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Privacy Policy

Last Updated: March 19, 2020

Relay Platform, Inc. (“Relay” or “we”) respects your right to privacy. This Privacy Policy applies to personal information that Relay collects, shares and uses and how you can exercise your privacy rights.

Relay offers a Software-as-a-Service solution for risk transfers and other workflow software solutions for the insurance and reinsurance markets (our “Services”). For more information about Relay, please see https://www.relayplatform.com (our “Site”).

INFORMATION WE COLLECT AND WHY WE COLLECT IT
In general, we collect personal information from or about you for the purposes described in this Privacy Policy or for purposes that we explain to you when or before we collect your personal information. We also may use your personal information for other purposes that are not incompatible with the purposes that we disclose to you but only when permitted by applicable laws.

1. We collect the information that you provide to us.
When you use our Site or Services, we may ask you to provide certain personal information and other information.

Personal Information that Relay Collects Why Relay Collects the Personal Information
Business Contact details, including name, telephone numbers, email address and postal address.
o To respond to your correspondence and requests and otherwise communicate with you
o To complete your subscription for the Services
o For billing purposes
o To obtain your feedback regarding our Site or Services
o To send you information about our Services that we think will interest you
User credentials, including name, email address, job title, office address, device type and ID and other personal information that you or your employer choose to provide to us. o To set up and maintain your account
o To monitor and enforce compliance with our Terms of Service or other agreement with you or your employer
o For customer service and support for our Services
Information you give us when you fill out an on-line information request form or send us an email. o To respond to your request in the form or email
o To learn more about your products or services if you are a prospective or current vendor or service provider
o To process your application if you apply for a job with us

Users of the Services also may upload personal information when requesting a quote or sharing materials. Relay does not review this uploaded information to determine whether it contains personal information and processes the uploaded information only as necessary to provide the Services for users of the Services, as described in the Relay Terms and Conditions https://www.relayplatform.com/relay-platform-terms/ . If you have questions about whether one of Relay’s customer has uploaded your personal information to the Services, please contact that customer.

2. We automatically collect information when you use the Site or Services.
We automatically collect certain information from your computer or mobile device when you use the Site or Services. Some of this automatically collected information is personal information under certain laws.

The information that we automatically collect includes:
• Information about how your computer or device interacts with our Site and Services, including the date, time, search requests and results, the pages accessed and links clicked
• IP address, broad geographic location (e.g., country or city-level location which Relay derives from other data), device type, device identification number, browser type, operating system and other technical information

We use this automatically-collected information:
• To provide the Site and Services
• For pricing and billing purposes
• To better understand how the Services are used so that we can update and improve the quality of the Services and develop new ones
• For our analytics purposes, such as to track usage of our Site, to measure the number of unique visitors to the different sections of our Site, to understand how people find our Site and to help us make our Site and marketing more useful
• To send you information about our Services that we think will interest you
• To address suspected or detected unauthorized and illegal activity on or through the Services, such as scraping or fraud, prevent recurrence and design countermeasures
• Detect security incidents
• Identify and repair bugs in the Services

Some of this information is automatically collected using cookies and similar tracking technology. See our NOTICE ABOUT COOKIES AND TRACKING TECHNOLOGY below.

3. We collect information from third party sources
From time to time, we may receive personal information about you from third-party sources, which include:
• Your employer which may provide us with your business contact information in connection with use of the Services on behalf of your employer.
• Marketing partners that help us identify individuals who may be interested in learning more about the Services and to supplement personal information we already have about you, such as when we acquire an email list from a marketing partner
• Resellers and other business partners that may share personal information with us when we offer “white label” access to the Services.

We only accept personal information from third parties when we have confirmed that these third parties have your authorization or are otherwise legally permitted or are required to disclose your personal information to us.

HOW RELAY SHARES PERSONAL INFORMATION
We may disclose your personal information to the following categories of recipients:
• Service providers, such as payment card processors, that help us provide the Services and Site for you;
• Marketing partners that help us identify individuals who may be interested in learning more about the Services and to supplement personal information we already have about you, such as when we acquire an email list from a marketing partner
• Competent law enforcement, regulatory or other government agencies, courts or other third parties when we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• Potential acquirers and their agents and professional advisers in connection with any proposed purchase, merger or acquisition of any part of our business. We will inform the buyer that the terms of this Privacy Policy apply to your personal information;
• With resellers and other business partners with which we share personal information in order to offer “white label” access to the Service; and
• Any other person with your consent to the disclosure.

NOTICE ABOUT OUR USE OF COOKIES AND SIMILAR TRACKING TECHNOLOGY
We use cookies and other data tracking technology to collect and use personal information about you. We also may allow others to use cookies and similar technologies (e.g., pixels) to recognize you and/or your device(s) when you use the Site or Services.

What are cookies?
Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Site and certain Services.

Relay also uses “pixels” (also known as web beacons). Pixels are transparent images that are used in collecting information about website usage across websites and over time.

Cookies that Relay sets on the Site or through the Services are called first-party cookies. Cookies set by any other party are called third-party cookies. Third-party cookies enable third-party features or functionality on or through the Site or through the Services, such as analytics, marketing automation and customer support. The parties that set third-party cookies can recognize your computer both when it visits the Site and also when it visits certain other websites.

Most browsers accept cookies automatically but allow you to disable them. You also can opt-out of certain cookies using the following link: http://optout.networkadvertising.org/?c=1. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Some features of our Site and Services may not work properly without cookies. To learn more about cookies generally, visit www.allaboutcookies.org and http://optout.aboutads.info/?c=2&lang=EN.

Some web browsers (including Brave, Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Relay, do not respond to DNT signals.

Why does Relay use cookies and other tracking technology?
Some cookies are required for the Site or Services to operate. Other cookies enable us to track the interests of Site users, to enhance the experience the Site and to target advertising.

The types of cookies served the Site and why they are used is as follows:
· “Strictly necessary” cookies are required to allow us to deliver the Sites to you and to provide specific services that you request from us.
· “Performance” or “Analytics” cookies help us to collect information about how visitors use the Site and helps us analyze and improve the Site. Performance or analytics cookies remain on your computer after you close your browser until you delete them.
· “Advertising” cookies are used to make advertising messages more relevant to you. They help to display advertisements that are based on your inferred interests, prevent the same ad from appearing too often and ensuring that ads are properly displayed for advertisers.

The cookies used on the Site and Services are:

Third Party and Cookie Type
Amplitude: Persistent
Google Tag Manager: Persistent
Chargebee: Persistent

We also use Google Analytics (including Double Click). Google Analytics provides us with demographic data about Site users, such as age and gender. Google uses a cookie that Google or its affiliate DoubleClick recognizes when you visit other websites. For more information about how Google collects, uses, and shares your information, please visit the Google Privacy Policy-Partners website at https://www.google.com/policies/privacy/partners/ or Google’s Privacy Policy.

Google uses cookies to help us analyze how visitors use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. On behalf of Relay, Google will use this information to evaluate your use of the Site and compile reports on your activity for us and third parties who help operate and provide services related to Relay. Google will not associate your IP address with any other data held by Google. You may refuse the use of these cookies by selecting the appropriate settings on your browser as discussed in this notice.

Google has developed an opt-out browser add-on; if you want to opt out of Google Analytics, you can download and install the add-on for your web browser.

Pixels and similar data collection technology enables Relay to monitor the traffic patterns of visitors from one Site page to another, to deliver or communicate with cookies, to understand whether you visit the Site after seeing our online advertisement displayed on a third-party website, to improve performance of the Site and to measure the success of our email marketing campaigns.

Relay currently does not serve targeted advertisements on the Site. Relay may use information about your visits to the Site to provide relevant advertisements on other websites. Relay and third parties also may deploy technology that measures the effectiveness of the advertisements on other websites by using cookies or web beacons to collect information about your visits to the Site and other websites to provide advertisements on other websites about goods and services that may interest you. The information collected through this process does not enable us or the third parties to identify your name, contact details or similar directly identifying details unless you choose to provide them.

HOW RELAY PROTECTS PERSONAL INFORMATION
We use technical, physical and administrative safeguards intended to protect the personal information that we collect from and about you. Our safeguards are designed to provide a level of security appropriate to the risk of processing your personal information and include (as applicable) measures to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and a procedure for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of personal information.

You are responsible for maintaining the security of your account credentials for the Services. Relay will treat access to the Services through your account credentials as authorized by you. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

If we become aware of a breach that affects the security of your personal information, we will provide you or your employer with notice as required by applicable law. To the extent permitted by applicable law, Relay will provide its notice to you through the email address associated with your account.

UNAUTHORIZED ACCESS TO THE SITE OR SERVICES – INCLUDING SCRAPING – IS PROHIBITED AND MAY LEAD TO CRIMINAL PROSECUTION.

HOW RELAY RETAINS PERSONAL INFORMATION
We retain personal information for as long we have a legitimate business need to do so, such for the duration of your subscription or to comply with applicable legal, taxation or accounting requirements.

When we have no longer have a legitimate business need to process your personal information, we follow our information governance procedures and either delete or anonymize your personal information. If we cannot delete or anonymize your personal information, then we will segregate and securely store your personal information until deletion or anonymization is possible.

CHILDREN’S PRIVACY
The Site and Services are not intended for use by minors (i.e., children under the age of majority if older in a particular jurisdiction) or to collect personal information from minors.

Relay does not knowingly collect personal information from minors. Consistent with the requirements of applicable law, if we learn that a minor has improperly provided us with personal information, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the minor that he or she cannot use the Sire or Services and subsequently will delete that information.

YOUR CHOICES ABOUT YOUR PERSONAL INFORMATION

California Privacy Notice

This California Privacy Notice applies to the processing of Personal Information of residents of the State of California (“California Residents”) as required by the California Resident Privacy Act of 2018 (“CCPA”).

If you are a California Resident, this California Privacy Notice explains your privacy rights and is intended to inform you at or before the time that you provide us with your Personal Information how and why we process your Personal Information. In this California Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular California Resident or household.

If this California Privacy Notice and any provision in the rest of our Privacy Policy conflict, then this California Privacy Notice controls for the processing of Personal Information of California Residents.

We may not honor part or all of a request you make to exercise your rights under CCPA – for example, certain information we collect is exempt from this California Privacy Notice, such as publicly-available information collected from a government agency. Most personal information collected by Relay within the context of providing our Services and related services to a California Resident who is an employee or representative of a business is exempt from CCPA until January 1, 2021.

California Privacy Rights
California Residents have the following rights:
• You have the right to request information about the categories and specific pieces of Personal Information we have collected about you (see table below), as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information.
• You have the right to opt out of Relay’s sale of your Personal Information if and when Relay determines the purpose and means of processing your Personal Information. (In CCPA, “sale” means transferring or making available Personal Information to third parties for monetary or other valuable consideration.) RELAY DOES NOT SELL PERSONAL INFORMATION. Accordingly, Relay does not offer a means by which to opt-out of sale of personal information.
• You have the right to request information about our disclosure for business purposes of your Personal Information to third parties.
• You have the right to request the deletion of your Personal Information.
• You have the right to not be discriminated against for exercising any of these rights.

The following tables lists categories of Personal Information that generally match the categories in the definition of Personal Information in CCPA. We indicate for each listed category the specific types of Personal Information in the category that Relay collected within the last 12 months.

Please note that users of the Services also may upload personal information when requesting a quote or sharing materials through the Services as described in the Relay Terms and Conditions https://www.relayplatform.com/relay-platform-terms/ . Relay does not review this uploaded information to determine whether it contains personal information. If you have questions about whether one of Relay’s customer has uploaded any specific category or pieces of personal information to the Services, please contact that customer.

Category of Personal Information in CCPA Examples of Personal Information in CCPA Category that Relay Collects Why Relay Collects this Personal Information
A. Identifiers Name, postal address, email address, unique identifier, Internet Protocol address, user account name, Social Security number and similar identifiers. o To create an account if you are a subscriber for the Services and if you register for events, training or content access
o To troubleshoot problems
o To learn how users interact with our products and services
o To improve our products and services and develop new features
o To customize your experience
o To promote our products and services
o To deliver advertising some of which is targeted based on your online activity and inferred interests
o To communicate with you
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) name, signature, social security number, address, telephone number and current employer and work address o To create an account if you are a subscriber for the Services and if you register for events, training or content access
o To troubleshoot problems
o To learn how users interact with our products and services
o To improve our products and services and develop new features
o To customize your experience
o To promote our products and services
o To deliver advertising some of which is targeted based on your online activity and inferred interests
o To communicate with you
C. Protected classification characteristics under California or federal law
None
N/A
D. Commercial information Records products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
o To customize your experience
o To promote our products and services
o To deliver advertising some of which is targeted based on your online activity and inferred interests
o To improve our products and services and develop new features
o To communicate with you
E. Biometric information None N/A
F. Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with online services and digital advertisements.
o To learn how users interact with our products and services
o To improve our products and services and develop new features
o To customize your experience
o To promote our products and services
o To deliver advertising some of which is targeted based on your online activity and inferred interests
o To communicate with you
G. Geolocation data IP address
We collect your IP address automatically. We may be able to determine your general location based on the IP address. Our mobile applications do not collect your precise location (e.g., your GPS coordinates).
H. Audio, electronic, visual, thermal, olfactory or similar information. If you contact us via telephone, we may record the telephone call. We will notify you if a call is being recorded at the beginning of the telephone call. We do not collect any thermal, olfactory or similar information. If we record a telephone call, we do so with your prior consent, for quality control and process improvement.
I. Professional or employment-related information Current employer and work address.
Depending on how and why you use our products and services, we may collect information about your current employer, title, work address and work email so that we can associate you with a particular customer or account. o To tie your individual account to a corporate account, at the request of your employer and with your consent
o To verify employer, work address and job title when you use our Services or interact with our other products and services
o To promote our products and services
o To communicate with you
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)) NONE

N/A
K. Inferences drawn from other categories (A. – L above) to create a profile about a consumer Profile reflecting the resident’s preferences and characteristics. o To customize your experience
o To promote our products and services
o To deliver advertising, some of which is targeted based on your online activity and inferred interests

We provide information about how we use and disclose personal information above in this Privacy Policy.

How to Submit Your Request to Exercise Your California Privacy Rights

If you are a California resident and would like to exercise one or more of your privacy rights, please:

Call us at +1 416 200 1158. Please tell our customer service team that you are a California resident and would like to exercise your privacy rights.
Send an email to [email protected] Please include “California Privacy Rights” in the subject line.

A different California law permits California residents to request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request by mail to or by email to [email protected] Please include “California Privacy Rights” in the subject line.

Notice for Individuals Located In EU

The data controller for the information you provide or that we collect pursuant to this Privacy Policy is: Harry Mills, who can be reached at [email protected]

Our legal basis for collecting and using personal information depends on the context in which it is collected. Generally, we only collect personal information from you only when we need the personal information to perform a contract with you (such as when you subscribe to our Services), when we have your consent to do so or when the processing is in our legitimate business interests and not overridden by your privacy or other fundamental rights and freedoms (such as when we process personal information to provide our Services to you). In some cases, we also may have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether providing your personal information is mandatory and the possible consequences if you do not provide your personal information.

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest is typically to provide our products and services and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our products and services, advising you of product features or new releases, informing you of product maintenance, or undertaking marketing activities. We may have other legitimate interests and if appropriate we will make clear our legitimate interests at the relevant time.

If you have questions about or need further information concerning the legal bases on which we collect and use your personal information, please contact us using the contact details provided below.
If you would like to review, correct, update, suppress, restrict or delete personal information that you have previously provided to us or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (where this right to portability is provided to you by law), please submit your request to us by email to [email protected]

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or other limitations you would like to put on our use of your personal information. For your protection, we only fulfill requests for the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable and within the time periods required by applicable law.

Please note that we often need to retain certain personal information for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion). Our databases and other records may have residual personal information which will not be removed. We also may not allow you to review certain personal information for legal, security or other reasons.

Please note that users of the Services also may upload personal data when requesting a quote or sharing materials through the Services as described in the Relay Terms and Conditions https://www.relayplatform.com/relay-platform-terms/ . Relay does not review this uploaded information to determine whether it contains personal data. If you have questions about whether one of Relay’s customer has uploaded your personal data to the Services, please contact that customer.

EEA residents have the right to lodge a complaint with a data protection authority about how we process your personal information. Please see https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en for more information. Please also read our Privacy Shield Policy immediately below to learn more about how to resolve complaints about your personal information processed by or on behalf of Relay.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Relay may transfer your personal information to jurisdictions other than the one in which you reside. These other jurisdictions may have data protection laws that are different from the laws of your place of residence (and, in some cases, not as protective).

Specifically, our servers are located in the U.S. When we collect your personal information, we may transfer it to or process it in other jurisdictions where we operate. Also, some of the third-party service providers with which we may share personal information (as described above) are located in and transfer personal information to various jurisdictions around the world.

Relay primarily uses the European Union Commission’s Standard Contractual Clauses for transfers of personal information from the European Economic Area, Switzerland and the United Kingdom (when the U.K. leaves the European Union) to other countries outside the European Economic Area, Switzerland and the United Kingdom (when the U.K. leaves the European Union).

UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will post the updated version and change the Effective Date above. We also will take appropriate measures to inform you in advance so that you have an opportunity to review the revised Privacy Policy before it is effective. If your consent is required by applicable privacy laws, we will obtain your consent to changes before the revised Privacy Policy applies to you.

HOW TO CONTACT US
If you have any concerns or questions about any aspect of this Privacy Policy, please contact our Privacy Policy Coordinator as follows:

Relay Platform Inc.
Attn: Greg Boutin
325 Front Street West, 4th Floor – Toronto, ON M5V 2Y1 – Canada
[email protected]