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OCEAN ACCELERATOR PRIVACY POLICY

OCEAN ACCELERATOR, INC., including its subsidiaries and affiliates, (“OCEAN”, “we”, ”us”, ”our”), has published this “Privacy Policy” (or “Policy”) to detail our policies and procedures regarding the collection, use, and disclosure of personally identifiable information received in the course of our customers using any services provided by OCEAN whether through electronic means, including email, through our website(s) (the “Site”), and/or any other related systems. Within this Policy, we will be referring to the Site, and any other service offered by OCEAN collectively as the “Service(s).”

This Privacy Policy applies to information that is provided to us when you use the Services. We reserve the right in our sole discretion to modify this Privacy Policy at any time. We will post the most recent version of this Policy on this page of our Site. We encourage you to periodically review this page for the latest information on our privacy practices. If you have any questions, we can be reached at info@oceanprograms.com.

1. Collecting PII and other Information
While using OCEAN’S Services, you may provide OCEAN with certain personal information for yourself or for another participant (“Personal Identifying Information” or “PII”). PII may include, but is not limited to, name, postal addresses, email addresses, telephone number, credit history, payment history, credit or debit card number, and/or other billing information. We may also collect information during your use of our Site including operating system, your phone carrier, hardware you use, pages you viewed, your IP address, how often you visit the Site, events that occur within the Site during your use, aggregated usage information, performance data, the site and location from where you downloaded or otherwise accessed the Services, your browser type, your Internet service provider, the referring and exit pages, installed fonts, device IDs, language and time zone settings, and other information relating to your use of or access to the Services through the use of automatic data collection tools.

We do not collect any PII unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services available on the Site. These may include: (i) registering for an account on our Site; (ii) sending us an electronic message; (iii) submitting your credit card or other payment information when ordering and purchasing products and services on our Site.

2. Using PII
OCEAN uses PII in a number of ways, including, but not limited to, the following: (i) to provide and improve aspects of the Services; (ii) to improve the experience for all customers, including identifying, completing and expediting any problems, issues or requests customers may have related to our Services; (iii) to project, predict and understand customer usage and needs; (iv) to communicate with customers regarding updates, announcements, changes, and other offerings from OCEAN; (v) to facilitate auditing, prevent or investigate fraud, comply with requests from regulatory and law enforcement authorities, protect our rights, protect your safety, protect the safety of others, comply with applicable law, respond to subpoena or court order, and otherwise investigate, establish, exercise, and defend legal rights; and, (vi) to facilitate a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence) and/or to facilitate any other activity in connection with the creation, development, offering, provision, or maintenance of our Services.

3. Email
By using our Services, you have the opportunity to provide us with your contact information in order to receive periodic updates about OCEAN and its Services. We may use third-party communication software to send these emails or monitor communications. By using the Services, you agree to this disclosure, but have the ability to opt out of any such communications.

4. Security
We take the security of PII very seriously. OCEAN will follow industry best practices, including the provisions of the California Consumer Privacy Act of 2018, when it comes to the transmission, maintenance and submission of your data, and every member of our team who is responsible for handling data follows these practices.

5. Children
As we do not provide our Services to anyone under the age of 13, we similarly do not collect PII from anyone under the age of 13. If you are under the age of 13, please do not provide any PII to OCEAN. Regardless of your age, please do not provide OCEAN with any PII of any person under the age of 13. If you are a parent or a guardian who has discovered that your child under age 13 has submitted his or her personally identifiable information to us without your permission or consent, we will make reasonable efforts to remove the information from our system, at your written request. To request the removal of your child’s information, please contact us as at info@oceanprograms.com and include in your message your child’s name, the email address associated with your child, and a description of the information you believe your child may have submitted.

6. Analytics and Tracking

a. Cookies and Local Storage
OCEAN actively collects information through the use of “cookies” and “local storage.” We use these to observe usage patterns and traffic on our Site, and subsequently link the appropriate cookies to your PII and account in order to optimize your customer experience. When visiting our site, your browser may alert you to our usage of cookies or local storage. You can always set your browser setting to limit their usage; however, it may limit the features of our Services. This information may be stored using third-party services.

b. Web Beacons
Another tracking technology that we may employ is the Web Beacon (a.k.a. web bugs or clear gifs). These tools help us manage and observe our content, track email campaigns, and other communications, and optimize the way we present content. Like cookies, these tools can be linked to PII in order to provide better customization and specificity.

c. Log Data
Our servers automatically record certain information about how visitors interact with our Site – this is known as “Log Data.” Log Data is a broad category of data, but it can include, but is not limited to: (i) browser type; (ii) operating system; (iii) Internet Protocol address; (iv) pages viewed and duration of viewing; (v) features and functionalities used; and (vi) links clicked.

7. Anonymous and De-identified Data
We may use third-party advertising services that collect non-personally identifying information using cookies and the other tools mentioned above. You may opt out of this data collection at any time by contacting us as provided at the beginning of this Policy, and include your name and email address. Additionally, we may use aggregated, de-identified data to show larger trends in the use and delivery of our Services. No PII is disclosed in this process.

8. Disclosure of Information to Third Parties
OCEAN does not sell any of PII without express consent. PII will only be disclosed as expressly set forth in this Policy.

9. Third-Party Services/Links
OCEAN may use third-party platforms or services in order to deliver, maintain, or update OCEAN’ Services. As such, OCEAN may disclose PII to these third-party providers in order to maintain and continue the operation of the Services. Our Site also may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects PII.

10. Accessing and Managing Your Information
Every OCEAN customer or account holder can request access to their PII. You may request to review your PII and/or obtain a copy of your PII by contacting us at any time as provided at the beginning of this Policy. If you believe that the information is incomplete or inaccurate, you can request that we correct it. We may not, however, be able to provide information relating to investigations, claims, litigation, or other matters. We can make corrections whenever possible. You may also request to have OCEAN delete your PII, provided that you understand that deleting such information may make it impossible for OCEAN to render Services to you. OCEAN reserves the right to archive or save data in order to comply with laws and regulations.

11. Governing Law, Jurisdiction, Venue
The information collected from our Services is hosted in the United States. If you are using or accessing the Services from outside the United States or any other region with laws or regulations governing personal data collection, use and disclosure that differ from the United States laws, please be advised that through your use of the Services, which are governed by United States law, you are transferring information to and from the United States and you consent to that transfer.

The laws of the State of Ohio and applicable United States law govern all matters arising out of or relating to this Policy, including, without limitation, interpretation, construction, performance, and enforcement, without giving effect to such state’s conflicts of law principles or rules of construction. You irrevocably and unconditionally submit to the jurisdiction of the federal and state courts venued in Hamilton County, Ohio for the purpose of any suit, action, or other proceeding arising out of or based upon this Policy, your access to or your use of the Services, which courts are the exclusive forum for any such suit, action, or other proceeding.

12. Assignment
The rights granted under this Policy are non-transferable and non-assignable by you, and such rights are not enforceable by anyone other than you, pursuant to applicable laws. However, OCEAN may transfer and/or assign any rights under this Policy without limitation and without notice or consent from you.

13. Updates and Revisions
This Privacy Policy may be updated periodically by OCEAN. We will notify you of such changes and updates by publishing the Privacy Policy on our Site. Your continued use of the Site and/or the Services after such changes and updates will constitute your acknowledgement of the revised Privacy Policy and your acceptance of its terms.

14. Acceptance of Policy
By using or accessing the Services, you acknowledge that you have reviewed and understand this Policy, and consent to the procedures identified in this Policy. You accept and consent to the collection of PII, the retention of PII, the handling of PII, and potential disclosure of PII as identified in this Policy.

SPECIAL NOTICE TO CALIFORNIA RESIDENTS
These additional disclosures for California residents apply only to individuals who reside in California. The California Consumer Privacy Act of 2018, as amended (“CCPA”) provides additional rights to know, delete and opt out, and requires business collecting or disclosing Personal Information to provide notice of rights California residents have and can exercise. Personal Information includes any personally identifiable information about you, including information that can identify, relate to, describe, be associated with you, or is reasonably capable of being associated with you, including, but not limited to, contact information, billing or credit card information, employment information, license information and financial information.

California Notice of Collection.

We have collected Personal Information corresponding to the following categories enumerated in the CCPA, including within the last 12 months.

Identifiers, including name, address, email address, account name, Social Security Number, Drivers’ license number, IP address assigned to your account.
Customer records, phone number, billing address, credit or debit card information, employment information.
Demographic information, such as your age or gender. This category includes pieces of Personal Information that also qualify as protected classification characteristics under other pre-existing California or federal laws.
Analytics and Advertising, including engagement with the Platform.
• Internet activity, including history of visiting and interacting with our Platform or website, browser type, browser language and other information collected automatically.
Geolocation data, including location enabled services such as WiFi and GPS.
Inferences, including information about your interests and preferences.

For more information on what we collect, including the sources we receive information from, review this Privacy Policy. We collect and use these categories of personal information for the business purposes described in this Privacy Policy.
OCEAN does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising or transfer of Personal Information, as a “sale,” we will comply with applicable law as to such activity.

OCEAN discloses the following categories of information for commercial purposes: Commercial Information; Demographic Data; Location Data; Identifiers; Inferences; and Internet activity. We may use and partner with different types of entities to assist with our daily operations and manage the Platform. Please review this Privacy Policy, for more detail about the parties with which we share Personal Information.

Right to Know and Delete.

If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information was collected;
• The categories of Personal Information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the Personal Information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the Personal Information; and
• The specific pieces of Personal Information we have collected about you

In addition, you have the right to delete the Personal Information we have collected from you. However, this is not an absolute right and OCEAN may have legal grounds for keeping such data.

To exercise any of these rights, please submit a request at info@oceanprograms.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Right to Opt-Out.

To the extent OCEAN sells your Personal Information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your Personal Information by us to third parties at any time. You may request to opt-out by contacting info@oceanprograms.com.

Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination.

You have the right to non-discriminatory treatment by us, should you exercise any of your rights.

Shine the Light.

Customers who are residents of California may request: a list of the categories of Personal Information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes, and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please contact us at info@oceanprograms.com. Requests must include “California Shine the Light Request” in the first line of the description and include your name, street address, city, state, and ZIP code. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year. Please note that OCEAN is not required to respond to requests made by means other than through the provided email address or do not have complete information.

RIGHTS FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA)

In addition to the terms set forth above, if you reside in a member state of either the European Union or European Free Trade Association that is a party to the EEA Agreement (collectively, EU Residents), you have the right to access personal information OCEAN has collected about you for the purpose of reviewing, modifying, correcting or requesting erasure of your information. You may also have the right to request a copy of your information. Further, you may also request that OCEAN restrict or stop processing your information. Finally, you may object to communications, direct marketing, or automated processing of your personal information.

To the extent applicable, the EU’s General Data Protection Regulation provides further information about your rights. You also have the right to lodge complaints with your national or regional data protection authority.

If you wish to exercise these rights, please contact us at the address set forth above. To protect the personal information OCEAN holds, OCEAN may also request further information to verify your identity when exercising these rights. Upon a request to erase information, OCEAN will maintain a core set of personal information to ensure we do not contact you inadvertently in the future, as well as any information necessary for archival or other legal purposes. We may also retain financial information for legal purposes, including United States Internal Revenue Service compliance. Additionally, in the event of an actual or threatened legal claim, OCEAN may retain your information for purposes of establishing, defending against, or exercising your rights with respect to such claim.

By providing information directly to OCEAN, you consent to the transfer of your personal information outside of the EEA to the United States. Please note that the current laws and regulations of the United States may not provide the same level of protection as the data and privacy laws and regulations of the EEA.

EFFECTIVE DATE: June 1, 2021.

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