1.SCOPE OF PRIVACY POLICY

This Privacy Policy applies to Personal Information collected on websites, mobile applications, or controlled widgets embedded in communication platforms with a link to this Privacy Policy (“Sites”). By Personal Information, Doola means information that identifies you personally and directly. It covers how Doola collects, uses, and share Personal Information as of the date that this Privacy Policy is posted. This Policy also doesn’t apply to any Sites maintained or operated by other companies or linked to our Sites.

Your Consent to Transfer Your Personal Information to the United States. Doola is headquartered in the United States. If you decide to use the Sites, your Personal Information may be transferred to the United States, and processed in several countries according to the terms described in this Privacy Policy. The laws in the United States or other countries may not be considered adequate by authorities in your home country. If you prefer not to have your Personal Information transferred outside your home country, don’t use the Sites. Otherwise, by using the Sites, you expressly consent and authorize DOOLA to transfer your Personal Information to destinations outside your home country, and process it according to the terms of this Privacy Policy.

2.COLLECTED INFORMATION

We collect information about you including Personal Information you voluntarily provide to us. We don’t require you to give us Personal Information to access public areas of our Sites. This is true unless you live in a country that defines Personal Information to include network identifiers like your Internet Protocol addresses. Certain secure areas of our Sites, however, enable authentication or require you to provide Personal Information when you use specific features on our Sites. If you can’t or choose not to provide us with the Personal Information we reasonably require, we may be unable to provide you with the information or services you have requested. For example, we may collect Personal Information from you when you:

1. Register for an account with us;
2. Make on-site purchases;
3. Interact with our applications;
4. Ask us to match the information stored on your device’s address book against our public directory of registered users; and
5. Request customer or technical

Information we collect about you, for example, may include but is not limited to your:

1. Name;
2. Postal address;
3. Geolocation (your device’s longitudinal and latitudinal information);
4. E-mail address;
5. Date of birth; and
6. Telephone or mobile number.

To facilitate certain functions on our Sites, we use third parties. Information third parties may collect about you include but are not limited to:

1. Name;
2. Postal address;
3. Geolocation (your device’s longitudinal and latitudinal information);
4. E-mail address;
5. Date of birth;
6. Telephone or mobile number;
7. Social security number;
8. Signatures;
9. Bank account information (eg. Account and routing number);
10. Credit card information;
11. Photocopy of government issued identification;
12. Analytic information; and
13. Internet activity.

Demographic Information

We may also collect certain demographic information (e.g., gender, country of residence, preferences) you provide to us, and may sometimes also combine it with your Personal Information.

Pseudo-Anonymized Information

In some situations, we may collect, use, and share emotion metrics, analytics, mobile apps used, and other information that no longer identifies you personally, with certain identifiers removed, for trend monitoring, market or product research, and overall technological enhancements.

Device Information

Depending on the permissions you’ve granted and other factors, we may receive information about your location and mobile device when you download or use apps created by our Sites, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, certain player search results, and other personalized content. We may also share this information with unaffiliated third parties for their own marketing activities. Examples of the device information we collect include:

• Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device
• Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi
• Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number, and IP

Most mobile devices allow you to turn off location services, and we encourage you to contact your device manufacturer for detailed instructions on how to do that.

Payment Information

Doola uses third-party payment processors to process payments made to us. In connection with the processing of such payments, we do not retain any financial information such as credit card numbers. Rather, all such information is provided directly to our third-party processors, Quickbooks, Paypal, or Chase Quickpay and whose use of your personal information is governed by their privacy policies.

3. ADVERTISEMENT

We advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications. To understand how our advertising campaigns are performing, we may collect certain information via our Sites through our advertising service providers. We or our vendors use several common online tracking tools to collect this information, such as browser and flash cookies, web beacons and other, similar technologies. The information we collect includes IP addresses, the number of page visits, pages viewed via our Sites, search engine referrals, browsing activities over time and across other websites following your visit to one of our Sites or applications, and responses to advertisements and promotions on the websites and applications where we advertise

Social Media Conversion Pixels

We use Conversion Pixels from Facebook, Snapchat, LinkedIn, and Google on our Sites. This allows Doola to keep track of what users do after they see or click on an advertisement. This enables us to monitor the effectiveness of our various advertisement platforms for purposes of statistics and market research. Data collected in this way is anonymous to us, which means we cannot see the personal data of individual users. However, this data is saved and processed by Facebook, Snapchat, LinkedIn, and Google. Facebook, Snapchat, LinkedIn, and Google can connect this data with your account and use it for its own advertising purposes, in accordance with their privacy and data rention policies.

Controlling Online Interest-Based Ads

We sometimes work with online advertising vendors to provide you with relevant and useful ads. This may include ads served on or through our Sites. This may also include ads served on other companies’ websites, online accounts, or mobile applications. These ads may be based on information collected by us or third parties. For example, your postal code may be used to target an ad for people in your area. These ads may also be based on your activities on our Sites or on third party websites, online accounts, or mobile applications.

To learn more about Interest-Based Advertising or to generally opt-out of this type of advertising by those third parties that are members of the self-regulatory programs such as the Network Advertising Initiative, please visit the NAI’s website (www.networkadvertising.org), which will allow you to opt out of Interest-Based Advertising by one, or all, NAI members. For more information about our ad service provider and its cookies, including information about how to opt out of these technologies, you may visit www.aboutads.info/choices .

Minors and Children Under 13

Our Sites are not intended for those under the age of 13. We do not knowingly collect any Personal Information from children under the age of 13 or knowingly track the use of our Sites by these minor users.

4. USE OF PERSONAL INFORMATION

In accordance with applicable law, we may share what we know about you with affiliated and unaffiliated third parties for their marketing activities, or for any purpose allowed by law (California residents see below). In certain instances, we may also help advertisers better reach our users by providing your device ID and type, geographic and geolocation information, language preferences, demographic, and other information obtained from you and other companies. We may run joint or co-sponsored programs or promotions with unaffiliated companies and, as part of that, collect, use, and may share certain information about you, only for the purpose of those programs or promotions. Finally, we may share collected location and Bluetooth data for Interest-Based Advertising, allowing certain advertisers to infer interests and serve ads to our users based on activity and location over time.

Whatever the purpose may be, we only process and share information about you to the extent reasonably necessary to fulfill your requests and other legitimate business objectives. When we disclose information about you to external entities that perform services on our behalf, they may access that information only for the purposes of performing those services. We may also use what we know about you to offer you other products and services. We may combine your online information with information collected from other sources or information we already have. We may also use and disclose what we know about you to our affiliates and others for any purpose allowed by law.

Business Activities

We process and may use information about you to:

• Respond to your questions about our product or services;
• Allow you to establish a connection with the Sites, use various functionalities on our Sites, or other permitted activities through the Sites;
• Identify new visitors to our Sites and recognize returning visitors;
• Send you communications, including ads, electronic newsletters, or other offers tailored to you;
• Enable our advertisers to provide you with more personalized content, advertise on other sites and mobile applications, and track the effectiveness of certain advertising campaigns;
• Determine whether you might be interested in new products or services;
• Better understand our audience, customers, or other visitors to our Sites;
• Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities; or
• For any other everyday business purposes, such as product development and administration of the

Authorized Service Providers

We use other companies and individuals to perform certain functions on our behalf. Those functions include payment card processors, call-center support, notification fulfillment vendors (for email and push notifications for example), analyzing or hosting data on cloud-based servers, and other companies that help us improve our products and services. We may disclose your information about you to these companies and other individuals only for the purposes of performing services on our behalf in the United States or other locations where we may conduct business at that time.

Customer Relationship Management Databases

Doola uses customer relationship management (“CRM”) database technology from HighLevel to manage and track our marketing efforts. HighLevel’s CRM databases include personal data belonging to our clients, and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by Doola professionals based on their personal interactions with you. HighLevel’s retention of the aforementioned data is governed by its privacy policy and data retention procedure, which can be found here: https://gohighlevel.com/privacy-policy.

California Residents

The California Consumer Protection Act (“CCPA”) provides California Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

1.Access to Specific Information and Data Portability Rights

You have the right to request that DOOLA disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: (i) the categories of Personal Information we collected about you; (ii) the categories of sources for the Personal Information we collected about you; (iii) our legitimate business purpose for collecting or selling that Personal Information (iv) the categories of third parties with whom we share that Personal Information; (v) the specific pieces of Personal Information we collected about you (also called a data portability request); (vi) if we sold or disclosed your Personal Information for a legitimate business purpose, two separate lists disclosing: sales, identifying the Personal Information categories that each category of recipient purchased; and disclosures for a legitimate business purpose, identifying the Personal Information categories that each category of recipient obtained.

1.Deletion Request Rights

You have the right to request that Doola delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that our customers purchase or request, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with 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 (Cal. Penal Code § 1546 et. seq.).
• 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.

1.Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at admin@doola.biz.

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 a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. The verifiable consumer request must also describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

1.Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Sale of the Businesses

If we sell all or part of our business, information about you may be transferred to the purchaser in connection with that transaction. We will use commercially reasonable efforts to include contractual provisions that require the purchaser to treat your Personal Information consistent with this Privacy Policy.

Other Disclosures

We may otherwise disclose information about you as permitted or required by law, when we believe in good faith it is necessary for safety purposes, required for legal reporting, or to protect our legal rights or enforce our Terms of Use or any applicable rules, or to protect the rights of others. We may also disclose information about you to our auditors, legal advisors, or to respond to a subpoena. We may also aggregate information that we gather about you, online sales, traffic patterns, and services, and provide these statistics to others in aggregate form.

5.YOUR RIGHT TO OPT OUT

If you wish for us to stop receiving marketing communications or newsletters you signed up to receive from us, you can opt-out any time by clicking the “Unsubscribe” link at the bottom of those communications.

If you wish for us to stop sharing your Personal Information with unaffiliated third parties for marketing activities, please contact us at admin@doola.biz with subject line “Opt Out.” Please make sure to send this request from the email account registered with us and tell us the application you are emailing about; if you have more than one account associated with that email address, please also include your specific User ID for which you are making the request. We will honor your request shortly after we receive it, and your request will only apply as of that date onward.

If you wish to limit or restrict other users on our Sites from seeing certain Personal Information or from being able to find you on our Sites, you can do so on some of our Sites by visiting the “Privacy” settings in your account.

If you wish to deactivate your account at any time, please contact us admin@doola.biz with subject line “Deactivate Account.” Please make sure to send this request from the email account registered with us and tell us the application you are emailing about; if you have more than one account associated with that email address, please also include your specific User ID you wish to deactivate. We will deactivate your account shortly after we receive your request.

6.SECURITY PROCEDURES

The security and confidentiality of your Personal Information matters to us. That’s why we have technical, administrative, and physical controls in place to protect your Personal Information from unauthorized access, use, and disclosure. We also review our security procedures periodically to consider appropriate technology and methods. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable.

When you use some features and functionalities on our Sites you are responsible for the information you choose to share or submit in these instances. Please carefully consider what you share in your profile, photographs, chat, and text conversations, and we urge you to not share private, confidential, and any Personal Information in general with anyone online.

7.YOUR CONTROL OF PERSONAL INFORMATION

You can log-in to your account to view your information and submit any updates or corrections to your information directly in your account profile. We cannot change information stored in systems belonging to third parties.

If you wish to deactivate your account at any time, please contact us directly at admin@doola.biz with subject line “Deactivate Account.” Please make sure to send this request from the email account registered with us and tell us the application you are emailing about; if you have more than one account associated with that email address, please also include your specific User ID you wish to deactivate. We will deactivate your account shortly after we receive your request. While your account will be deactivated on a going forward basis, information about you may still be retained to comply with applicable record retention laws, legal holds, or other business requirements.

For UK Consumers

The Data Protection Act gives you the right to access information we hold about you. Your right of access can be exercised in accordance with the Act. If you wish to access information in this way, please contact us at admin@doola.biz with subject line “UK Consumer Request.” Please make sure to send this request from the email account registered with us and tell us the application you are emailing about; if you have more than one account associated with that email address, please also include your specific User ID for which you are making the request.

8.CONTACT

If you have any questions, have a complaint, or wish to send us comments about this Privacy Policy, contact us directly admin@doola.biz with subject line “Question” or write to us at the address below. We will investigate your complaint, and use reasonable efforts to respond to you as soon as possible.

9.AMENDMENTS TO PRIVACY POLICY

We may amend this Privacy Policy at any time. If we make any material change to the way we collect, use, disclose, or otherwise process Personal Information, we will prominently post a link to the updated Privacy Policy. Any material changes to this Privacy Policy will be effective 10 days after we post the updated Privacy Policy. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Policy. If you disagree with our Privacy Policy changes, you may exercise your then-available options to opt-out or simply deactivate your account. Further, if a separate agreement exists between you and us (“Separate Agreement”), and the terms of this Privacy Policy conflict with the terms of the Separate Agreement, the provisions of the Separate Agreement will govern to the extent of the conflict.