SOCOSIX STRATEGIES, LLC PRIVACY NOTICE

SocoSIX Strategies, LLC (“SocoSIX”) is firmly committed to your privacy. This Privacy Notice states our privacy practices when you visit our website or use any of our products, mobile applications, or services (collectively, the “Services”). Our mission in implementing this Privacy Notice is to protect your information and use it only to provide you with the highest quality Services available. The privacy and security of your information is of paramount importance to us. We do not sell, lease, rent, or barter ANY of your personal information to any third parties without your consent other than as provided in this Notice. We value the trust you place in SocoSIX. We are committed to providing a website with a secure environment and unparalleled customer service. This Privacy Notice describes the information we collect and how we use such information. Additional terms regarding your use of our Services are contained in the applicable agreement between SocoSIX (or its affiliate) and you. As an agent processing personal information on behalf of our customers, SocoSIX does not own or control the personal information that it processes on behalf of its customers and does not have a direct relationship with all individuals whose personal information may be processed in connection with the provision of our Services. In these circumstances, SocoSIX customers are responsible for providing appropriate notice to the relevant individuals and obtaining any requisite consent.

Why do we collect information?

In general, we collect information to help us in our marketing and promotional efforts, to analyze user behavior, and to customize and improve our Services. This information is used to assist SocoSIX in serving you when visiting our websites or using any of our Services. Our goal is to provide you with a personalized service which includes continually looking for ways to improve our Services and enhance your experience on our website.

What information do we collect?

The type of information we collect may be different depending on whether you are signing up to receive notifications, using our Services, communicating to our customer support team, or simply visiting our website. During any one of these processes, we collect contact information, which includes your email address, physical address, phone numbers and/or wireless device information. This information will be used to provide the Services to you. By simply visiting our website (without filling out any forms), we will not collect data that does personally identifies you, but data about your activities (e.g., the pages you viewed, the date and time of your visit, and location information from your IP address or GPS location) is collected. We may use this information to improve our Services, obtain market research information, or better understand how our Services are used generally. We do not intentionally collect personal information from anyone we know to be under eighteen (18) years of age. If you provide us with your information, you represent and warrant that: (i) you are eighteen (18) years of age or older; or, (ii) if you are providing information for a child under eighteen (18) years of age for the purpose of receiving notifications, you are the parent or legal guardian of such child; you are over eighteen (18) years of age; and that you are legally authorized to provide information for such child to be contacted through the Services.

Who do we share information with?

Information may be shared with our affiliates and service providers as needed for business purposes which include delivery of our Services, account administration, customer service, transaction processing, processing and delivery of account statements, and research and analysis. Customers we have a contractual relationship with may view your standard personal information through use of our Services. Through these contractual relationships, we require customers and service providers to maintain a level of privacy protection comparable to our own practices. Our policy is to notify individuals who use our Services of requests for their personal information prior to disclosure unless we are prohibited by law from doing so or in exceptional circumstances, such as emergencies.

Security precautions

We have stringent security measures in place to protect against the loss, misuse, and alteration of information under our control. We use secure technology, privacy protection controls, and restrictions on employee access in order to safeguard your information; however, the very nature of the Internet makes it impossible to guarantee the security of transmitted data.

How do we use cookies?

Like many other sites on the Internet, our website uses cookies and similar technologies such as web beacons, tags and JavaScript alone or in conjunction with cookies to compile information about the usage of our websites and interaction with emails from us. If you do not want this site to place a cookie on your browser and track your activity, you may leave the site or you may browse the site using privacy mode in your web browser.

SocoSIX commitment to children’s privacy

SocoSIX website, app and Services are intended for use by adults over the age of 18. Because of the nature of our service, which may include security of children, we may collect and retain information necessary for such security, which may include personal information about children. SocoSIX intends that parents or guardians provide information on children under age 13 when required. If you are a parent or legal guardian and think your child under 13 has given us information, you should contact us at privacy@socosix.com.

Nevada SB220 Notice

Although SocoSIX does not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us at privacy@socosix.com to register an e-mail contact address for us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. Contact us in the same manner to update your contact email for notices. Changing your email elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada notice contact information. It is your responsibility to keep your notice contact information current.

SOCOSIX PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: January 1, 2020. This Privacy Notice for California Residents supplements the information contained in the general Privacy Notice of SocoSIX Strategies, LLC (“SocoSIX “, “we” or “our”) and applies solely to all visitors to our website and users of any of our products, apps or services (collectively, the “Services”) who reside in the State of California (“consumers” or “you”). We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

Information We Collect

Our Services collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Services have collected the following categories of personal information from SocoSIX visitors and users within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, employee identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, address, personal telephone number, business telephone number. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as class lists, student schedules, student identification codes or assignments.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as:

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

SocoSIX obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you complete our forms and when you register for and use our Services.
• Indirectly from you. For example, from observing your actions on our website.
• Directly from our customers. For example, our customers provide personal information about consumers in order to receive the benefit of our services.

 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our Services, we will use that personal information to respond to your inquiry. If you provide your personal information to subscribe to our Services, we will use that information to process your payment and facilitate delivery of the Services. We may also save your information to facilitate new product orders or process refunds.
• To provide, support, personalize, and develop our Services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your experience of our Services and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of SocoSIX’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SocoSIX about users of our Services is among the assets transferred.

SocoSIX will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

SocoSIX may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. Disclosures of Personal Information for a Business Purpose In the preceding twelve (12) months, SocoSIX has disclosed personal information to its service providers for the following business purposes: delivery of our Services, account administration, customer service, transaction processing, processing and delivery of account statements, and research and analysis. Sales of Personal Information In the preceding twelve (12) months, SocoSIX has not sold personal information.

Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. Access to Specific Information and Data Portability Rights You have the right to request that SocoSIX disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights You have the right to request that SocoSIX delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• 1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• 2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• 3. Debug products to identify and repair errors that impair existing intended functionality.
• 4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• 6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• 7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• 8. Comply with a legal obligation.
• 9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 1-850-803-3730
• Visiting our website at socosix.com
• Emailing us at privacy@socosix.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Response Timing and Format We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which SocoSIX collects and uses your information as described herein and in SocoSIX’s general Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: Phone: 1-850-803-3730 Website: socosix.com Email: privacy@socosix.com Postal Address: SocoSIX Strategies, LLC Attn: Compliance Department, 171 Brooks Street SE, Suite 308, Fort Walton Beach, FL 32548

California Do-Not-Track

SocoSIX does not track its customers over time and across third-party websites to provide targeted advertising and therefore does not respond to Do-Not-Track (DNT) signals.

ACCOUNTABILITY FOR ONWARD TRANSFER

Except as permitted or required by applicable law, if SocoSIX transfers personal information provided by its Customers to a third party outside the European Economic Area (EEA), and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as the EEA, we will ensure that the recipient of your Personal Data offers an adequate level of protection by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR) or we will ask you for your prior consent to such international data transfers. SocoSIX reserves the right to transfer personal information in the event it sells or transfers all or a portion of its business or assets (including in the event of a reorganization, dissolution, or liquidation).

CHOICE

The Services are not intended to transmit sensitive data, or personal health information, or financial-related information (including nonpublic information collected by financial institutions subject to regulations specific to the conduct of financial services) or other personal information sensitive in nature. We offer individuals the opportunity to choose whether SocoSIX may disclose their personal information to third parties. Unless you elect to allow us to share your information, SocoSIX will not use personal information for purposes beyond the scope for which the information was originally collected or subsequently authorized by the individual and we will not retain personal information for longer than necessary or as otherwise set forth in the applicable customer agreement. Individuals may contact SocoSIX as indicated below regarding the use or disclosure of their personal information. If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link located on the bottom of our marketing emails, by replying or texting ‘STOP’ if you receive SMS communications or by turning off push notifications on our apps on your device. Additionally, you may unsubscribe by contacting SocoSIX using the information in the “Contact us” section, below. Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.

DATA INTEGRITY

SocoSIX depends on applicable customers and users of our Services to update and correct personal information, to the extent necessary, for the purposes for which the information was collected or subsequently authorized by the relevant individuals. With respect to personal information SocoSIX may obtain directly from individuals through its Website, SocoSIX takes reasonable steps to ensure that the personal information we process is (i) relevant for the purposes for which it was collected, (ii) reliable for its intended use, and (iii) accurate, complete, and current. Individuals may contact SocoSIX as indicated below to request that SocoSIX update, correct or request deletion of their personal information. Individuals who seek access or who seek to correct, amend, or delete personal information that SocoSIX maintains on behalf of a Customer in connection with the provision of its Services should make such requests directly to the appropriate customer. If an individual is unable to contact the appropriate customer, or does not obtain a response from the customer, SocoSIX will provide reasonable assistance in forwarding the individual’s request to the customer. SocoSIX may limit or deny access to personal information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by applicable law. Individuals may request access to their personal information by contacting SocoSIX as indicated below.

Your Rights

You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws and, in particular, if you are located in the EEA, these rights may include the right:

• To access your Personal Data held by us (right to access);
• To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification);
• To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
• To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing);
• To transfer your Personal Data to another controller, to the extent possible (right to data portability);
• To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
• Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). Automated Decision-Making currently does not take place on our websites; and
• To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

Changes to Privacy Notice

SocoSIX reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on our website and update the Privacy Notice’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.