Privacy policy.

NEATFREAK PRIVACY POLICY

1. Introduction

This Global Privacy Policy (“Privacy Policy”) describes how NeatFreak Corp. and its

affiliates will gather, use, and maintain your Personal Information on the NeatFreak

Platform. It will also explain your legal rights with respect to that information.

By using the NeatFreak Platform, you confirm that you have read and understand this

Privacy Policy, and our Global Terms of Service (together referred to herein as the

“Agreement”). The Agreement governs the use of the NeatFreak Platform. NeatFreak

will collect, use, and maintain information consistent with the Agreement.

If you are a California resident, please see the “Additional Disclosures for California

Residents.” If you have any questions or wish to exercise your rights and choices,

please contact us as set out in the “Contact Us” section below.

2. General Terms

In this Privacy Policy:

 NeatFreak Corp. may be referred to as " NeatFreak," “we,” “our,” or “us.”

 We call a user of the NeatFreak Platform “User,” “Users,” “you,”

“your,” or “Customer” and “Cleaner,” as appropriate.

 The mobile applications (whether on iOS or Android) are referred to as

the “Apps.”

 NeatFreak’s App and related services, information and communications are

collectively referred to as the “NeatFreak Platform.”

 “Terms of Service” refers to our Global Terms of Service, which can be found

on the support page in account setting of the App. This Privacy Policy is

incorporated into, and considered a part of, the Terms of Service.

3. Information Collection

Information you provide to NeatFreak

NeatFreak collects certain personally identifiable information about you, including

information that can identify, relate to, describe, be associated with you, or is reasonably

capable of being associated with you (“Personal Information”). Examples of Personal

Information that NeatFreak collects include but are not limited to:

Contact Information. This may include your first and last name, postal address,

telephone number, and email address.

Billing Data, including your payment instrument number (such as a credit or debit card

number), expiration date, and security code as necessary to process your payments.

Identity Information. If you are a Cleaner, we may collect Personal Information, such

as your date of birth and address, national identification number if applicable, together

with the result of basic criminal record checks as provided by you, or by our Third-Party

Agents (as defined below), as applicable and to the extent permitted by law in your

jurisdiction, as well as such information as may be needed to validate your identity.

Financial Information. To help Cleaners set up a payment account and help

Customers make payments to Cleaners and pay fees to NeatFreak, we may collect

financial information, including credit card number, bank routing numbers, tax

information, taxpayer identification number, and other payment information, as

applicable. We use Financial Information in order to operate the NeatFreak Platform

and to ensure that Cleaners are paid by Customers. We do this as necessary for our

legitimate interests in providing our platform and services and to fulfill our contracts with

Users. To keep your financial data secure, we have contracted with a third party to

maintain and process your payment information.

Promotional Information. Certain offerings of the NeatFreak Platform, such as

newsletters, surveys, contests, and the like are optional and so you are not required to

enter them or to give us your data in connection with them. Where you do consent to

take advantage of NeatFreak Platform offerings, we will use your data to (as applicable)

send you newsletters and other communications that are tailored based on information

we have about you, or to operate and manage the survey, contest or similar offering in

connection with our legitimate interest in promoting our business and the NeatFreak

Platform. To opt-out of receiving marketing communications from us, please see Section

8, Your Rights and Choices.

Employment Information. We collect employment and education history, transcripts,

writing samples, and references as necessary to consider your job application for open

positions.

Content Information. You also may choose to send NeatFreak Personal Information in

an email or chat message containing inquiries about the NeatFreak Platform and we

use this Information in order to help us respond to your inquiry. We also collect content

within any messages you exchange with other Users through the NeatFreak Platform

(such as through our chat functionality).

We require that you furnish certain information when you register an account with us in

order to provide services through the NeatFreak Platform. For example, if you are a

Customer, we collect your first and last name, email address, and your zip or postal

code in order to create and administer your NeatFreak account. We also collect

additional information in order to facilitate your booking request, such as information

about the service you are seeking, the time, date and location of the Service, and Billing

Data. If you are a Cleaner, we collect your first and last name, email address, mobile

phone number and zip or postal code in order to create and administer your NeatFreak

account and facilitate communications between you and your Customers through the

NeatFreak Platform. We also collect information about your services, rates, and skills,

as well as Identity Information and Financial Information.

Third Party Information. If you registered through a co-branded version of our

NeatFreak Platform through one of our Partners (as defined below), they may provide

us with basic information such as your name, address, email, and purchase history

related to your Service needs. We may receive additional information about you, such

as demographic data, Financial Information, or fraud detection information, from Third-

Party Agents (as defined below) and combine it with other information that we have

about you, to the extent permitted by law, in order to comply with our legal obligations

and for the legitimate interest in improving the NeatFreak Platform. NeatFreak may work

with Third-Party Agents to perform identity checks and criminal background checks on

Cleaners, if applicable and permitted by local law, in order to advance our legitimate

interests in ensuring the safety of our Users and maintaining the integrity of the

NeatFreak Platform.

4. Information NeatFreak Collects Automatically

We automatically collect certain information when you use the NeatFreak Platform. The

categories of information we automatically collect and have collected, including in the

last 12 months, are as follows:

Service Use Data, including data about features you use, pages you visit, emails and

advertisements you view, portions of the NeatFreak Platform that you view and interact

with, the time of day you browse, and your referring and exiting pages.

Device Data, including data about the type of device or browser you use, your device’s

operating system, your internet service provider, your device’s regional and language

settings, and device identifiers such as IP address and Ad Id. When you visit and

interact with the NeatFreak Platform, NeatFreak may collect certain information

automatically through cookies or other technologies, including, but not limited to, the

type of computer or mobile device you use, your mobile device’s unique device ID, the

IP address of your computer or mobile device, your operating system, the type(s) of

internet browser(s) you use, and information about the way you use the NeatFreak

Platform (“Device Information”). We may use Device Information to monitor the

geographic regions from which Users navigate the NeatFreak Platform, and for security

and fraud prevention purposes. Use of any IP-masking technologies or similar

technologies (like the TOR network) may render portions of the NeatFreak Platform

unavailable and are forbidden on the NeatFreak Platform.

Location Data, including imprecise location data (such as location derived from an IP

address or data that indicates a city or postal code level), and, with your consent,

precise location data (such as latitude/longitude data). When you visit the NeatFreak

Platform via a native mobile application, we use, with your consent when required under

applicable law, GPS technology (or other similar technology) to determine your current

location in order to determine the city you are located in and display a relevant location

map. We will not share your current location obtained in this manner with other Users.

Cookies and similar technologies are described in our Cookie Policy, which sets out

the different categories of cookies and similar technologies that the NeatFreak Platform

uses and why we use them.

5. NeatFreak’s Cookie Policy

NEATFREAK COOKIE POLICY

NeatFreak uses cookies, unique identifiers and other similar technologies, like pixels, to

distinguish you from other users of our platform, provide our services to you, help collect

data and to improve our platform. This Cookie Policy supplements our Privacy Policy

and explains how and why we use cookies and other similar technologies. Any terms

capitalized in this policy and not otherwise defined shall have the same meaning

attributed to them in this Privacy Policy.

When you use our mobile applications, we will access and use mobile device IDs to

recognize your device. We use “cookies” and equivalent technologies to collect

information through our App.

Most browsers accept cookies by default. You can instruct your browser, by changing its

settings, to decline or delete cookies. If you use multiple browsers on your device, you

will need to instruct each browser separately. Your ability to limit cookies is subject to

your browser settings and limitations. Exhibit A sets out the different categories of

cookies that the NeatFreak Platform uses and why we use them.

Cookies

Cookies are small data files stored on your device that act as a unique tag to identify

your browser.

Persistent cookies help with personalizing your experience, remembering your

preferences, and supporting security features. Additionally, persistent cookies allow us

to bring you advertising both on and off the NeatFreak Platform. Persistent cookies may

remain on your device for extended periods of time, and generally may be controlled

through your browser settings. We utilize persistent cookies that only NeatFreak can

read and use, and access mobile device IDs to:

 save your login information for future logins to the NeatFreak Platform;

 assist in processing items during checkout;

 hold session information; and

 track user preferences.

Flash Cookies

We may use flash cookies (or Local Shared Objects) to personalize and enhance your

visit. Via flash cookies we may store your preferences or display content based upon

what you view on the Sites to personalize your visit.

Pixel Tags

We and our Third- Party Agents may use "pixel tags” (sometimes referred to as "web

beacons or "clear GIFs"). These or similar technologies are tiny graphic images and/or

blocks of code with a unique identifier that are used to understand browsing activity

and/or determine whether a specific action was performed.

These are used by NeatFreak or our Third- Party Agents in connection the NeatFreak

Platform and HTML-formatted email messages to, among other things, track the actions

of Users and email recipients, determine the success of marketing campaigns, and

compile statistics about Site usage and response rates.

App and Location Technologies

We include technologies in our apps that are not browser-based like cookies and cannot

be controlled by browser settings. For example, our Apps may include Software

Development Kits (SDKs), which is code embedded in Apps that collects information

about the App and your use / activity in the App. These SDKs allow us to track our

conversions, bring you advertising both on and off the NeatFreak Platform. 

You can stop all collection of information via an app by uninstalling the app. You can

also reset your device Ad ID at any time through your device settings, which is designed

to allow you to limit the use of information collected about you. If you do not want us to

use your location anymore for the purposes set forth above, you should turn off the

location services for the mobile application located in your device’s account settings,

your mobile phone settings, and/or within the mobile application.

Third Party Cookies

Third party cookies are placed by someone other than NeatFreak. These third parties

may gather browsing activity across multiple websites and multiple sessions. Third party

cookies are usually persistent cookies and are stored until you delete them or they

expire based on the duration set in respect of each third party cookie.

For example, we may work with third party advertisers who may place or read persistent

cookies on your browser.

A description of third party cookies and similar technologies used by the Sites, along

with their respective privacy policies and options for controlling your privacy on these

platforms is set out below: 

 DoubleClick: Google's Doubleclick re-targeting cookie lets us serve personalized ads to

you when you're browsing other websites and social media platforms. You can control ad

personalization on Google and partner websites in Google’s Privacy and Terms page.

 Facebook Impressions: We use Facebook Impressions to track the number of people

that interact with our content on Facebook. This information is collected by Facebook

and is provided to us under the terms of Facebook’s Privacy Policy. You can control the

information that we receive from Facebook using the privacy settings in your Facebook

account. 

 LinkedIn Widgets: This tool enables visitors to engage with us via LinkedIn and show

visitors relevant ads and personalized content on LinkedIn. To learn more about

LinkedIn’s practices and to opt out, please visit LinkedIn’s Privacy Policy and Settings.

 Iterable: Email newsletters you elect to receive from us are transmitted through. Iterable

uses pixel tag technology to determine whether an email has been opened. In addition,

when you click on any link in an email newsletter or marketing message you have

elected to receive, Iterable recognize that fact. This information is used in the aggregate

to measure the rate at which emails are opened and various links are clicked, to

measure user interests and traffic patterns, and to improve the content of the email

newsletters and the services and features offered through the email newsletter and

marketing messages. Because some of this information is linked to individual email

addresses, it is personally identifiable. You can view Iterable’s privacy policy here. 

 Bing Ads: We use Bing Ads to promote our company online and use the cookies

provided by Bing to record completion of a transaction on our website. You can find out

more about Bing cookies by visiting Bing’s Privacy Policy.

 Google Analytics: We use Google Analytics, a web analytics service. Google Analytics

uses cookies to help NeatFreak analyze how visitors use the Site(s). The information

generated by cookies about your use of the Site(s) and the NeatFreak Platform

(including your IP address) will be transmitted to and stored by a Google server in the

United States. Google uses this information for the purpose of evaluating your use of the

Site(s), compiling reports on Site activity for Site operators, and providing Site operators

with other services relating to Site activity and Internet usage. You can prevent the

storage of data relating to your use of the Site(s) and created via the cookie (including

your IP address) by Google, as well as the processing of this data by Google, by

downloading and installing the browser plug-in available here. You can obtain additional

information on Google Analytics’ collection and processing of data and data privacy and

security at the following links: How Google Uses Information From Sites Or Apps That

Use Our Services and Analytics Help. 

Information from Other Sources. 

We also collect information from other sources, including data brokers, social media

networks, and publicly-available sources.

Your Choices and Managing Cookies

You can adjust your browser settings to enable you to stop accepting cookies or to

prompt you before accepting a cookie from the websites you visit. Depending on what

browser you use, you may manage your settings here: Internet

Explorer, Safari, Chrome, Firefox, and Opera. If you do not accept cookies, however,

you will not be able to use all portions or all functionalities of the NeatFreak Platform.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to

online services you visit. Note, however, there is currently no industry consensus as to

what site and app operations should do with regard to these signals. Accordingly, unless

and until the law is interpreted to require us to do so, we do not monitor or take action

with respect to “Do Not Track” signals. For more information on “Do Not Track,”

visit https://www.allaboutdnt.com.

Contacting Us

If you have any questions about this Cookie Policy or the manner in which we or our

Third-Party Agents treat your Personal Information, your dealings with the NeatFreak

Platform, or if you have technical problems, you may contact us via email

(founders@neatfreak.us).

Exhibit A

Type of

Cookie

Purpose NeatFreak or

3rd party

Authentication

Cookies

These cookies (including local storage and

similar technologies) tell us when you’re

logged in, so we can customize your

experience and connect your account

information and settings.

NeatFreak

Localization These cookies help provide a localized

experience by showing you your local metro

area.

NeatFreak

Site features

and services

These provide functionality that helps us

deliver products and the NeatFreak Platform.

For example, cookies help you log in by pre-

filling fields or help ensure older versions of

web browsers can still view our Site(s). We

may also use cookies and similar

technologies to help us provide you with

social plugins and other customized content

and experiences, including customized fonts.

NeatFreak

Analytics and

research

These are used to understand, improve, and

research products and services, including

when you access the NeatFreak Platform and

related websites and apps from a computer

or mobile device. For example, we may use

cookies to understand how you are using site

features, to report on any errors in how the

Site is functioning, to report to our vendors

 Google

Analytics

 Google

Tag

Manager

when content licensed from them is

assessed, and to segment audiences for

feature testing. We and our partners may use

these technologies and the information we

receive to improve and understand how you

use apps, products, services and ads.

Interest-Based

Advertising

Things like cookies and pixels are used to

deliver relevant ads, track ad campaign

performance and efficiency, and to

understand your interests from your online

activity on the mobile applications and other

apps. For example, we and our ad partners

may rely on information gleaned through

these cookies to serve you ads that may be

interesting to you doing that your information

(which will not contain your name, email

address or other "real-world" identifiers) will

be shared with other platforms in the digital

advertising ecosystem all involved in

assisting the delivery, purchase, reporting

and analysis of digital advertising. Similarly,

our advertisers may use a cookie, attribution

service or another similar technology to

determine whether we’ve served an ad and

how it performed, or provide us with

information about how you interact with them.

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 may 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.

You can instruct your browser, by changing its

options, to stop accepting cookies or to

prompt you before accepting a cookie from

the websites you visit. To successfully opt-

out, you must have cookies enabled in your

web browser. Please 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 device that

you use. Once you opt out, if you delete your

browser’s saved cookies, you may need to

opt-out again.

For more information about targeting and

advertising cookies and how you can opt out,

you can visit the Network Advertising

Initiative opt-out page, or the Digital

Advertising Alliance’s opt-out pages in the

United States.

6. NeatFreak’s Use of Information

We collect and use information for business and commercial purposes in accordance

with the practices described in this Privacy Policy. Our business purposes for collecting

and using information include:

 To operate and make available the NeatFreak Platform. We use your data to

connect you with other Users to enable the posting of, selection for, completion

of, and payment for Services, in order to fulfill our contracts with Users;

 For billing and fraud prevention, on the basis of our legitimate interests in

ensuring a safe and secure environment in which Customers and Cleaners can

meet and conduct business, and in order to comply with our legal obligations;

 To conduct identification and criminal background checks, if applicable and to the

extent permitted by local law, on Users, in order to advance our legitimate

interests as well as for the substantial public interest of ensuring the safety of our

Users both online and offline, preventing or detecting unlawful acts, protecting

the public against dishonesty, and maintaining the integrity of the NeatFreak

Platform given that Cleaners often interact directly with Customers and may enter

their homes;

 To analyze NeatFreak Platform usage as necessary for our legitimate interest in

improving the NeatFreak Platform to grow our business;

 To contact you and deliver (via email, SMS, push notifications, or otherwise)

transactional information, administrative notices, marketing notifications, offers

and communications relevant to your use of the NeatFreak Platform, with your

consent when required under applicable law, as necessary for our legitimate

interests in proper communication and engagement with our Users, and in

promoting our business;

 To provide you with customer support in order to fulfill our contracts with Users;

 For internal market research for our legitimate interest in improving the

NeatFreak Platform to grow our business;

 For troubleshooting problems for our legitimate interests in ensuring a safe and

secure environment in which Users can meet;

 To assist Users in the resolution of complaints and disputes between them, as

necessary for our legitimate interests in facilitating good relations among Users;

 To enforce our Terms of Service and our legitimate interests in ensuring our

Agreement is complied with; and

 As otherwise set forth in the Agreement.

Interest-Based Advertising. Ads are a standard part of user experience, and

NeatFreak believes that targeted advertising enhances this experience. NeatFreak and

affiliate third parties may use cookies and other technologies to place ads where they

believe interested Users will see them. In addition to banner ads, NeatFreak may

advertise products, companies and events that we think might interest you through the

email address and/or phone number you provide. We may incorporate Tracking

Technologies on the NeatFreak Platform as well as into our ads displayed on other

websites and services. Some of these Tracking Technologies may track your activities

across time and services for purposes of associating the different devices you use, and

delivering relevant ads and/or other content to you (“Interest-Based Advertising”).

For more information and to understand your choices regarding third-party ads, please

see our Cookie Policy. Advertising and marketing is carried out as necessary for our

legitimate interests in providing an engaging and relevant experience, promoting our

services, and growing our business.

Analytics and Market Analysis. NeatFreak may analyze information (“Market

Analysis”) as necessary for our legitimate interests in providing an engaging and

relevant experience and promoting and growing the NeatFreak Platform.

NeatFreak uses information to offer services to Users who express an interest in these

services, through a poll for example, or to Users who can be presumed to have an

interest based on results from our Market Analysis. We do this as necessary for our

legitimate interests in providing an engaging and relevant experience, promoting our

services, and growing our business.

Cell Phone Numbers. NeatFreak may use your cell phone number to call or send

recurring text messages to you, using an autodialer or prerecorded voice, in order to

provide you notifications about Services, for marketing purposes (with your consent

where required by law), and to administer the NeatFreak Platform. If you would like

more information about our policy, or how to opt out, please review the “Your Rights and

Choices” section below or Section 9 of our Terms of Service. You may be liable for

standard SMS and per-minute charges by your mobile carrier. NeatFreak may also

message you via push notifications (with your consent when required under applicable

law), which you can opt-out of on your mobile device. Data rates may apply.

Call recordings. Calls to or from NeatFreak or its Third Party Agents may be monitored

and recorded for the purposes of quality control and training. Such calls may contain

Personal Information.

7. Information Sharing

We only share the Information we collect about you as described in this Privacy Policy

or as described at the time of collection or sharing, including as follows:

Third Party Agents. We share information, including Identity Information, with entities

that process information on our behalf for our business purposes. We contractually

prohibit our Third-Party Agents from retaining, using, or disclosing information about you

for any purposes other than performing the services for us, although we may permit

them to use information that does not identify you (including information that has been

aggregated or de-identified) for any purpose except as prohibited by applicable law.

To operate the NeatFreak Platform, including processing your transactions, we may

share your Personal Information with our agents, representatives, vendors and service

providers (“Third Party Agents”) so they can provide us with support services as

follows:

 Email origination;

 Identity checks (currently carried out by our providers Sterling (Canada) and

Jumio (U.S., France, Germany, Spain, Portugal and Italy)), and criminal

background checks (currently carried out by our provider in the U.S. and

Canada), to the extent permitted by applicable law;

 Fraud prevention and detection (currently carried out by our providers). Our fraud

detection providers also use information relating to you and your use of and

activity on the NeatFreak Platform to provide fraud detection services to their

other customers;

 Receipt, invoice, or support services;

 Customer relationship management services;

 Data analytics;

 Marketing and advertising;

 Website hosting;

 Communications services;

 Technical support;

 Financial transaction fulfillment (in which we are currently supported by Stripe,

who processes your Personal Information in accordance with its own privacy

policy) and related chargeback and collection services; and

 To otherwise help us provide the NeatFreak Platform.

Partners. Some NeatFreak content is "sponsored by" or "presented by" other

companies. If you connect to the NeatFreak Platform through a co-branded version of

our NeatFreak Platform or otherwise participate in one of our partner programs, we may

share information about your use of the NeatFreak Platform with that Partner in order to

offer the integrated platform and to evaluate the partner program. We may also share

your Personal Information with our Partners in order to receive additional information

about you, or in order to create offers that may be of interest to you. Please check such

Partner’s privacy policy before revealing information about yourself. If you don't want

these Partners to have your Personal Information, you can choose to not participate.

Promotions. When you voluntarily enter a sweepstakes, contest, or other promotion,

we share information as set out in the official rules that govern the promotion as well as

for administrative purposes and as required by law (e.g., on a winners’ list). By entering

a promotion, you agree to the official rules that govern that promotion, and may, except

where prohibited by applicable law, allow the sponsor and/or other entities to use your

name, voice, and/or likeness in advertising or marketing materials. We may occasionally

contact you, if you want us to, with information about special events, activities,

promotions, contents, submission opportunities, and programs. You always have the

ability, in your Account, to ask NeatFreak not to contact you with this type of information.

Please see Section 8, Your Rights and Choices, for more information.

Other Users. NeatFreak facilitates contact between Customers and Cleaners and

reserves the right to share one User’s contact information (e.g., name, phone number,

email, or postal address) with other Users, or with the recipient User’s legal or other

authorized representative, in order to: (1) facilitate or communicate the resolution of an

investigation or dispute related to or arising from an interaction between two or more

Users of the NeatFreak Platform; or (2) facilitate the performance of a Service. This

exchange of information is essential to the operation of the NeatFreak Platform.

Legal Obligations. NeatFreak and our Third Party Agents may disclose your Personal

Information or User Generated Content to courts, law enforcement, governmental or

public authorities, tax authorities or authorized third parties, if and to the extent required

or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply

with NeatFreak’s legal or regulatory obligations; (ii) respond to a court order, warrant or

subpoena; (iii) respond to a valid legal request relating to an investigation into alleged

criminal or illegal activity; or (iv) respond to or address any other activity that may

expose us to legal or regulatory liability.

In jurisdictions where NeatFreak is, according to applicable law, required to collect or

remit information about Users’ permits, licenses, tax, or social security registrations,

NeatFreak and our Third Party Agents may disclose information, including but not

limited to, User contact details, identification information, transaction dates and

amounts, license and permit status, and tax identification number(s) to applicable

governmental authorities.

NeatFreak reserves the right to disclose Personal Information from both private and

public areas of the NeatFreak Platform in the absence of a court order, warrant, or

subpoena, to the extent permitted by applicable law, if we are given reason to believe, in

our sole discretion, that someone is causing injury to or interfering with the rights of

Users, the general public, or NeatFreak or its partners, parents or affiliates.

It is our policy to provide notice to Users before producing their information in response

to law enforcement requests unless (i) we are prohibited or otherwise constrained by

law or court order from doing so, (ii) we have reason to believe the User’s account has

been compromised such that the notice would go to the wrong person, or notice would

otherwise be counterproductive or would create a risk to safety, or (iii) it is an

emergency request and prior notice would be impractical (in which case we may provide

notice after the fact).

Merger or Acquisition. NeatFreak reserves the right to share information in connection

with, or during negotiations of, any proposed or actual merger, purchase, sale, or any

other type of acquisition or business combination of all or any portion of our assets, or

transfer of all or a portion of our business to another business.

Public Areas. Your profile on the NeatFreak Platform consists of information about you

and your business, and may include information such as photographs, your years in

business, skills and expertise, hourly pay rates, feedback/rating information, and other

information, including your username (“Profile”). The information in your User Profile

may be visible to all Users and the general public. If you choose to post a Service via

the NeatFreak Platform, the contents of such listing will be viewable to Cleaners you

select on the NeatFreak Platform.

8. Your Rights and Choices

You may opt-out of receiving promotional communications from us, including

promotional communications related to the NeatFreak Platform, and request the

removal of your Personal Information from our databases, or deactivate your account,

by logging in the App and clicking on the “Account” tab, or by contacting us via email

(founders@neatfreak.us).

Account Settings. During registration you choose whether to receive marketing

correspondence from NeatFreak. This information remains on your Profile where you

can, at any point, easily edit it. After logging on, click on the “Account” tab, then select

“Notifications” to make your preferred selections.

Push Notifications. You have the option to receive updates and relevant offers via

push notifications in your app. These notifications can be configured in the settings of

your mobile device at any time.

Corrections to Profile. You have the right to access, update, and correct inaccuracies

in your NeatFreak Profile at any time by logging in and clicking on the “Account” tab.

There, you can view, update, and correct your Account information.

So that we may protect the integrity of the NeatFreak Platform, there are certain pieces

of information, such as your email, that you cannot alter yourself. Please reach out to

Neatfreak via email (founders@neatfreak.us) to help get this updated.

Promotional Communications. You can opt out of receiving promotional

communications from NeatFreak via the Account tab in your Profile. In addition, you can

opt out of email marketing by clicking on the unsubscribe link in any message. You can

opt out of promotional communications from NeatFreak sent via text message at any

time by following the instructions provided in those messages to text the word "STOP".

Please note that your opt-out is limited to the phone number used and will not affect

subsequent subscriptions. If you opt-out of only certain communications, other

subscription communications may continue. Even if you opt-out of receiving promotional

communications, NeatFreak will continue to send you non-promotional communications,

such as those about your account, Services, transactions, servicing, or NeatFreak’s

ongoing business relationship with you. If you receive unsolicited promotional

communications from a NeatFreak domain, please let us know via email

(founders@neatfreak.us).

If you are a California Resident, please see the Additional Disclosures for California

Residents section below.

9. NeatFreak’s Information Retention Policy

We retain personal data for as long as you are a User in order to meet our contractual

obligations to you, and for such longer period as may be in our legitimate interests and

to comply with our legal obligations (see Exhibit A for exemplar document retention

periods). We may also retain data from which you cannot directly be identified, for

example where stored against a randomly-generated identifier so we know the data

relates to a single User, but we cannot tell who that User is. We use this kind of data for

research purposes and to help us develop and improve our services, and we take

appropriate measures to ensure you cannot be re-identified from this data.

10. NeatFreak’s Security of Collected Information

Your NeatFreak account is password-protected so that only you and authorized

NeatFreak staff have access to your account information. In order to maintain this

protection, do not give your password to anyone. This will help protect your information

entered on public terminals from disclosure to third parties.

NeatFreak implements and maintains reasonable administrative, physical, and technical

security safeguards to help protect information about you from loss, theft, misuse and

unauthorized access, disclosure, alteration and destruction. NeatFreak has staff

dedicated to maintaining this Privacy Policy and other privacy initiatives, periodically

reviewing security, and making sure that every NeatFreak employee is aware of our

security practices. Nevertheless, transmission via the internet is not completely secure

and we cannot guarantee the security of information about you.

11. Notification of Changes

NeatFreak’s Privacy Policy is periodically reviewed and enhanced as necessary. This

Privacy Policy might change as NeatFreak updates and expands the NeatFreak

Platform. NeatFreak will endeavor to notify you of any material changes by email.

NeatFreak also encourages you to review this Privacy Policy periodically.

12. Children’s Privacy

This service is intended for a general audience, and is not directed at children under 13

years of age. In certain jurisdictions, this minimum age may be higher. Please check the

Jurisdiction-specific Provisions below for more information.

We do not knowingly gather personal information (as defined by the U.S. Children’s

Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a

parent or guardian and you believe that we have collected information from your child in

a manner not permitted by law, please let us know by contacting us via email

(founders@neatfreak.us). We will remove the data.

We do not knowingly collect or “sell” the Personal Information of minors under 18 years

old who are California residents.

13. Contacting Us

If you have any questions about this Privacy Policy or the manner in which we or our

Third-Party Agents treat your Personal Information, your dealings with the NeatFreak

Platform, or if you have technical problems, you may contact us via email

(founders@neatfreak.us).

NeatFreak’s staff will respond to all emails from Users with questions about privacy,

including the types of Personal Information stored on the NeatFreak databases, and

requests to know, delete or rectify such Personal Information.

14. Jurisdiction-specific Provisions

A. Residents of the United States of America

Information of U.S. Users. Our collection, use, and retention of the Personal

Information of U.S. Users is in accordance with applicable U.S. laws, as is our

determination of what is deemed to be “personal data and/or information.”

NeatFreak expressly disclaims any liability that may arise should any other individuals

obtain the information you submit to the NeatFreak Platform.

Interest-Based Advertising in the United States. For more information about interest-

based ads, or to opt out of having your web-browsing information used for behavioral

advertising purposes, please visit www.aboutads.info/choices.

NeatFreak’s Security of Collected Information. While NeatFreak will use

commercially reasonable efforts to ensure the security of all Personal Information, we

expressly disclaim any liability for any unauthorized access to or use of our secure

servers and/or any and all Personal Information stored therein, and you agree to hold

NeatFreak harmless for any damages that may result therefrom. If you have any further

questions on this issue, please refer to the Terms of Service.

Additional Disclosures for California Residents

These additional disclosures for California residents apply only to individuals who reside

in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides

additional rights to know, delete and opt out, and requires business collecting or

disclosing Personal Information to provide notice of rights California residents have and

can exercise.

California Notice of Collection. We have collected Personal Information

corresponding to the following categories enumerated in the CCPA, including within the

last 12 months.

  Identifiers, including name, address, email address, account name, Social Security

Number, IP address - and an ID number assigned to your account.

  Customer records, phone number, billing address, credit or debit card information,

employment or education information.

  Demographic information, such as your age or gender. This category includes pieces of

Personal Information that also qualify as protected classification characteristics under

other pre-existing California or federal laws.

  Analytics and Advertising, including purchases and engagement with the NeatFreak

Platform.

  Internet activity, including history of visiting and interacting with our Service, browser

type, browser language and other information collected automatically.

  Geolocation data, including location enabled services such as WiFi and GPS.

  Inferences, including information about your interests and preferences.

For more information on what we collect, including the sources we receive information

from, review Section 3, Information Collection. We collect and use these categories of

personal information for the business purposes described in Section 6, NeatFreak’s Use

of Information, including to provide and manage the NeatFreak Platform.

NeatFreak does not generally sell information as the term “sell” is traditionally

understood. However, to the extent “sale” under the CCPA is interpreted to include

advertising technology activities such as those disclosed in Section 6, NeatFreak’s Use

of Information, as a “sale,” we will comply with applicable law as to such activity.

NeatFreak discloses the following categories of information for commercial purposes:

  Commercial Information;

  Demographic Data;

  Location Data;

  Identifiers;

  Inferences; and

  Internet activity.

We use and partner with different types of entities to assist with our daily operations and

manage the NeatFreak Platform. Please review Section 7, Information Sharing, for

more detail about the parties with which we share Personal Information.

Right to Know and Delete. If you are a California resident, you have the right to know

certain information about our data practices in the preceding 12 months. In particular,

you have the right to request the following from us:

 The categories of Personal Information we have collected about you;

 The categories of sources from which the Personal Information was collected;

 The categories of Personal Information about you we disclosed for a business purpose

or sold;

 The categories of third parties to whom the Personal Information was disclosed for a

business purpose or sold;

 The business or commercial purpose for collecting or selling the Personal Information;

and

 The specific pieces of Personal Information we have collected about you

In addition, you have the right to delete the Personal Information we have collected from

you. However, this is not an absolute right and NeatFreak may have legal grounds for

keeping such data.

To exercise any of these rights, please submit a request via email

(founders@neatfreak.us). In the request, please specify which right you are seeking

to exercise and the scope of the request. We will confirm receipt of your request within

10 days. We may require specific information from you to help us verify your identity and

process your request. If we are unable to verify your identity, we may deny your

requests to know or delete.

Right to Opt-Out. To the extent NeatFreak sells your Personal Information as the term

“sell” is defined under the CCPA, you have the right to opt-out of the sale of your

Personal Information by us to third parties at any time. You may request to opt-out by

clicking Do Not Sell My Personal Information and making your choice.

Authorized Agent. You can designate an authorized agent to submit requests on your

behalf. However, we will require written proof of the agent’s permission to do so and

verify your identity directly.

Right to Non-Discrimination. You have the right to non-discriminatory treatment by us,

should you exercise any of your rights.

Shine the Light. Customers who are residents of California may request: a list of the

categories of Personal Information disclosed by us to third parties during the

immediately preceding calendar year for those third parties’ own direct marketing

purposes, and (ii) a list of the categories of third parties to whom we disclosed such

information. To exercise a request, please contact us via email

(founders@neatfreak.us). Requests must include “California Shine the Light

Request” in the first line of the description and include your name, street address, city,

state, and ZIP code. We may require additional information from you to allow us to verify

your identity and are only required to respond to requests once during any calendar

year. Please note that NeatFreak is not required to respond to requests made by means

other than through the provided email address or mail address.