Privacy

Privacy Policy

As of January 20, 2022, SBA Edge, LLC, including any subsidiaries and affiliates (collectively, "SBA", "we" or "us") is committed to protecting your privacy and developing technology that gives you the most powerful and secure online experience. This Privacy Policy (the "Privacy Policy") explains how the SBA collects and uses information about you. It applies to data collection through the SBA Site and any other website that links to this Privacy Policy (the "Site" or "Website"), as well as offline data collection. Please note that if you are visually impaired, you can access this notice through your browser's audio player.

APPLICABILITY

This Privacy Policy is a statement of how information about you is collected, used, and potentially shared by SBA. Specifically, this Privacy Policy will tell you:

• what personal information we collect;
• what your choices are regarding your personal information;
• how we use your personal information and with whom we share it;
• your consent to the collection, use and disclosure of personal information;
• how you can access your personal information for review and updating;
• how we retain and dispose of your personal information; and
• how we protect your personal information.

Personal information is any information that directly and indirectly identifies an individual user or that can reasonably be linked to a specific person, computer or device ("Personal Information"). Such information includes, but is not limited to: (i) your name; (ii) postal address; (iii) telephone number; (iv) financial account information; (v) social security number; (vi) e-mail address; and (vii) other similar information.

1. CHANGES

SBA reserves the right to change this Privacy Policy at any time in its sole discretion. If we do so, we will update the "effective date" at the top of this Privacy Policy and notify you of any material changes by displaying a prominent notice at the top of the SBA website or by sending an e-mail directly to you. Changes, revisions or deletions with respect to this Privacy Policy will be effective immediately upon their inclusion in or deletion from this Privacy Policy and the posting of the same in this Privacy Policy on the Site.

You are encouraged to revisit this Privacy Policy from time to time to review any changes that have been made. Your continued access and use of the site following the posting of any such changes shall indicate your acceptance thereof.

2. PURPOSES AND USES OF YOUR PERSONAL INFORMATION

We generally use your personal information for the following purposes:

• as required by law;
• as necessary for the performance of a contract with you and our business partners to run our website;
• to deal with contact and user support requests sent via forms on our website or e-mail;
• to improve our services and the Site;
• carry out marketing campaigns;
• to ensure the security of our website; and
• with your explicit and informed consent.

We will only use your personal information for the purposes for which it was originally collected. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so. Please note that, where permitted by law, we may process your personal information without your knowledge or consent if we believe it is reasonably necessary to comply with applicable laws.

3. TYPES OF PERSONAL INFORMATION COLLECTED AND PURPOSES OF COLLECTION

We will only collect personal information about you that is adequate, relevant and limited to what is necessary.

SBA account setupWhen you sign up for an account with us, we ask for and collect personal information, such as your name, valid e-mail address, physical address, telephone number and online identifiers. We also collect payment details to facilitate the customer billing process. In some cases, and in some jurisdictions, we may also collect your government identification number (e.g. social security number, driver's license number, passport number or similar government identifier), utility provider details, and information about leases or other contracts relating to real estate or property to which you may be a party. We use this information to provide you with account-related functionality. Accounts can be used to manage your SBA services. Providing this information is necessary to create an account and use our services. We may not be able to create your account or provide our services if you do not provide this information.

Website forms. If you express an interest in receiving information about our services using any of the forms on our website, we collect the information you enter into the forms. We collect this information in order to respond and communicate with you about your requests. Providing this information is voluntary.

Support Request Information. We keep your personal information associated with customer support requests and queries to keep track of who dealt with your problem and whether and how it was resolved.

Automated Information. We automatically receive and record information from your browser about the devices you use to access our website. This includes things like IP addresses, the type of browser and device you use, your language settings, the web page you visited before accessing our websites and identifiers associated with your devices. We use "cookies" and various other tracking technologies (for example, cookies and beacons) to collect and store information about your use of our website, your interactions with content on our website and your interactions with our online advertising efforts. We use these tools to ensure that you receive a personalized experience and to keep your account secure. Please refer to the Cookies and Other Tracking Technologies section of this Privacy Policy for more information.

Employment information. If you apply to a job posting or become an employee, we collect the information necessary to process your application or retain you as an employee. Depending on the jurisdiction in which you and/or the position for which you are applying, this may include your contact information, nationality, government identification number (such as your social security number or equivalent government identifier), demographic information, information about your education, medical, financial, criminal history, employment history, training records and other information that may be necessary to facilitate our evaluation of your application for employment. Providing this information is generally necessary to process your application. We use information about applicants and current employees to perform our employment contract or the anticipation of an employment contract with you. In some contexts, we are also required by law to collect information about our employees. We also use your information for the purposes of efficient personnel and workforce operations.

Business contact information. If you or your employer correspond with us regarding a business opportunity or enter into a business relationship with us, we collect the information necessary to facilitate that correspondence and/or relationship, such as your name, contact information and job title. We may also collect payment information, credit card or corporate credit card number, billing address, billing information and other payment details. We use this information to negotiate or execute service agreements or other contracts. In addition to the information we collect directly from you, we may also receive information about you from other sources, including third parties, business partners, our affiliates or publicly available sources.

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

We use common tracking technologies such as e-mail tracking, log files, web beacons and cookies to automatically collect information about you, which may contain personal information. This information is used to analyze how our website is used, to ensure the security of our website and to improve our services.

Log files. Directly or through our hosting service provider, we may automatically receive and record information from your Internet browser, including your IP address (the Internet address of your PC), the name of your computer, the type and version of your Web browser, referring addresses, where the computer is routing from and other generally accepted log information. We may also record page views (hit counts) and other general statistical and tracking information which will be aggregated with information about other users to understand how our site is being used and for security and monitoring purposes.

Email tracking. We may send emails that use a "click URL" linked to the content of our website. When you click on one of these URLs, you pass through our web server before reaching the destination page. We track this click information to help determine interest in specific topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply do not click on text or graphic links in the email or notify us as set out below (Changing or removing information; Opting out).

Web beacons. We may track your browsing on our websites via beacon as a means of tracking your web traffic patterns. We may also track this activity in connection with third-party traffic monitoring and services, which may also be used in connection with cookies to understand web activity and behaviors.

Cookies. As mentioned above, the SBA uses "cookies" to track and store information about Local on the Internet Users. "Cookies" are alphanumeric identifiers in the form of text files that are inserted and stored on your hard disk. Cookies track your personal preferences and activities. If you do not wish cookies to be placed on your hard drive, you can disable your ability to accept and receive cookies via your web browser. However, please keep in mind that if you disable your hard drive's ability to accept and receive cookies, you may not be able to fully utilize all of the additional conveniences and features of the Internet Site. The SBA uses cookies on your website for the following purposes: to better serve you by remembering your user preferences; to improve our site; to make our site function properly; and to provide a safe browsing experience while using our site.

We use the following types of cookies on our website:

Strictly Necessary Cookies. These cookies are essential because they allow you to browse our website and access its secure areas. Without these cookies, some functionalities of the site will not work properly. These cookies do not collect information about you for marketing purposes. This category of cookies is essential for the functioning of our website and cannot be disabled.

Functional Cookies. We use functional cookies to remember your choices so that we can tailor our website to provide you with enhanced features and personalized content. For example, these cookies may be used to remember your name or preferences on our website. We do not use functional cookies to target you with online marketing. Although these cookies can be disabled, this may result in less functionality when using our website.

Performance or analytical cookies. These cookies collect anonymous passive information about how you use our website, including web pages you visit and links you click on. We use the information collected by these cookies to improve and optimize our website. We do not use these cookies to target you with online marketing. You can disable these cookies.

Third-party cookies. We engage in behavior-based advertising, which means that a third party uses cookies to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website or on other websites.

Your choices

Your browser may give you the option to refuse some or all browser cookies. You can also remove cookies from your browser. You can exercise your preferences regarding the cookies served on our Site by following the steps described below.

Primary cookiesYou can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located in the "Help", "Tools" or "Edit" settings). Please note that if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies, other parts of the Services may not function properly. You can find more information on how to change your browser's cookie settings at http://www.allaboutcookies.org.

Third-party cookies. To disable third-party advertising networks and similar entities that use advertising cookies, visit http://www.aboutads.info/choices. After clicking on the link, you can opt out of receiving this advertising from all participating advertising companies or only from advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, see http://www.aboutads.info/consumers.

We do not control the collection or use of your information by third parties to serve interest-based advertising. However, these third parties may provide you with ways to opt out of their collection or use of your information in this manner. In addition, most web browsers provide help pages relating to setting cookie preferences. More information can be found for the following browsers here:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (desktop)
• Safari (Mobile)
• Android browser
• Opera
• Opera Mobile

Do not track. Some Internet browsers, such as Chrome, Internet Explorer, Firefox and Safari, include the ability to transmit "Do Not Track" or "DNT" signals (e.g. Chrome Incognito). As uniform standards for "DNT" signals have not been adopted, our Site does not currently process or respond to "DNT" signals.

5. SHARING PERSONAL INFORMATION WITH THIRD PARTIES

If we have collected your personal information, we will not disclose it to third parties without your consent, except in the following circumstances:

Business partners. We employ other companies to perform functions on our behalf, such as maintaining the site, collecting information, sending and responding to e-mail, and other functions necessary to support SBA, the site, and the products and services we offer. We will provide our business partners with only the Personal Information necessary to perform their functions and instruct them not to use your information for any purpose inconsistent with this Privacy Policy. We require the companies we work with to contractually agree to comply with privacy laws and maintain protections for personal information consistent with this Privacy Policy.

Harm Issues. We may disclose your Personal Information on a case-by-case basis to attorneys, private investigation organizations or law enforcement agencies if we believe that you are: (i) at risk of harm from third parties; (ii) harming or interfering (or harming or interfering) with others; or (iii) violating (intentionally or unintentionally) our Terms of Use or other legal obligations.

Within our corporate organization. We may share your personal information with our subsidiaries and affiliates to provide you with the Site or services and take action based on your request, as well as for management and analysis purposes. For example, we may share your information with our subsidiaries and affiliated companies to administer our loyalty programs, process orders and requests, and expand and promote our Site and services.

 Legal. We will disclose Personal Information about you to the extent we reasonably believe we are required to do so by law. If we receive legal process requesting disclosure of your Personal Information, we may attempt to notify you via the contact information you have provided (if any) within a reasonable time before we respond to the request, unless such notification is not permitted. In addition, we may share your personal information with third parties as permitted by law to, for example, protect against fraud, the confidentiality or security of our business records or to comply with applicable legal requirements.

Transfer of ownership. We will have the right to transfer Personal Information to a third party in connection with a sale or merger of a Site or business unit. If we transfer your Personal Information, we will do so in accordance with this Privacy Policy, provided that the acquiring third party has agreed to protect your Personal Information with protections that are, in all material respects, equal to or more protective than those set forth in this Privacy Policy.

Consent. We may disclose your personal information for any purpose with your consent.

6. YOUR CHOICES AND RIGHTS IN RELATION TO PERSONAL INFORMATION

We give our users appropriate control over their personal information. You can contact us to change or update discretionary information that you have previously submitted. See the Contact Us section below for our contact information. If we send you newsletters, updates, surveys or other communications related to marketing materials, we will provide you with the ability to decline - or "opt-out" - of receiving such communications. Instructions for opting out will be provided if and when we decide to send you such communication. Please understand that you will not be permitted to "opt-out" of formal notices regarding the operation of this site and legal and other notices relating to your relationship with the site. Additional Rights for Individuals Located in Certain Jurisdictions In some circumstances and jurisdictions, we may be subject to data protection laws that grant you additional data protection rights depending on where you are located. To the extent required by these applicable laws, we will grant you the rights listed below, provided that we can adequately verify your identity:

• Access to your personal information. You can request confirmation of and access to the personal information we hold. If permitted and required by law, we will confirm whether we hold or process your personal information and grant you reasonable access to the data we hold about you.
• Retention and deletion of your personal information. We normally retain your personal information for the period necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of data or request that we delete your personal information by contacting us at the address described below. If permitted to do so and to the extent required by law, we will grant a request to delete personal information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, in pursuit of a legal claim, to detect or monitor fraud, resolve disputes or enforce our agreements with you. In addition, please understand that if you request the deletion of your information, you will not be able to use the associated features of the site and any associated services. You cannot remove de-identified, anonymous or aggregated data from our databases.
• You may have the right to object to the use of your personal information. You may have the right to object to direct marketing and, in some circumstances, the right to object to certain automated processing operations.
• Right to Restrict Processing. You may have the right to object to the processing of your information in certain circumstances, for example where: (i) you contest the accuracy of your information; (ii) your personal information is being or has been unlawfully processed; (iii) we no longer need to process your information, but you need your information in connection with a legal claim, or (iv) you object to processing pending verification whether there is a legitimate reason for such processing.
• Right of rectification. You may have the right to request the rectification or correction of inaccurate or incomplete personal data concerning you.
• Right to Data Portability. You may have the right to request to receive your information in a structured, commonly used and machine-readable format in certain circumstances.
• Revocation of consent. You may revoke any prior consent to the processing of your personal information if we process your data on the basis of consent. If you revoke your consent, we may no longer be able to process your personal information or provide the part of the service that relies on such consent. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so.

For more information on your privacy rights, see Information for Specific Jurisdictions below. To exercise any of the above rights that may apply to you, please send your request to us using the information on the Contact us section below. If you are not satisfied with our response, you may have the right to lodge a complaint with your local supervisory authority or government privacy regulator.

7. INTERNATIONAL TRANSFERS

Your personal information may be stored and processed in any country where we have offices or servers or in which we contract service providers. Your personal information may be transferred to countries outside your country of residence, including the United States, which may have different data protection and processing laws to those in your country. Any such transfer should only take place in accordance with and as permitted by the law of your jurisdiction, but please be aware that the laws and practices relating to the protection of personal information are likely to be different from, and in some cases may be weaker than, those within your home jurisdiction. Regardless, in all cases, we will apply the provisions of this Privacy Policy to your Personal Information wherever it is located. If you have questions about international transfers, please contact us using the information at Contact us section below.

8. SECURITY OF YOUR PERSONAL INFORMATION

SBA uses commercially reasonable physical, administrative and technical safeguards to protect the security of any Personal Information submitted by you through our Site. One of these safeguards is the HTTPS protocol that we use to ensure that your Personal Information is kept confidential.

Our security systems are structured to prevent unauthorized access to the personal information you provide us. Please understand, however, that information processing activities can never be 100% secure. Due to the nature of Internet communications and evolving technologies, we cannot provide and disclaim assurance that the information you provide to us will remain free from loss, misuse or alteration by third parties who, despite our efforts, gain unauthorized access.

9. RETENTION

We will process and retain your personal information for as long as your account is active or for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. After retention periods expire, we delete your personal information or prevent any further use of it.

10. LINKS TO THIRD-PARTY WEBSITES

The SBA website may contain links to other websites. This Privacy Policy applies exclusively to our Site, and SBA makes no representations or warranties about, and is not responsible for, the privacy practices of other sites. When you enter a linked site, SBA encourages you to read the privacy policy of that linked site, as its privacy policy may differ substantially from that of the site.

11. CHILDREN'S PERSONAL INFORMATION

We do not knowingly or intentionally collect personal information from minors. If you are under 18, you may use our website only with the consent of your parent or guardian. Please contact us if you believe that we have collected personal information about a child without consent, so that we can take appropriate action and delete it.

12. CONTACT US

We encourage you to provide us with feedback on this Privacy Policy. If you have any questions, comments or concerns about this Privacy Policy, please email us at dpo@sbaedge.com. If you are located in any of the jurisdictions listed in the section below, you can also contact us using the contact information found on the specific jurisdiction's page.

13. INFORMATION FOR SPECIFIC JURISDICTIONS

If you are located in any of the countries or jurisdictions listed below, please click on the links for more information about your privacy rights and how to contact us: