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Streem – Privacy Policy

Effective Date: December 15, 2020

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Streem, LLC (“Streem”), as a controller and responsible party for the personal information you provide to us, understands that you care about how we collect, use, and share your information when you interact with us, and we value the trust you place in us. Streem provides this Privacy Policy on behalf of itself and certain of its affiliates. This Privacy Policy explains:

1. The types of information we collect through our Services (as defined below);

2. How we use that information;

3. The types of information we share and under what circumstances;

4. The choices you have regarding our collection, use, and sharing practices;

5. The steps we take to protect and secure your information; and

6. Your rights under applicable data protection laws.

Generally, we use your information to deliver our Services, gather data for our internal analytics, develop new products and services, and for marketing and other legitimate business purposes. It is important that the personal information we hold about you is accurate and current. Please inform us if your personal information changes during your relationship with us.

This Privacy Policy applies to Streem and our website (the “Website”), web-based applications, our mobile application (the “App”), online services and other interactions with users both online and offline (collectively, the “Services”), including in certain circumstances where the Services are incorporated into a business partner’s offering, as further described herein.

Please note that your access and use of the Services may be governed by further written agreement between you and Streem, or a written agreement between you and one of Streem’s business partners.

WHAT DO WE COLLECT?

We may collect different types of information about you, depending upon how you interact with us. This information may include personal information, business information, financial information, demographic information, log-in information, device information, and location information. Sometimes we collect combinations of all these types of information or aggregate some or all of these types of information to improve the Services and facilitate other legitimate business purposes.

Information You Give Us

Some of the Services may include features or services that permit you to enter contact information and other information about you. The information may vary depending on whether you are an individual (“Customer”) seeking to engage a professional or a professional (“Provider”) delivering services to a consumer.

We collect and store information you provide or that is provided by Providers on your behalf in connection with our Services. This may include:

1. Information you provide to Streem or to Providers. This consists of any contact information that you provide through the App or other communications with Streem, Providers or their organizations. We may collect information such as your name, location data, email, address and phone number.

2. Information you provide when you interact with us directly through a Provider. For our technology to work, our Services require that you provide us with access to the camera and microphone for the device on which you are using Streem. If you are a Customer and you choose to connect with a Provider via our Services, that Provider has the option to initiate recording the video of that conversation. By using the Services, you consent to the recording of any conversations you have via the Services; if you are a Customer and do not wish to be recorded, please discuss this with the Provider prior to participating in a call. Recorded videos are stored and accessible through the Provider’s account. Recorded videos may also be shared by a Provider within their organization (where applicable) to deliver their services or with other entities, according to the data-use practices established by the Provider or such other entities. The content of any recorded video is determined solely by how you use your device’s camera during a video communication with a Provider (for example, by turning your device’s camera towards yourself), and you hereby give your explicit consent to Streem to receive and process such content.

3. Information you provide to us via social media. This includes any posts, pictures, videos and messages which you submit to us via our social media accounts on other sites (including by use of hashtags associated with us).

4. If you contact us, we keep a record of that communication and any contact information provided. This information may be collected through any communication with Streem, such as through video, email or the App.

5. Professional and Employment Related Information. If you apply for a job with us, you may provide us with certain personal information about yourself, such as information contained in a resume, cover letter, or similar employment-related materials. We may also collect personal information in conducting reference checks as part of the job application process. If you are a Provider, we may collect information about you, your employer, or your employment status in order to authenticate and manage your use of the Service.

6. Information you provide when you enter a contest or participate in a promotion. We may collect your name, address, phone number, email address, and other information you provide.

Streem does not facilitate payments between Customers and Providers, and Providers do not share Customer payment information with us. Please do not provide a credit card number, social security number, or other sensitive information during a Streem video session.

When Customers connect with Providers, Streem facilitates the exchange of information (e.g., videos, photos, sound, location data and data about products or the environment) between them and collects that information. Streem is not responsible for any recording or access of personal information exchanged by either party that occurs outside of the Services. When using the Services, you agree to abide by Streem, LLC’s Terms of Use as applicable to you.

Information We Collect Automatically

When you interact with the Services, certain information about your use of the Services is automatically collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. This includes:

1. Technical and usage information. We collect details of your visits to our Website or App and information generated in the course of the use of our Website or Services including, but not limited to, the timing, frequency and pattern of use, the type of device, browser, and operating system you are using, information about your internet connection data, location data, weblogs and other communication data, the resources that you access, and how you reached our Website or App. See our Cookies and Other Automatic Information Gathering Technologies section for more information on how we may use these technologies to collect this information. 2. Email information. We collect information about how you interact with emails we send you, including whether you open or click links in our email communications.

3. Social media account information. We may collect information that you make available to us on a social media platform, including your account ID or username and other information included in your posts. We do not have access to or collect any information contained in the direct messages of your social media account.

WHY DO WE COLLECT THIS INFORMATION AND HOW DO WE USE IT?

We use the information we collect from you, subject to, and where allowable under, applicable laws, for the following purposes:

1. To further our purpose of offering technology to connect Customers and Providers.

2. To communicate with you, including to respond to inquiries, provide the best service, and to send you communications regarding service features.

3. To analyze Website or App usage and enhance their operation.

4. To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.

5. To allow Providers to register and create an account and profile in connection with the Services (and elsewhere).

6. To share your information with our parent company, affiliates and subsidiaries for those purposes set forth herein.

7. So we or our parent company, affiliates or subsidiaries may provide the Services, conduct marketing activities, develop new products or services (for example, products or services that link appliances to a specific home or other specific location) or conduct activities related to or in furtherance of those purposes set forth herein for which we use your information, in each case, solely where we consider appropriate and have an appropriate legal basis. If we use or share your location information for the development of new products or services, none of the other types of personal information we collect from you will be used in such products or services (or the development thereof).

8. To complete transactions you have requested or upon which you assist.

9. To enable you to provide us with feedback.

10. To administer promotions you enter into such as a contest or sweepstakes.

11. To alert you to changes and updates in our Services or policies.

12. To send you communications that may be of interest to you, such as emails or text messages about Streem and its parent company, affiliates and subsidiaries and their products or services.

13. To develop, customize, measure, test and improve products, services, content and advertising.

14. To personalize your overall experience with Streem.

15. To respond to law enforcement and regulatory requests, or as required by applicable law, regulation or court order.

16. In connection with a merger, acquisition, divestiture, restructuring, reorganization, dissolution or other transaction involving some or all of our assets that include your information.

17. To manage aspects of your relationship with us, including but not limited to establishing, maintaining and terminating a business relationship, general operations, and administrative, financial and human resources related purposes.

18. For certain other purposes disclosed at the time you provide your information.

19. As otherwise set forth in this Privacy Policy.

We process your information on the following legal bases: (a) with your consent; (b) as necessary to perform under an applicable agreement to provide Services and (c) as necessary for our legitimate interests in providing the Services, where those interests are not overridden by your fundamental rights and freedoms related to data privacy.

If our processing of your personal information is based on your consent, you are free to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before such withdrawal.

We will only use your personal information for the purposes for which we collected it, unless (a) we reasonably believe that we need to use such personal information for another reason and (b) that reason is compatible with the original purpose for which such personal information was collected.

If we plan to use your personal information for an unrelated purpose (as compared to a purpose compatible with the original purpose for which such personal information was collected), we will notify you reasonably promptly and explain the legal basis for that use. We may process your personal information without your knowledge or consent, in compliance with the above, where required or permitted by applicable law.

Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfill the purposes for which we collected such personal information, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. 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 of 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.

If you would like to obtain detailed information on retention periods regarding specific information categories, please contact us at support@streem.com.

WHO DO WE SHARE INFORMATION WITH?

We share your personal information with third parties only if (a) you have consented to such sharing (including as such sharing is described in this Privacy Policy), (b) such sharing is necessary for the performance of our Services, (c) we have other legitimate interests in such sharing or (d) such sharing is required or permitted by applicable law.

External Processors. We may share your information with processors to perform functions on our behalf such as data storage, certain technical capabilities of the Services, website and software development, and

analytics. Our processors are given the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes.

Business Partners. Our business partners may use the Services to provide services to you, including by enabling you to identify and engage Providers (whether through the App or a business partner’s offering that incorporates the Services). When you utilize the Services through another entity or otherwise interact with another entity in connection with your use of the Services, this Privacy Policy will govern Streem’s use of your information but that entity will also have access to (and may own or control) your information, including because that information may be used to deliver the services you request, and that entity’s privacy practices will govern its use of such information.

Your Employer. If you are a professional employed by a Provider or if you are an employee of a company that has an enterprise relationship with Streem to offer you our Services (for example, as a means to provide you with IT support in your office), we may share certain information with your employer. Specifically, your company may have designated one or more administrators who can see the names and contact information of employees who have created accounts with Streem. We may allow employers to access the content of video calls, as well as provide information to your company regarding how many employees are active or not active users of Streem.

Parent Company, Affiliates and Subsidiaries. We may share your information with our parent company, affiliates and subsidiaries for legitimate business purposes, including to allow for our parent company, affiliates and subsidiaries to develop and modify products and services that may be of interest to you or other consumers.

Social Media Platforms. Where you choose to interact with us through social media, your interaction with social media providers typically allows that platform to collect some information about you through cookies they place on your device and other tracking mechanisms. In some cases, that social media platform may recognize you through its tracking even when you do not interact with their application(s). Please visit the social media platforms’ respective privacy policies to better understand their data collection practices and controls they make available to you.

ADDITIONAL INFORMATION ABOUT OUR DATA COLLECTION AND SHARING PRACTICES

Sharing of Data. We may analyze data and share these analyses at our discretion in order to provide or enhance the Services (or develop, provide and enhance other products or services), including with Providers and external processors.

Change of Ownership or Corporate Organization. We may transfer to another entity or its affiliates some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, or financing transaction (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Streem or as part of a corporate reorganization or other change in corporate control. We cannot guarantee that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Cross-Border Transfer of Data. You understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the United States regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. To the extent allowable under applicable law, by using the Services, you consent to the collection, international transfer, storage, and processing of your data.

Where required or permitted by applicable law, we may share information for other reasons we disclose to you.

HOW WE SECURE THE INFORMATION WE COLLECT FROM OR ABOUT YOU

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services, including encryption of data. While we use these precautions to safeguard your personal information, like any company, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf, and, to the extent allowable under applicable law, you use our Services at your own risk.

Cookies and Other Automatic Information Gathering Technologies

Cookies: Our Website uses a technology called “cookies”. A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s device so that we can recognize the user’s browser when they return. Most web browsers automatically accept cookies but, if you prefer, you can modify your browser or device setting to disable or reject cookies. Some cookies are strictly necessary for us to provide our Services. These cookies will be placed automatically. To the extent required under applicable law, before we use any other cookies or tracking services, we will ask for your consent. If you delete your cookies or if you decline to enable our use of cookies, some features of the Services may not be available, work, or work as designed. For questions about our cookie practices, contact us at support@streem.com.

You may be able to opt-out of or block tracking by interacting directly with the third parties whose tracking technologies are integrated directly through our Website and App. Please see below for more information.

Additional Information About Our Use of Tracking Technologies

Streem relies on partners to provide many features of our Website and Services using data about your use of Streem and other sites. We may use cookies for the following purposes:

1. Website and App operations: Enabling features that are necessary for providing you the Services on our Website and App.

2. Analytics: Allowing us to understand how our Services are being used, track Website performance and make improvements.

3. Personalized marketing: Delivering tailored communications or advertising to prospective customers or interests across services and devices and measuring the effectiveness of these communications.

4. Social media: Enabling the sharing of content from our Services through social networking and other sites.

We use Google Analytics, a web analytics service provided by Google Inc., on our Website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Website, compile reports on the Website’s activity, and provide other services related to Website activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here https://policies.google.com/.

Below is a list of third parties we use for information gathering purposes with links to more information on their use of your data and how to exercise your options regarding tracking:

Analytics:

Segment - Privacy Policy

Looker – Privacy Policy

Datadog – Privacy Policy

Hotjar - Privacy Policy

Personalized Advertising, Social Media:

Twitter - Privacy Policy

Facebook - Data Policy

LinkedIn Privacy Policy

Site Operations:

HubSpot Privacy Policy

Interest Based Advertising - We may work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate our online advertising campaigns.

Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioral ads from third-party advertising companies participating in the Digital Advertising Alliance’s Webchoices tool: https://optout.aboutads.info/.

Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.

To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.

YOUR OPTIONS AND RIGHTS

Information Stored on Account Profiles of Providers

If you are a Provider, please visit the Settings section in the App to update your profile information. Providers may request deletion of their profile or any information contained in their account by emailing us at support@streem.com.

Marketing Communications

If at any time you would like to unsubscribe from receiving future marketing emails, you can click the unsubscribe link at the bottom of any email bulletin, or email us at support@streem.com and we will promptly remove you from applicable communications.

Interest-Based Advertising

To opt out of interest-based advertising, see the “Interest-Based Advertising” section above.

USERS UNDER 16

Our Website and Services are intended for users ages 16 and older. Accordingly, we will not knowingly collect or use any information from children that we know to be under the age of 16. If we become aware of information collected from a child under 16, we will delete such information.

YOUR CALIFORNIA PRIVACY RIGHTS

Residents of the state of California also have the right to request information regarding third parties to whom Streem has disclosed certain categories of personal information during the preceding year for such third parties’ direct marketing purposes. To make such a request, please send your request by email to support@streem.com.

NOTICE OF CALIFORNIA CONSUMER DATA COLLECTION AND SHARING PRACTICES

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to access and control Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a federal privacy law, such as the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to Access Information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect your Personal Information, we are required to verify your identity before we act on your request.

Right to Request Deletion of Information

You have the right to request in certain circumstances that we delete Personal Information that we have collected directly from you. To protect your Personal Information, we are required to verify your identity before we act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Sale of Personal Information

In the preceding twelve (12) months, we have not sold Personal Information. In addition, we will not sell Personal Information during any time period in which this Privacy Policy does not set forth instructions with respect to a consumer’s “right to opt-out” of the sale of Personal Information.

How to Submit a Request

You may submit a request by sending us an email at support@streem.com or calling us at (833) 729-2890.

Information Regarding the Categories of Personal Information Collected and Disclosed

The following is a description of our data collection practices, including the Personal Information we collected, the sources of that information, the purposes for which we collect information, and whether we disclose that information to external parties. We may use any and all of the information for any of the purposes described in this Privacy Policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CCPA.

1. Personal identifiers: We collect your name, phone number, email address, and/or location when you provide it to Streem as a part of creating an account or using the Services (and we may collect the same when you are using a third party offering incorporating the Services).

o We do not collect your Social Security number, driver’s license number, or passport number.

o We do not collect any medical information or health information about you.

o We do not collect your payment information or financial account information.

o We collect your IP address automatically when you use our Services.

o We collect your device ID automatically when you use our Services.

2. Commercial information: When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies.

3. Internet or other electronic network activity information: We collect information about your use of our Services, including details of your visits to our Website or App and information generated in the course of the use of our Website or Services including, but not limited to, the timing, frequency and pattern of use, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our Website.

4. Geolocation data: We may collect location data from you, including in cases where a Provider asks for your location to provide services. Whether or not you are a California resident, we collect your precise location (e.g., your GPS coordinates) only when you provide your consent.

5. Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone or videoconference, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We do not collect your image or any thermal, olfactory, or similar information.

6. Professional or employment-related information: If you are a professional using the Streem service on behalf of your employer, we may collect information about you, your employer, or your employment status in order to authenticate and manage your use of the Service.

7. Education information: We do not collect any information about the institutions you have attended or the level of education you have attained.

8. Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We do not collect information about your preferences or characteristics or for the purpose of creating a profile.

We may share any of the above-listed information with service providers, which are external parties that we engage for business purposes and are restricted from using personal information for any purpose that is not related to our engagement. The categories of service providers with whom we share information and the services they provide are described herein. We may also disclose information to other external parties who are not listed here when required by law or to protect our company or other persons.

Information for Individuals Located in the UK, EEA and Switzerland

Right to lodge a complaint

Users that reside in the UK, EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here and here.

Transfers

Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities, as described above. We will transfer this data using the standard contractual clauses as adopted by the European Commission from time to time or such other safeguards as may be required by applicable data protection laws.

Individual Rights

If you are a resident of the UK, EEA or Switzerland, you are entitled to certain rights. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you. These rights include the ability:

1. to request from us access to personal information held about you;

2. to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;

3. to ask for personal information to be erased if (a) the information is no longer necessary for the purpose for which it was collected, (b) you withdraw consent and no other legal basis for processing exists, (c) if our processing of such information is not based on legitimate grounds, or (d) we are under a legal obligation to erase your information;

4. to request that we restrict our processing if (a) you contest the accuracy of your personal information, for a period enabling us to verify the accuracy of the personal information, (b) the processing is unlawful and you request restriction on processing rather than erasure, (c) we no longer need the personal information for the purposes of our processing but such information is required by you to establish, exercise or defend a legal claim, or (d) you have objected to our processing, for the period pending resolution as to whether our legitimate grounds in processing override your rights and interests;

5. to receive the personal information you have provided to us in a structured, commonly used and machine-readable format in order to transmit that information to another controller where (a) our processing is based on your consent or necessary for the performance of a contract to which you are party, and (b) such processing is carried out by us using automated means; and

6. to object to, on grounds relating to your particular situation, our processing of your personal information to the extent such processing is based upon our legitimate interests. Once you exercise your right to object, we will no longer process the relevant information unless we have compelling and legitimate grounds for such processing which override your interests, rights and freedoms, or to the extent such processing is conducted in connection with the establishment, exercise or defense of legal claims.

 

To submit a request to exercise your rights, please contact us at support@streem.com. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Information for Individuals Located in Canada

Transfer of Personal Information

We and our service providers may disclose your personal information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate. For information about the manner in which we or our service providers treat personal information, please contact us as set out in the “Contact Us” section of this Privacy Policy.

Access

Subject to limited exceptions under applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody and control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

Changes to This Policy

We may make changes to this Policy from time to time. Such changes will become effective when they are posted. We will notify you of any material changes to this Privacy Policy by posting a Privacy Policy with an updated date on the Website and will obtain your consent, where required by law, either through your registered email address or by prominent posting on the Website. Where permitted by law, your continued use of our Services following the posting of any changes will mean you accept those changes. Please consult this page periodically to ensure familiarity with the most current version of this Privacy Policy.

Contact Us

For questions about our privacy practices, you may contact our Privacy Officer at support@streem.com.