Privacy Notice

When you visit our website at neumi.com (the "Website"), use our mobile application (the "App"), and more generally use any of our services (the "Services", which include the Website and App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully.

This privacy notice applies to all information collected through our Services (which includes our Website and App), as well as any related services, sales, marketing, or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

Table of contents

1. What information do we collect?
2. How do we use your information?
3. Will your information be shared with anyone?
4. How do we handle your social logins?
5. How long do we keep your information?
6. How do we keep your information safe?
7. Do we collect information from minors?
8. What are your privacy rights?
9. Controls for do-not-track features
10. Do California residents have specific privacy rights?
11. Do we make updates to this notice?
12. How can you contact us about this notice?
13. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Personal information provided by you. We collect names; phone numbers; email addresses; mailing addresses; usernames; passwords; billing addresses; debit/credit card numbers; and other similar information.

Payment data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Global Payroll Gateway. You may find their privacy notice at globalpayrollgateway.com/privacy.

Social media login data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "How do we handle your social logins?" below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and usage data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. This may include your IP address, device information, browser type and settings, and information about your activity in the Services (such as date/time stamps, pages and files viewed, searches and other actions), and device event information (such as system activity, error reports, and hardware settings).
• Device data. Information about your computer, phone, tablet, or other device you use to access the Services, including IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location data. Information about your device's location, which can be either precise or imprecise. We may use GPS and other technologies to collect geolocation data. You can opt out of allowing us to collect this information either by refusing access or by disabling your Location setting on your device. If you opt out, you may not be able to use certain aspects of the Services.

Information collected through our App

In short: We collect information regarding your geolocation, mobile device, and push notifications when you use our App.

If you use our App, we also collect the following information:

• Geolocation information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile device data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
• Push notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt out, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our App, for troubleshooting, and for our internal analytics and reporting purposes.

2. How do we use your information?

In short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We use the information we collect or receive:

• To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as Google or Facebook), we use the information you allowed us to collect from those third parties to facilitate account creation.
• To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting, we will obtain your consent. To update or delete your testimonial, contact support@neumi.com with your name, testimonial location, and contact information.
• Request feedback. We may use your information to request feedback and to contact you about your use of our Services.
• To enable user-to-user communications. With each user's consent.
• To manage user accounts. For account management and keeping it in working order.
• To send administrative information to you. Product, service, new feature information, and changes to our terms, conditions, and policies.
• To protect our Services. Including fraud monitoring and prevention.
• To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements, or in connection with our contract.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• Fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• Administer prize draws and competitions when you elect to participate.
• To deliver and facilitate delivery of services to the user.
• To respond to user inquiries and offer support.
• To send marketing and promotional communications, in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
• Deliver targeted advertising tailored to your interests and/or location, and measure its effectiveness.
• For other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and improving our Services. We may use and store this information in aggregated and anonymized form.

3. Will your information be shared with anyone?

In short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

• Consent: When you have given specific consent to use your personal information for a specific purpose.
• Legitimate interests: When reasonably necessary to achieve our legitimate business interests.
• Performance of a contract: Where we have entered into a contract with you and need to fulfill its terms.
• Legal obligations: Where we are legally required to do so to comply with applicable law, governmental requests, judicial proceedings, court orders, or legal process.
• Vital interests: Where necessary to investigate, prevent, or take action regarding potential violations, suspected fraud, threats to safety, illegal activities, or as evidence in litigation.

More specifically, we may need to process your data or share your personal information in the following situations:

• Business transfers. In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition.
• Business partners. We may share your information with our business partners to offer you certain products, services, or promotions.

4. How do we handle your social logins?

In short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the provider, but will often include your name, email address, friends list, profile picture, as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information.

5. How long do we keep your information?

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. How do we keep your information safe?

In short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

7. Do we collect information from minors?

In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@neumi.com.

8. What are your privacy rights?

In short: You may review, change, or terminate your account at any time.

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details at ec.europa.eu/justice/data-protection/bodies/authorities.

If you are a resident in Switzerland, the contact details for the data protection authorities are available at edoeb.admin.ch.

If you have questions or comments about your privacy rights, you may email us at support@neumi.com.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details below. You will then be removed from the marketing email list — however, we may still communicate with you to send service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

9. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

10. Do California residents have specific privacy rights?

In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information below.

If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as: (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, IP address, email address, and account name	Yes
B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	Yes
C. Protected classification characteristics under California or federal law	Gender and date of birth	No
D. Commercial information	Transaction information, purchase history, financial details, and payment information	No
E. Biometric information	Fingerprints and voiceprints	No
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	No
G. Geolocation data	Device location	Yes
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video, or call recordings created in connection with our business activities	No
I. Professional or employment-related information	Business contact details, job title, work history, and professional qualifications	No
J. Education information	Student records and directory information	No
K. Inferences drawn from other personal information	Inferences used to create a profile or summary about an individual's preferences and characteristics	Yes

We may also collect other personal information outside of these categories in instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at support@neumi.com, by calling toll-free at 1-888-204-3088, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

Neumi, LLC has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. Neumi, LLC will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data — request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law (such as the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities).

Right to be informed — request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell your personal information to third parties;
• the categories of personal information that we sold or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request, or to re-identify individual data to verify a consumer request.

Right to non-discrimination for the exercise of a consumer's privacy rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. We will only use personal information provided in your request to verify your identity or authority to make the request.

Other privacy rights

• You may object to the processing of your personal data.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling of your personal information to third parties. Upon receiving a request to opt out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us by email at support@neumi.com, by calling toll-free at 1-888-204-3088, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

11. Do we make updates to this notice?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at support@neumi.com or by post to:

Neumi, LLC
4735 S Cherry St
Murray, UT 84123-3608
United States

13. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please visit neumi.com/en/register.