Ohana, Inc., as well as any present or future affiliated or related company (“Ohana” or “we”), recognizes the importance of your privacy. This privacy policy tells you what personal information we collect, how we use it, and what controls we have over it. Ohana may change this privacy policy from time to time, in its sole discretion, as discussed in section 8 below. By registering an account with us (“Account”) or otherwise using or visiting any Ohana website, application, product, software, tool, data feed, and/or service (collectively, the “Service”), you understand and agree to the terms of this policy. Please read this policy carefully.

1. What Information Do We Collect?

a. Personally-Identifiable Information:We may collect personally identifiable information – that is, information which can either directly or indirectly identify a person – when you specifically and knowingly provide it to us, for example when you register an request a demo or register and provide personal information such as your e-mail address, name, phone number, year of birth, or other information. Where applicable, personally identifiable information includes “personal data”, “personal information” and/or “sensitive personal information” each as defined in applicable law. We ask that you not send us, and you do not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or geneticcharacteristics, criminal background or trade union membership) on orthrough Services or otherwise. If you do send or disclose any sensitivepersonal data to us, you consent to our processing and use of such sensitive personal data in accordance with this policy.

This policy does not apply to the privacy practices of third parties that we do not own or control, including but not limited to any third party websites, services, applications, online resources to which the Servicemay link or otherwise reference (collectively “Third Party Services” or “TPS”) that you may access through the Services. For example, the Services utilize the YouTube API Services as a TPS, and you are agreeing to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms), Privacy Policy (http://www.google.com/policies/privacy), and API Services Terms of Service (https://developers.google.com/youtube/terms/api-services-terms-of-service) when engaging YouTube content and services through the Service. Our use of information received from Gmail APIs will adhere to Google’s Limited Use Requirements (https://developers.google.com/terms/api-services-user-data-policy). We take no responsibility for the content or privacy practices of any TPS. We encourage you to carefully review the privacy policies of any TPS you access.

You may have the option to register an Account with us using a TPS, and you may connect your Account to a TPS such as Instagram, Facebook, Twitter or YouTube. By authorizing us to access your TPS account, you authorize us to obtain certain information from your TPS account, which may including your name, email address, birthday, work history, education history, current city, shared media, and the names, profile pictures, relationship status, and current cities of your TPS contacts. We only obtain information from your TPS account that you specifically authorize and grant us permission to obtain. Our use of information received via Google Restricted Scopes, such as from Gmail APIs, will adhere to Google’s Limited Use Requirements (https://developers.google.com/terms/api-services-user-data-policy)

Ohana does not consider personally identifiable information to include information that has been anonymized so that it does not allow a third party to identify a specific individual or household. We collect and use your personally-identifiable information to: provide the Services; operate and improve our Service; provide customer service; perform research and analysis aimed at improving our products, Service and technology; and display content that is customized to your interests and preferences.

You may always choose not to provide personally identifiable information, but if you so choose, certain parts of the Service may not be available to you. If you have registered an Account with us, you willhave agreed to provide your personally identifiable information in order to access the Services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Services.

b. Non-Personally-Identifiable Information:We may collect and aggregate non-personally identifiable information which is information which does not permit you to be identified or identifiable either by itselfor in combination with other information available to a third party. This information may include information such as a website that referred you to us, your hardware types, geographic location, log data, and access times and durations. We also may collect navigational information, including information about the Service content or pages you view, the links you click, and other actions taken in connection with the Service. We use this information to analyze usage patterns aspart of making improvements to the Service.

c. Cookies, Pixels and Local Storage:We may collect information using “cookies”, which are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device untilyou delete them) to provide you with a more personal and interactive experience when using the Services.

We use two broad categories of cookies: (1) first party cookies, serveddirectly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits anysite or application that is party of the Services; and (2) third party cookies, which are served by service providers on sites or applicationsand can be used by such service providers to recognize your computer or mobile device when it visits other websites.

i. Cookies we use

We use two broad categories of cookies: (1) first party cookies, serveddirectly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits anysite or application that is party of the Services; and (2) third party cookies, which are served by service providers on sites or applicationsand can be used by such service providers to recognize your computer or mobile device when it visits other websites.

ii. Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you use the Services

iii. Pixel Tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on the Services to track the actions of users on our sites and applications. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

iv. Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,”please visithttp://www.allaboutdnt.com.

2. What Do We Do With The Information That We Collect?

Except as disclosed in this policy, Ohana does not share or sell your personal information to any outside parties.

a. Ohana will use the personally identifiable information directly provided by you solely for the purpose for which you have provided it, which may include:

We may share this information with service providers who perform services on our behalf, such as those services listed above, or other services like processing information requests, providing security services, displaying stored data you access, to assist us in marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need to provide the service they provide, will be required to maintain the confidentiality of the information, and will be prohibited from using it for any other purpose.

We will only retain your personally identifiable information as long as reasonably required to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes). Data collected via the YouTube API will be retained for a maximum of 30 days unless required to provide you withthe Services or a longer retention period is required by law.

You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) our collection of sensitive personal data; (iii) any new processing of your personal data that we may carry out beyond the original purpose; or (iv) the transfer of your personal data outside the European Economia Area (if it originates from the EEA). Please note that your use of some of the Services may be ineffective upon opt-out.

b. Disclosure:As a general rule, Ohana will not disclose any of your personally identifiable information except under one of the following circumstances: we have your permission, including the permission granted by your acceptance of this policy; we determine in good faith that it is legally required to be revealed by any relevant statute, regulation, ordinance, rule, administrative or court order, decree, or subpoena; it is information that we determine must be disclosed to correct what we believe to be false or misleading information or to address activities that we believe to be manipulative, deceptive or otherwise a violation of law; where you are otherwise notified at the time we collect the data; where we need to share your information to provide the product or service you have requested; when such disclosure is made subject to confidentiality restrictions in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by Ohana. Ohana may share the non-personally identifiable information that Ohana gathers, in aggregate form only, with advertisers and other partners.

3. Your Rights

Consistent with applicable law, you may exercise any of the rights described in this section. See here for information on personal data rights requests and how to submit a request. Please note that we may ask you to verify your identity and request before taking action on yourrequest.

a. Managing Your Information.If you have an Account, you may access and update some of your information through your Account settings. If you have connected your Account to a TPS you can change your settings and remove permission for the TPS app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

b. Rectification of Inaccurate or Incomplete Information.You have the right to ask us to correct inaccurate or incomplete personal informationabout you (and which you cannot update yourself within your Account,if any).

c. Data Access and Portability.In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

d. Data Retention and Erasure.We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:

e. Withdrawing Consent and Restriction of Processing.If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent doesnot affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we useyour personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to the next section and pending the verification whether our legitimate grounds override your own.

f. Objection to Processing.In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling) where such processing isbased on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail [email protected]

g. Lodging Complaints.You have the right to lodge complaints about our data processing activities by filing a complaint with us via the “Contact Us” section below or with a supervisory authority.

4. Children’s Policy.

The Terms of Service clearly provide that Users must be (i) 18 or older, or (ii) 13 and older if either (a) an emancipated minor, or (b) he/she possess legal parental or guardian consent. Ohana does not knowingly collect personally identifiable information from users under 13. In the event that we learn that we have collected any personal information from a user under the age of 13, we will attempt to identify and delete that information from our database.

5. International Usage.

The Service is owned by Ohana and may be accessed in the United States and abroad. For data protection purposes, Ohana is the controller and, unless otherwise noted, is also the processor of data. Information collected may be retained, and may be stored, processed,accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction. If you are located outside of the United States, please note that the information you provide to us may be transferred to the United States. By using the Service, application and/or website, you consent to such transfer. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Policy.

6. California Privacy Rights

California law permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact Us” section below for where to send such requests.

7. Security and Encryption

We follow generally accepted industry standards to help protect your personal information. No method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while we endeavor to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that we collect online, we cannot guarantee its absolute security. Our Service has security measures in place designed to protect against the loss, misuse and alteration of the information underour control. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All Service information is maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords. You are responsible to keep your password secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that thesecurity of any Account you might have with us has been compromised), please immediately notify us of the problem by contacting us [email protected]

8. Changes to This Policy

We reserve the right to change the terms of this privacy policy at any time. When we make changes, we will revise the “last updated” date at the top of the policy. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. We encourage you to review this policy whenever you visit one of our websites or applications.

9. Contact Us

For general inquiries or to lodge a complaint, email us [email protected], or by mail to Ohana Inquiries,11444 W Olympic Blvd #600, Los Angeles, CA 90064. To opt-out of use of your data for direct marketing, email us [email protected]

To deactivate your Account, go to your Account, click Settings, and then click Deactivate my Account.

Deactivating an Account and an Account deletion request are two different things. When you choose to deactivate your Account, you canreactivate it at a later date if you wish; when you delete your Account, no deleted information can thereafter be recovered. You can request permanent deletion of your personal data and closure of your Account at any point by submitting a deletion request [email protected] We may ask you to verify your identity before taking action on your request. Please include the subject line “Personal Data Right Request – Deletion Request”, and your country of residence.

To access your data, you can visit the Dashboard of your Account. If you would like to get a copy of some or all of the personal data we hold about you pursuant to applicable law, you can send us an email [email protected] Please note that we may ask you to verify your identity before taking further action on your request. Please include the subject line “Personal Data Right Request – Access Request”, provide us your country of residence, and provide as much information as you have regarding the data you would like a copy of.

To exercise a right to portability under applicable law, please email us [email protected] include the subject line “Personal DataRight Request – Portability Request” and your country of residence.

To object to our processing of some of your personal data where allowed under the laws of the jurisdiction where you reside, you may request that we not process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise, or defense of legal claims. You may exercise your rights to object to processing by sending us an email [email protected] Please include the subject line “Personal Data Right Request – Processing Objection” and your country of residence.

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