk reduction plan.
Providing regular information security awareness training to our employees.
Limiting access to personal information to those whose jobs require it.
Implementing and monitoring intrusion prevention and detection systems.
Technologically separating systems containing personal information from public networks such as the internet.
Maintaining up-to-date software and safeguards.

How Long We Keep Your Personal Information

We keep your personal information for only as long as we need it.

We keep IP Class C IP addresses, which do not identify individual users or devices, for no more than 5 years.

We keep browser and device information for up to 5 years.

Cookies that we place on user devices, expire after 3 months, along with the information (such as browser history)
associated with them.

We keep aggregated information that can no longer be associated with a person or device for longer.

Cookies and other trackers

Our website uses certain tags, log files, web beacons, cookies, and similar trackers from third parties
(collectively, “Trackers”), that you should be aware of.

Cookies are small data files stored on your hard drive or in device memory that can allow information about your
online activities and your preferences and choices to be stored on your browser and communicated to websites and
others. Some cookies are necessary to allow web pages to properly display the information you want. You can reject
other non-essential cookies by changing the settings in your browser, but if you do this, some choices (including
opt-outs from tracking) may also be lost. Turning off cookies in your browser will not prevent information collection
on a different browser or device used by the same person, or through apps or mobile identifiers. To prevent
information collection through your mobile device, you must go to settings on the device and turn off information
collection for advertising.

For more information about cookies and other identifiers, including how to see what cookies and other tracking tools
have been set on your device and how to manage and delete cookies and other trackers, visit www.allaboutcookies.org, www.aboutidentifiers.org and www.youronlinechoices.eu.

To see the types of cookies used on our site, see our list of cookies.

Children’s privacy

We do not knowingly collect, use, or disclose personal data from children under 13, or, where required by law,
children under 16. If you believe that we have collected, used, or disclosed the personal data of a child under the
legally mandated age, please contact us using the contact information provided in this Notice, so that we can take
appropriate action.

Privacy rights

Access, correction and deletion of personal information

You have the right to access, correct, and delete your personal information. If you have any questions about your
rights, or you would like to exercise any of them, please e-mail: privacy@adaptivesearch.com.

Right to know

You have the right to request certain disclosures about our processing of your personal information.

You may request the disclosure of the following:

the categories of personal information we have collected about you.
the categories of sources from which the personal information is collected.
the business or commercial purpose for collecting, selling, or sharing personal information.
the categories of third parties to whom the we have disclosed personal information.
in some cases, the specific pieces of personal information we have collected about you (with certain limitations)

No retaliation or discrimination

We do not discriminate against a consumer because of the exercise by the consumer of any of their privacy rights.
right to access, deletion or opt-out from sale or sharing of your personal information. This means that we will not
Deny goods or services to you.

Charge you different prices or rates for goods or services.
Provide you a different level or quality of goods or services.
Suggest that you will receive a different price or rate for goods or services or a different level or quality of
goods or services.

Additional U.S. state privacy rights and choices

If you are a California consumer, you have the right to:

know what information we have collected about you, ask us to delete your personal information;
ask us to delete your personal information;
ask us to correct personal information if you believe we are keeping inaccurate information about you; and
opt-out of the sale or sharing of your personal information, including by sending a Global Privacy Control (GPC)
signal from your browser.

We will not discriminate against you in any way for exercising these rights.

You can exercise these rights by emailing us at privacy@adaptivesearch.com. If you have a business account with us,
we may use information in that account to authenticate you.

For certain requests (requests to know or correct the information we maintain about you) we may email you to confirm
your identity. If we cannot confirm your identity for a request to delete information, we will treat it as a request
to opt out of sale and sharing. An authorized agent may make requests on your behalf, but we will request proof that
you gave permission for that agent to act for you.

If you are a Virginia, Connecticut, Colorado, Oregon, Texas, or Utah consumer, (or, beginning in October
2024, a Montana consumer), you have the right to:

Confirm whether or not we are processing your personal information and access your personal information;
Correct inaccuracies in your personal data and the purposes for which we are processing it;
Delete your personal information;
Obtain a copy of personal data you have previously provided to us, or in some states, all the personal data we
have obtained about you, in a form that allows it to be shared with another controller;
Opt out of targeted advertising
Opt out of the sale of your personal information;
Opt out of profiling that would be used for significant decisions about you.
If and when global privacy controls or other universal opt-out mechanisms are approved and honoring them is
required in your state, you will also have the right to opt-out of sale, targeting, or profiling, or all of these,
using these browser-based controls.

For certain requests, we may email you to confirm your identity. You can exercise these rights by emailing us at
privacy@adaptivesearch.com.

We will not discriminate against you for exercising these rights.

Authorized agent

If you would like an authorized agent to make a request for the disclosures, deletion or correction on your behalf,
the agent may do so by emailing us at privacy@adaptivesearch.com. Upon receipt of a request by an agent, we will ask
the consumer for written, signed permission that the agent has been authorized by the consumer to act on their behalf.
Once written authorization is provided, we will start processing the request. We will respond directly to the e-mail
address provided by the authorized agent regarding the fulfillment of the request.

Additional information for the residents of the European Union, European Economic Area, the United Kingdom

Contacts

For the purposes of EU/UK data protection regulations Adaptive Search FZ-LLC is the controller of this website.

You may contact us at Privacy@adaptivesearch.com if you have any questions or complaints about our data protection
practices. You may always contact your local data protection authority as well.

You can reach our European and UK representative at:

Rickert Rechtsanwaltsgesellschaft mbH
– Adaptive Search FZ-LLC –
Colmantstraße 15
53115
Bonn
Germany
art-27-rep-2-24@rickert.law

Why do we collect your Personal Data?

In the European Union, we rely on three different legal bases for processing data—your consent, our legitimate
interest, and as required by contract. We process your personal data for the following purposes and lawful basis:

We use Consent as our lawful basis for processing your personal information for these purposes:
- To Store and/or access information on a device We obtain your consent to place or obtain
  information
  from cookies, identifiers or trackers on your device.
When we use legitimate interest as the legal basis for processing personal information, we first weigh whether the
risk that the processing poses to data subjects outweighs the benefits we (and you) obtain through our processing
the data. We use Legitimate Interest as our lawful basis for processing your personal information under these
purposes:
- Use limited data to select advertising. When we use only information such as the content of
  the
  page you are visiting to seect advertising to display to you, we have determined that the risk to you is minimal
  and
  the benefit of your receiving free, ad-supported content with related advertising outweighs that risk.
  Similarly,
  using personal information to limit the number of times you see an ad or measure how well the ad attracts your
  interest and the interst of others (ad performance) improves your experience and creates very little risk to
  you.
- We use a very limited amount of personal information to maintain and improve our services, and we also believe
  that the benefits of this outweigh any risk to you from our processing this small amount of personal
  information.
  Develop and improve services: Information about your activity on We also rely on our legitimate
  interest to maintain the security and functionality of the website.

Your Rights

Refer to the “How can you exercise my privacy rights section?” of this Notice or contact our Privacy Office via
e-mail: privacy@adaptivesearch.com.

Withdrawal of Consent

You have the right to withdraw consent at any time for the personal data processing purposes where we rely on your
consent.

International Transfer of Personal Data

Our website and technology infrastructure is primarily maintained in the United States. If you are visiting our site
from the regions with laws governing data collection and use that may differ from those in the United States, please
note that you may be transferring your information to the United States and other countries around the world. When you
use this site, you acknowledge and agree that you are providing your personal information to countries that may not
have the same level of data protection as your country. If you are situated in the EU, EEA, or UK, whenever we
transfer your Personal Data out of the EU, EEA, UK, we ensure appropriate and suitable safeguards are used and we rely
on legally valid transfer mechanisms, such as Standard Contractual Clauses. Where we use certain service providers, we
may use specific contracts, including data processing agreements based on the EU/EEA Standard Contractual Clauses,
along with supplemental security measures, to ensure personal information is protected.

Changes to this Notice

We may update this notice periodically to reflect changes in the law or our practices. We will not change the way we
use personal information we have already collected under this policy without notifying you and obtaining your consent.

Contact information

If you have any comments or questions in connection with this Notice, or for further information on our personal
information processing practices and your rights in relation to your personal information, please contact us here.