This Privacy Policy discusses the information that we collect about you through your use of SETVI’s websites and mobile and online services (“SETVI Services”), how we may use this information, and the security approaches we use to protect your information. This Privacy Policy is made part of and incorporated into SETVI’s General Terms and Conditions of Use, which govern your use of the SETVI Services.

By using the SETVI Services or by providing us with any Personally Identifying Information, you consent to the collection and use of your information by us in accordance with this Privacy Policy.

WHAT INFORMATION WE MAY COLLECT

Personally Identifying Information

Personally Identifying Information (“PII”) is information that can be used on its own or with other information to identify, contact, or locate a single person. Your submission of and our handling of PII is governed by this Privacy Policy.

User Information

When you register as a user of the SETVI Services or any component thereof, we may ask you to provide certain information, including PII such as your name, e-mail address, phone number and organization. Your account administrator may also provide PII about its users. We collect information about your uses of the SETVI Services as they occur. We use IP addresses and session identifiers to analyze trends, to administer the sites, to track user activities, to infer user interests, and to otherwise induce, deduce, and gather information

about individual users and market segments.

Product and Customer Data

To the extent your use of the SETVI Services includes inputting and/or uploading product data, such as descriptions, catalogs, images, prices and inventory, or customer data such as customer names, lists, contact information, records, and the like, we will store that information for your use in the SETVI Services.

Transaction Data

To the extent your use of the SETVI Services includes the inputting, processing, or completing of transactions, transaction information, sales data, or sales presentation data, we will store that information for your use in the SETVI Services and for the completion of the functionality related thereto, including, but not limited to, providing analytics.

Cookies

We may automatically gather information (including technical and/or usage information) when you access certain SETVI Services, such as SETVI websites, including through the use of cookies. Cookies are small data files saved to your computer or device by your web

browser that enable the site’s or the service provider’s systems to recognize your browser and capture and remember certain information. Cookies help us serve you better by storing certain information relevant to your use of our products or services. We may use session or persistent cookies to enhance your user experience in this way. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. 

You can choose to disable cookies through your browser settings. Each browser is different, so look at your browser Help menu to learn the correct way to modify your cookies. If you disable cookies, certain features of the SETVI Services may be unavailable to you or may not function properly.

Do Not Track

Because there is not yet a common understanding of how to interpret web browser-based “Do Not Track” (“DNT”) signals other than cookies, we do not currently respond to undefined “DNT” signals to any of our websites or services.

HOW WE USE INFORMATION WE COLLECT

Use of PII

We may use your PII for the following purposes:

• To monitor and provide the SETVI Services.

• To respond to your requests.

• To customize your experience based on your interests.

• To maintain your account.

• To investigate and enforce our rights and the rights of third parties.

• To administer a promotion, survey or other feature.

• To contact you in connection with the SETVI Services.

Use on Non-PII

We may, in our sole discretion, use and retain non-personal, non- individually identifiable information collected, submitted or derived, whether from PII or otherwise, individually or in the aggregate for any business purpose, including but not limited to selling, renting, or disclosing to third parties.

HOW WE MAY DISCLOSE THE INFORMATION

Required Disclosure of PII

We may disclose your information and any materials you upload when we believe release is appropriate to comply with the law; respond to subpoenas, legal document requests, or court orders; enforce our General Terms and Conditions of Use or this Privacy Policy; protect ours or others' rights, property, or safety; or prevent fraud or abuse of the SETVI Services.

Disclosure to Outside Parties We generally do not sell, trade, or otherwise transfer to outside

parties your PII unless we provide you with advance notice, except as described herein. We may, however, share non-PII about our users, individually or in the aggregate, with outside parties. The term "outside parties" does not include our affiliates and website hosting partners and other parties who assist us in operating the SETVI Services, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.

Corporate Transaction

In the event that we sell our company, or otherwise transfer any assets of our company, we may provide your information to the purchaser so that you may continue the relationship or business with us and our products and services.

HOW WE MAY RETAIN THE INFORMATION

Except to the extent otherwise expressly set forth in writing by SETVI, we may dispose of and permanently delete information, including, but not limited to, uploaded files, data, and PII, in our discretion and without notice, subject to applicable law that specifically requires the handling or retention of information. We may retain and use your information for as long as we have any reason, in our discretion, to do so, including, without limitation, to provide you services, to comply with our legal obligations, to resolve disputes and to enforce our

agreements. Except to the extent otherwise expressly set forth in writing by SETVI, we do not undertake specified retention obligations for individual user data.

SAFEGUARDING THE INFORMATION

We use generally accepted standards to safeguard and help prevent unauthorized access to your information. This includes the use of Secure Sockets Layer (SSL) encryption in the transmission of data through the submission forms and other mechanisms in the SETVI

Services. We store data in a data facility having reasonable and customary physical, electronic and software security. However, no commercial method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, we

cannot guarantee the absolute security of that information during its transmission or its storage in our systems, but we will use all reasonable efforts to do so.

PRIVACY AND THIRD PARTY LINKS

This Privacy Policy applies solely to information collected through the SETVI Services. In an attempt to provide you with increased value, we may include third party links on our sites and services. These linked sites have separate and independent privacy policies. We

therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of the SETVI Services, including any links, and therefore request any feedback (including if a specific link does not work).

USE OUTSIDE OF THE UNITED STATES

It is important to note that the SETVI Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the SETVI Services and/or providing us with any information, you consent to this transfer.

CHANGES TO THIS POLICY

This Privacy Policy shall be available at:

http://www.setvi.com/privacy-policy/

This Privacy Policy may change from time to time. If we decide to change this Privacy Policy, we will post those changes on the website listed above. You should therefore visit that website from time to time to review this Privacy Policy as it may be updated. By continuing to use the SETVI Services after those changes are posted, you agree to be bound by the revised Privacy Policy.

CONTACTING SETVI

You may contact us for account support through our web support system by visiting: http://support.setvi.com

You can correct or update your PII by updating your profile, by contacting your account administrator or by contacting us as described above.