Privacy Policy Last Updated AUGUST 2024 1. Overview

SGE Software Inc. (“SGE Software,” “we,” “us,” and “our”)
respects your privacy and is committed to protecting it through compliance with
this Privacy Policy (“Privacy Policy”). This Privacy Policy describes how we
collect and use your Personal Information when you visit our website at 

https://www.simplygrowthengine.com

 or
otherwise use the Platform as described further in the 

Terms of Service

, and that you may provide in electronic messages to SGE Software.

Please read this Privacy Policy to understand our policies
and practices regarding your Personal Information and how we will handle it. If
you do not agree with our policies and practices, do not use the
Platform.  By accessing or using the Platform, you agree and consent to
this Privacy Policy.

SGE Software may change this Privacy Policy at any time, at its discretion.

 Your continued use of the Platform after
we make changes is deemed to be acceptance of and consent to those changes, so
please check the Privacy Policy periodically for updates.

This Privacy Policy is subject to and governed by the SGE
Software Terms of Service. The Services are part of the Platform and are
described further in the Terms of Service.

2. The Types of Information That SGE Software Collects About You and How SGE Software Collects Information About You

SGE Software may collect two types of information from you
when you visit the Platform: Personal Information and Non-Personal Information
(collectively “Information”).

“Personal Information” refers to data by which you may be personally identified, such as name, email address, employer, job title and department, and telephone number. “Non-Personal Information” means data that is about you, but does not identify you specifically. If you do nothing during your visit to our Platform but browse, read pages, or view content, we will gather and store Information about your visit that does not identify you personally.

We collect Information:

Directly from you when you provide it to us. When you subscribe to a newsletter, create an account, make a purchase or request information from SGE Software, we will ask for things like your name, contact, billing, shipping and communication information, and account ID or credentials in order to fulfill your request. If you set up an appointment with us through the Platform, attend a trade show or event, or otherwise contact us, you may also voluntarily provide similar information.  If you submit any Personal Information about other people to us or to our service providers, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Information in accordance with this Privacy Policy (for example, by You asking for their consent). From third parties. We obtain information through partners, vendors, suppliers and other third parties.  The parties from whom we obtain information are typically corporate enterprises (although some may also be educational or public enterprises) and they may be located in any of the locations in which we do business.  These enterprises largely fall into the following categories: Advertising and marketing companies, data set and information vendors, public database providers, social media platforms, partners, providers of products or services, hosts or vendors at events or trade shows, research partners, or enterprises that use SGE Software Services.  We take steps to confirm that information we receive from these third parties has been collected with your consent or that these parties are otherwise legally permitted to disclose your Personal Information to us.  We might also obtain information through a partner, or co-create datasets with a partner, as part of our business operations.  This kind of data is used for work like improving the Platform and other SGE Software Services, enhancing existing products and developing new capabilities and features.  In some cases we combine Personal Information about individuals that we receive from multiple sources, including directly collected from you or through your use of the Platform. Automatically as you navigate through the Platform or during the time in which you utilize our Services.  We collect information about how you interact with the Platform through the use of cookies, pixel tags, and similar technologies.  Please view our separate Cookies Policy for more information on our use of cookies and similar technologies, how you can manage cookies and how we respond to Do Not Track signals.

3. How SGE Software Uses Personal Information It Collects About You and the Purposes for the Collection and Use

We use Personal Information that we collect about you or
that you provide to us for the following purposes:

For Functionality and Development of the Platform and SGE Software Services. We use information to provide, offer, and personalize the Platform and other SGE Software Services provided to you.  Some information, like your IP address, is used to communicate with your device to provide network connectivity, measure usage levels of the Platform, diagnose server problems and provide security features.  Other business purposes that depend on use of your information include data analysis related to testing, modifying, improving or developing new products, services and technologies, and to identify trends. Some Platform features may leverage artificial intelligence (“AI”) tools to enhance performance capabilities. We do NOT retain Personal Information to develop, improve, or train generalized AI or machine learning models, including user data provided via third party APIs, including but not limited to Google Workspace APIs. SGE Software Platform’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. We use cookies to make our websites and the Platform operate, work more efficiently, and provide analytic information. Technologies similar to cookies, such as pixel tags are also used in connection with the Platform. For more information on our use of cookies, please read our Cookies Policy. For Customer Support, Platform Updating and Reporting. The Platform may use information to provide SGE Software with updates and reports, and to check that the Platform is working properly.  Update functions may automatically check your system to see whether files need to be refreshed, updated, or modernized, in order to provide you with the up-to-date security, versions, features, options and controls associated with your systems or devices.  We rely on information to analyze performance and improve and maintain the Platform.  We also rely on Personal Information you provide to us to provide you with customer support for the Platform and other SGE Software Services, and to verify eligibility for promotional offers. For Business Operations. We use information to operate our business; for example, to perform accounting, auditing, billing, reconciliation, and collection activities. Other business purposes that depend on use of your Personal Information include crime or fraud monitoring and prevention, protecting our legal rights, and performing contractual obligations.  We also use Personal Information to contact you to advertise, market and sell SGE Software Services in accordance with your communications preferences. To Communicate. We use contact information to send messages; to provide SGE Software Services; to respond to customer service requests; to provide alerts such as security updates or changes in our policies or about subscriptions that are ending; and to send marketing or informational materials like newsletters or white papers, in accordance with your communication preferences.  We occasionally conduct surveys, or do focused research or studies which may require you to voluntarily share Personal Information in order to participate.  These activities typically have additional notices that provide more information about the use of your Personal Information and to which you may be asked to consent. For Advertising and Marketing. We may use Personal Information collected from you, combined with information about what advertisements you viewed and other information we collect, to enable us to provide personalized content and to study the effectiveness of advertising and marketing campaigns.  You may choose whether to allow or deny uses or sharing of your device’s location by changing your device settings, but if you choose to deny such uses or sharing, we may not be able to provide you with certain personalized SGE Software Services and content on the Platform. For Statistical Purposes to Improve the Platform. We may compile Platform statistics into traffic reports, which help SGE Software understand, anticipate, and respond to user needs.  If we learn, for example, of heightened interest in certain aspects of the SGE Software Platform, we are likely to highlight that information on the Platform home page. This Information helps us create a better overall experience for Platform users.

LEGAL BASIS FOR OUR USE (APPLICABLE ONLY TO EEA AND UNITED KINGDOM VISITORS):

  If you are in the European Economic Area or
the United Kingdom, our legal basis for collecting and using the Personal
Information described above will depend on the Personal Information concerned
and the specific context in which we collect it.

However, we will collect Personal Information from you only
where we have your consent to do so, where we need the Personal Information to
perform a contract with you, where we have a legal obligation to do so, or
where the processing is in our legitimate interests (such as processing for
administrative purposes, direct marketing, product development or improvement,
preventing fraud or criminal acts and in support of information security) and
not overridden by your data protection interests or fundamental rights and
freedoms. 

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 time of collection. We will also tell you whether the requirement for
that information is mandatory and explain any consequences to you if you do not
provide the information.

Similarly, if we collect and use your Personal Information
based on our legitimate interests (or those of any third party), we will take
reasonable steps to provide clear notice and describe our legitimate interests.

SGE Software is the Data Controller of all Personal
Information collected through the Platform in the EEA and the United Kingdom,
except with respect to the Services (where SGE Software is the Data Processor)
or where a supplemental Privacy Policy says otherwise. The contact details for SGE
Software are set out in the "

HOW TO CONTACT US

” section.

If you have questions about or need further information
concerning the legal basis on which we collect and use your Personal
Information for any specific processing activity, please contact us using the
contact details provided under the “

HOW TO CONTACT US

” Section below.

RETENTION OF YOUR PERSONAL INFORMATION:

 We will
only retain your Personal Information for as long as reasonably necessary to
fulfill the purposes we collected it for, including for the purposes of
satisfying any legal, regulatory, tax, accounting or reporting requirements and
for other purposes described in this Privacy Policy.  We may retain your
Personal Information for a longer period in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to our
relationship with you.

To determine the appropriate retention period for Personal
Information, we consider the amount, nature and sensitivity of the Personal
Information, the potential risk of harm from unauthorized use or disclosure of
your Personal Information, the purposes for which we process your Personal
Information and whether we can achieve those purposes through other means, and
the applicable legal, regulatory, tax, accounting or other requirements. 
In some circumstances you can ask us to delete your data: see “YOUR LEGAL
RIGHTS” below for further information.  And in some circumstances we will
anonymize your Personal Information (so that it can no longer be associated
with you) for research or statistical purposes, in which case we may use this
information indefinitely without further notice to you.

4. How SGE Software Protects Your Information

The Platform is designed to provide reasonable and
appropriate administrative, technical and organizational security measures to
protect your Personal Information against risks such as temporary or permanent
loss, destruction, and unauthorized or unlawful access, alteration, use or
disclosure.  We require our suppliers and vendors to apply similar
protections when they access or use Personal Information that we share with
them.  Users of the Platform must also do their part in protecting the data,
systems, networks, and service they are utilizing.  No technology, data
transmission or system can be guaranteed to be 100% secure.  If you have
reason to believe that your interaction with us is no longer secure (for
example, if you feel that your password to any SGE Software account has been
compromised), please immediately notify us by contacting us using the
instructions in the “

HOW TO CONTACT US

” section below.

5. When SGE Software Shares Your Information

We work through our affiliates to provide the Platform and
other SGE Software Services.  We also work with authorized suppliers and
business partners.  When we share your Personal Information with these
companies, we put in place appropriate measures to limit the use of your
information only for legal and authorized purposes that are consistent with
this Privacy Policy, as well as appropriate confidentiality and security
measures.

We also share information with third parties for advertising
and marketing; when required by law or to respond to legal process; to protect
our customers; to protect lives; to maintain the security of the Platform; and
to protect our legal rights.  We may disclose Personal Information that we
collect or you provide as described in this Privacy Policy:

With Affiliates and Subsidiaries. For purposes limited to and consistent with this Privacy Policy. With Suppliers. Our authorized vendors and suppliers may require Personal Information to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service.  We use a wide variety of software and tools at SGE Software, and we process Personal Information using these tools as a regular course of business.  Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use. With Partners. We occasionally have relationships with third parties that are not suppliers or vendors but are working with us to offer certain opportunities such as marketing and similar promotions, to enable joint products or research studies, or to facilitate services on the Platform.  In these cases, additional terms or Privacy Policies may be provided.  For third parties or uses not described in this Privacy Policy, we share your information only with a lawful basis to do so.

For Advertising and Marketing. We share your information with our third-party company partners to prepare and deliver advertising and marketing content, to provide content services and to enable them to provide you with more personalized ads and to study the effectiveness of our campaigns.

In particular, we use third-party companies to communicate regarding goods and
services that may be of interest to you, in accordance with your
preferences.  You may receive this content by a variety of means such as
email, phone or when you access and use the Platform or other SGE Software
Services, and other websites.  Content may be based on information
obtained, for example, through prior purchases or transactions, through your
device’s physical location, through information about what advertisements and
content you have viewed, or through cookies and similar technologies relating
to your access to and use of the Platform and other websites. Please read
our 

Cookies Policy

 for more information. You can choose whether to allow or deny
uses and/or sharing of your device’s location by changing your device settings,
but if you choose to deny such uses or sharing, our partners may not be able to
provide you with the applicable Platform Services and content.

For Connections to Social Networks and Third Party Services. Where you are using our Services and have chosen to connect your social networks profiles to the SGE Software Services, or if you authorize a third party service to access your account, you are agreeing to provide information about you to the social networks and the third party services under their respective terms and privacy policies. For example, if you choose to connect your YouTube account to the SGE Software Services, this connection uses YouTube’s API services, and the Google Privacy Policy (located here) will apply to you. If you have authorized us to access your information via the YouTube API services, in addition to our normal procedure for deleting stored data, you may revoke our access to your data via the Google security settings page, located here.

Sales, Mergers & Acquisitions. We may disclose Personal Information as part of a contemplated or actual corporate transaction such as a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

With Your Consent. SGE Software may disclose your Personal Information to any other person or entity where you consent to the disclosure. For information about how to decline our advertising and marketing, please see the section entitled "Your Choices & Rights" below.

We do NOT share your phone number or opt-in consent with third parties unless we’ve received your express written consent to do so.

We also share non-personally identifiable information, such
as anonymized or aggregated information, with suppliers for purposes such as
analysis, identifying trends in the areas of our products and to help research
and develop new SGE Software Services.

SGE Software does not sell any of your Personal Information
for monetary compensation.

6. Information From Children

We do not knowingly collect, use, or disclose Information
from children under 16.  If we learn that we have collected the Personal
Information of a child under 16—or the equivalent minimum age depending on the
jurisdiction, such as 13 in the United States per the Children’s Online Privacy
Protection Act—we will take steps to delete the information as soon as
possible.  If you are under 16, do not provide any Information about
yourself to SGE Software, including your name, address, telephone number or
email address. If you become aware that Information of a child under 16 years
of age has been provided, please use one of the methods provided under the “

HOW TO CONTACT US

” section below.

7. Links to Other Websites and Services

We are not responsible for the practices employed by
websites or services linked to or from the Platform, including the information
or content contained therein.  This Privacy Policy does not address, and
we are not responsible for, the policies and practices of third parties or
other organizations that are not operating on SGE Software’s behalf, including
policies and practices related to privacy and security, data collection,
processing, use, storage, and disclosure.  This includes: (a) any third
party operating any site or service to which the Platform links – the inclusion
of a link on the Platform does not imply endorsement of the linked site or
service by us or by our affiliates; or (b) any app developer, app provider,
social media platform provider, operating system provider, wireless service
provider or device manufacturer (such as Facebook, Apple, Google, Microsoft,
LinkedIn, etc.) - including any Personal Information you disclose to other
organizations through or in connection with the Platform or other SGE Software
Services.

8. Do Not Track

Some browsers incorporate a "Do Not Track" (“DNT”)
feature that, when turned on, signals to websites and online services that you
do not want to be tracked.  At this time, the Platform does not respond to
DNT signals.

9. YOUR LEGAL RIGHTS

SGE Software respects your rights in how your Personal
Information is used and shared. Depending on where you live, you may have
rights to request access or corrections to your personal data and make choices
about the kinds of marketing materials you receive (or choose not to receive
marketing from SGE Software at all). See below for more information, depending
on your location.

10. European Privacy Rights

If you are in Europe, you may have additional rights under
the GDPR, the UK GDPR, or nFADP.  Additional choices and rights may be
available to you depending on which SGE Software Services you use.

Access, Correction to or Deletion of Your Information. If you would like to correct or update your Personal Information, or to request access to or deletion of your Personal Information, you may contact us by visiting the Platform or by using the contact details provided under the “HOW TO CONTACT US” section below.  If you request a change to or deletion of your Personal Information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such 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). Some of your information may also remain within our systems and other records where necessary for compliance with applicable law.

At your request and where the law requires us to do so, we will confirm what
Personal Information we hold about you.  You may also have a legal right
to obtain a copy of your Personal Information.  You can make such a
request by making a written request in one of the ways described in the “HOW TO
CONTACT US” section below.  We may charge a processing fee for this
service where permitted by law and we will require evidence of your identity
before fulfilling your request.

Data Privacy Rights Specific to Individuals in the European Economic Area, the United Kingdom, and Switzerland. You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information, or request portability of your Personal Information.  You can exercise these rights by making a written request in one of the ways described in the “HOW TO CONTACT US” section below. Similarly, if we have collected your Personal Information with your consent, you can withdraw your consent at any time.  Withdrawing your consent will not affect (1) the lawfulness of any processing we conducted prior to your withdrawal, or (2) processing your Personal Information under other legal bases. If you believe we are using your Personal Information in a way that is inconsistent with this Privacy Policy or for more information about your rights, contact your local data protection authority.  Additionally, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, you may contact JAMS Mediation, Arbitration, and ADR Services (https://www.jamsadr.com/eu-us-data-privacy-framework) to address complaints and provide appropriate recourse free of charge to you.  Under certain conditions, you may invoke binding arbitration. For additional information on pre-arbitration requirements, please see Annex I of the DPF Principles.

Advertising and Marketing Choices. We give you many choices regarding our use and disclosure of your Personal Information for advertising and marketing purposes.  You may access or update your contact details and modify your communication preferences by using one of the methods provided under the “HOW TO CONTACT US” section below.  Please also note that if you choose not to receive marketing communications from us, we may still send you communications related to your products or the Platform, such as information about a security update, service issue or product delivery.  Some advertising content is delivered through the Platform’s use of cookies and similar technologies.  Our Cookies Policy includes more information on SGE Software’s use of such technologies for advertising and other purposes.

11. International Compliance

SGE Software is a global company with its headquarters in
the United States.  As such, we may transfer your Personal Information
between the United States and our affiliates and business partners in other
countries.  We may also transfer your Personal Information to our third
party service providers, who may be located in a different country to you.

SGE Software transfers information internationally in order
to operate efficiently, to improve performance, and to create redundancies to
protect information in the event of an outage or other problem.  In so
doing, we will process your Personal Information in a way that meets the
commitments of this Privacy Policy and complies with the law wherever we
transfer it.

Whenever SGE Software transfers Personal Information beyond
the country of origin, we will do so in accordance with applicable laws. 
For Personal Information originating in the European Economic Area (EEA), the
United Kingdom (UK), or Switzerland that is transferred to a SGE Software
entity outside the EEA, UK, or Switzerland, SGE Software participates in
the 

EU-U.S. Data Privacy Framework (EU-U.S. DPF)

 and, as
applicable, the UK extension to the EU-U.S. DPF, and/or the Swiss-U.S. Data
Privacy Framework (Swiss-U.S. DPF). SGE Software commits to the DPF Principles
and, as needed, will take additional steps to provide appropriate safeguards
for the Personal Information we transfer. The Federal Trade Commission has
jurisdiction over SGE Software’s compliance with the EU-U.S. DPF, the UK
Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF).  SGE Software may
be required to disclose Personal Information in response to lawful requests by
public authorities, including to meet national security or law enforcement
requirements. SGE Software is liable in cases of onward transfers to third
parties.

12. Data Privacy Framework

SGE Software Inc. and LeadConnector LLC comply with the
EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S.
DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by
the U.S. Department of Commerce. SGE Software has certified to the U.S.
Department of Commerce that SGE Software and LeadConnector adhere to the
EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard
to the processing of personal data received from the European Union in reliance
on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on
the UK Extension to the EU-U.S. DPF. SGE Software has certified to the U.S.
Department of Commerce that SGE Software and Leadconnector adhere to the
Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with
regard to the processing of personal data received from Switzerland in reliance
on the Swiss-U.S. DPF. If there is any conflict between the terms in this
privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF
Principles, the Principles shall govern. To learn more about the Data Privacy
Framework (DPF) program, and to view our certification, please visit 

https://www.dataprivacyframework.gov/

.
SGE Software further agrees to notify you without undue delay, if its
self-certifcation under any of the Data Privacy Framework is withdrawn,
terminated, revoked or otherwise invalidated and provide take appropriate steps
to stop and remediate and unauthorized processing of such personal data.

13. California Privacy Rights

This section is addressed to California residents only and
provides more information about your rights under the California Consumer
Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.), as
amended. Subject to certain exceptions, the CCPA grants to California residents
the rights to: be notified about the collection, use, disclosure, sale or
sharing of their Personal Information; request access to, deletion of, or
correction of their Personal Information; request to opt out of the “sale” or
“sharing” of Personal Information (where such information is sold or shared);
limit the use or disclosure of Sensitive Personal Information (as defined under
CCPA); and to not be discriminated against for exercising such rights.

SGE Software does not sell your Personal Information. 
If you wish to exercise your right to opt-out of SGE Software using your
Personal Information for cross-contextual targeted advertising purposes (called
“sharing” under the CCPA), you may do so by using the details in the “

HOW TO CONTACT US

” section or the appropriate withdrawal mechanism provided to you
on the Platform.

You can request access to, correction of or deletion of your
Personal Information by using the details in the “

HOW TO CONTACT US

”
section.  If you request a deletion of your Personal Information, please
note that SGE Software may still need to retain certain information for
recordkeeping purposes, to complete any transactions that you began prior to
requesting such deletion, to comply with applicable law, or for other purposes
permitted by CCPA.  If you submit a request to exercise rights under CCPA,
SGE Software will ask you to provide certain information to verify your
identity.  This information will depend on your prior interactions with SGE
Software and the sensitivity of Personal Information at issue.  If SGE
Software denies your request, we will explain why.

You can designate an authorized agent to make a request
under the CCPA on your behalf in certain circumstances. If you use an
authorized agent for this purpose, SGE Software may ask you to verify your
identity or that you provided the authorized agent signed permission to submit
a request under the CCPA.  If you provide an authorized agent with power
of attorney pursuant to Probate Code sections 4000 to 4465, it may not be
necessary to perform these steps and SGE Software will respond to any request
from such authorized agent in accordance with the CCPA.

The Privacy Policy describes the categories of Personal
Information that SGE Software collects and how SGE Software uses such Personal
Information. If SGE Software collects Sensitive Personal Information, we limit
our use of the Sensitive Personal Information to uses: (1) you have authorized,
(2) that are required to fulfill your requests for goods or services, or (3)
that are otherwise allowed by the CCPA or required by other laws or
regulations.

The categories of Personal Information collected, disclosed,
and sold from California residents over the preceding 12 months and SGE
Software’s applicable retention periods include:

Personal Information Category Retention Period Business Purpose Collected Disclosed Sold

Identifiers (such name, address, IP address, email, etc.)

See Section 3 of Privacy Policy: “Retention of Your
Personal Information”

For functionality, customer support, business operations,
communication, advertising and marketing, and statistical purposes.

Yes

Yes

No

Personal information defined in Civil Code Section
1798.80(e) (such as signature, SSN, financial information, and insurance
information, etc.)

No

No

No

Protected personal information (such as gender, religion,
sexual orientation, or disability)

No

No

No

Commercial information (such as products or services
purchased, obtained, or considered, or other purchasing or consuming
histories or tendencies, etc.)

See Section 3 of Privacy Policy: “Retention of Your
Personal Information”

For development, customer support, business operations,
communication, advertising and marketing, and statistical purposes.

Yes

No

No

Biometric information

No

No

No

Internet or other similar network activity (such as
information on a consumer’s interaction with a website, application, or
advertisement, etc.)

See Section 3 of Privacy Policy: “Retention of Your
Personal Information”

For functionality, business operations, and statistical
purposes.

Yes

Yes

No

Geolocation data

No

No

No

Audio, electronic, visual, thermal, or olfactory
information

No

No

No

Professional or employment-related information

No

No

No

Education information

No

No

No

Inferences (such as analytics and preferences

Yes

Yes

No

14. Colorado Privacy Rights

This section is addressed to Colorado residents only and
provides more information about your rights under the Colorado Privacy Act or
“CPA.” Subject to certain exceptions, the CPA grants to Colorado residents the
rights to: be notified about the collection, use, disclosure, or sale of their
Personal Information; request access to, deletion of, or correction of their
Personal Information; and request to opt out of the use of Personal Information
for targeted advertising, sale, or certain profiling.

You can request access to, correction of or deletion of your
Personal Information by using the details in the “

HOW TO CONTACT US

”
section. If you request a deletion of your Personal Information, please note
that SGE Software may still need to retain certain information for
recordkeeping purposes, to complete any transactions that you began prior to
requesting such deletion, to comply with applicable law, or for other purposes
permitted by CPA.  If you submit a request to exercise rights under CPA, SGE
Software will ask you to provide certain information to verify your identity.
This information will depend on your prior interactions with SGE Software and
the sensitivity of Personal Information at issue. If SGE Software denies your
request, we will explain why. If we have not responded to your request or asked
for additional time to respond to your request within 45 days after you send us
a request, you have the right to appeal our failure to take action. To appeal
our failure to take action, contact us using the details in the “

HOW TO CONTACT US

” section.

You can designate an authorized agent to make a request
under the CPA on your behalf in certain circumstances. If you use an authorized
agent for this purpose, SGE Software may ask you to verify your identity or
that you provided the authorized agent signed permission to submit a request
under the CPA.

15. Connecticut Privacy Rights

This section is addressed to Connecticut residents only and
provides more information about your rights under the Connecticut Data Privacy
Act or “CTDPA.” You can exercise your rights by using the details in the “

HOW TO CONTACT US

” section. If we inform you that we decline to take action
regarding your request, you have the right to appeal our failure to take action
by contacting us using the details in the “

HOW TO CONTACT US

” section.

16. Utah Privacy Rights

This section is addressed to Utah residents only and
provides more information about your rights under the Utah Consumer Privacy Act
or “UCPA.” You can exercise your rights by using the details in the “

HOW TO CONTACT US

” section.

17. Virginia Privacy Rights

This section is addressed to Virginia residents only and
provides more information about your rights under Virginia’s Consumer Data
Protection Act or “VCDPA.” Subject to certain exceptions, the VCDPA grants to
Virginia residents the rights to: be notified about the collection, use,
disclosure, or sale of their Personal Information; request access to, deletion
of, or correction of their Personal Information; request to opt out of the use
of Personal Information for targeted advertising, sale, or certain profiling;
and to not be discriminated against for exercising such rights.

You can request access to, correction of or deletion of your
Personal Information by using the details in the “

HOW TO CONTACT US

”
section. If you request a deletion of your Personal Information, please note
that SGE Software may still need to retain certain information for
recordkeeping purposes, to complete any transactions that you began prior to
requesting such deletion, to comply with applicable law, or for other purposes
permitted by VCDPA.  If you submit a request to exercise rights under
VCDPA, SGE Software will ask you to provide certain information to verify your
identity. This information will depend on your prior interactions with SGE
Software and the sensitivity of Personal Information at issue. If SGE Software
denies your request, we will explain why. If we inform you that we decline to
take action regarding your request, you have the right to appeal our failure to
take action. To appeal our failure to take action, contact us using the details
in the “

HOW TO CONTACT US

'' section.

18. How To Contact Us About This Privacy Policy

To ask questions about this Privacy Policy and our privacy
practices, contact us at 

[email protected]

 or
by mail at:

SGE Software Inc.

ATTN: Legal Department 400 North Saint Paul St., Suite 920

Dallas, Texas 75201

For the UK:

Simply Business Consulting

- SGE Software Inc. -

PO Box 1487

Warwickshire

United Kingdom

[email protected]

For the EU:

Rickert Rechtsanwaltsgesellschaft mbH

- SGE Software, Inc. -

Colmantstraße

1553115 Bonn

Germany

art-27-rep-SGE [email protected]

In compliance with the EU-U.S. DPF, the UK Extension to the
EU-U.S. DPF, and the Swiss-U.S. DPF, SGE Software commits to resolve DPF
Principles-related complaints about our collection and use of your personal
information. EU, UK, and Swiss individuals with inquiries or complaints
regarding our handling of personal data received in reliance on the EU-U.S.
DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first
contact SGE Software at: 

[email protected]