PRIVACY NOTICE FOR CALIFORNIA RESIDENTS UNDER THE CALIFORNIA PRIVACY RIGHTS ACT

Last Updated: January 23, 2023.

This privacy notice for California residents supplements the information contained in the Privacy Policy of Simple Link Network Malta Limited dba Simple Link Network Ltd. and its subsidiaries (collectively, “we,”, “us,” or “our”) and applies to Visitors, Users, and Customers who reside in the State of California (“consumers” or “you”) We adopt this notice to comply with the California Privacy Rights Act of 2020 (“CPRA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

This statement refers to the information collected either automatically or, as submitted by you, when you access, use or visit our Site, consume our Services or otherwise engage with us (as those terms are defined in our Privacy Policy).

1. CATEGORIES OF PERSONAL INFORMATION COLLECTED ABOUT YOU

As described in our Privacy Policy, the following data categories are collected about you:

• Identifiers (online and physical)
• Online and network activity
• Device information
• Usage information
• Payment and billing information
• Marketing and advertising information
• Customer support and customer relation information

For more details about the elements in each category, please refer back to our Privacy Policy

2. SHARING INFORMATION

• We do not sell your personal information or share it for monetary gain.
• We may disclose your personal information to a third party for a business purpose, including our Affiliated Companies. When we do so, we enter 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.
• In the preceding twelve (12) months, we have shared the following categories of personal information for a business purpose:

Category	Business Purpose
All categories	Our hosting, processing, infrastructure and security service providers in order to provide, facilitate, process and secure the Applications, the data and the services.
Internet and network data	Service providers, web platforms, analytics services and online marketing platforms.
Business relations	CRM and mailing list platforms
Support and customer services	Support and help desk services
Contact information	Customer support services
Billing information	Payment processing
Cookies and certain online identifiers	Marketing and advertising of the Services, analytics, Website and Services functionality
Legal Proceedings or law requirements	Complying with applicable Laws, regulations, legal process, or governmental requests

3. YOUR RIGHTS

The CCPA provides consumers who are California residents with certain rights regarding their personal information. Below we describe your CPRA rights and explain how to exercise those rights:

3.1. Access to Certain Information and Data Portability Rights

You have the right to request us to disclose certain information to you about our collection and use of your personal information over the past 12 months. If you have an account with us, you can exercise your right directly via your account, or make a request to us as described below. Once we receive and confirm your verifiable consumer request, we will disclose the information you have requested, which could be one of the following types:

• 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 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.

3.2. Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (see below). If you have an account with us, you can exercise your right directly via your account, or make a request to us as described below. When applicable, once we receive and confirm your verifiable consumer request, 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 providers to:

• 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 a customer/you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (CalOPPA).
• 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.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

3.3. Rectification Rights

You have the right to request that we correct any inaccurate personal information that it has collected about you, including

• The right to request that we delete any incomplete or inaccurate personal information that it has collected about you
• You have the right to request that we provide a method to directly correct your personal information only if you have an online account and the information is reasonably available through the account.

Note: These rights to rectification only apply to the personal information we collected about you and do not apply to personal information that we received from a third party.

3.4. Right to Opt-out of the Sale or Share of Personal Information

Simple Link Network Ltd. is not in the business of selling, renting, or disclosing personal information to third parties for their direct marketing goals. We will only disclose personal information to third party marketers upon your request.

3.5. Exercising your rights and choices

• To exercise the access, data portability, and deletion rights described above, you can choose the relevant options via your account. If you don't have an account with us, you can submit a verifiable consumer request to us by email to: [email protected] or directly via the account you maintain with us. Please see below how to submit your request
• Only you or a person registered with the California Secretary of State that you authorize 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 such a request for access or data portability twice within a 12-month period.
• The request must:

• Be made by a registered California resident, or someone on their behalf.
• 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 request does not require you to create an account with us if you do not already have one. We will only use personal information provided in a verifiable consumer request to verify the identity or authority to make the request.

3.6. Response Timing and Format

• We strive to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
• If you do not have an account with us, we will deliver our written response by email. 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 that is the case.
• For data portability requests, we will select a format to provide your personal information that is readily usable 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.

4. NON-DISCRIMINATION

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

5. DO NOT TRACK SIGNALS

Do Not Track is a privacy preference that can be configured in certain web browsers (the “DNT Feature”); the DNT Feature, when enabled on a web browser, signals the websites you visit that you do not want certain information about your visit collected. Undertone does not currently respond or recognize DNT Feature signals.

6. CHANGES TO THIS PRIVACY NOTICE

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you as per the notification mechanism described in our Privacy Policy or as otherwise required by applicable laws.

7. CONTACT INFORMATION

If you have any questions or comments about this notice, our privacy statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: [email protected].

Simple Link Network Malta Limited dba Simple Link Network Ltd

28, Triq Hal Dwieli, Sliema, Zebbug ZBG 3250, Malta.