PRIVACY PRACTICE STATEMENT

Valid Evaluation, Inc. (“Company”) – Privacy Practice Statement

Valid Evaluation, Inc. (“Company”) believes that understanding what our customers want for products, services and information is an important part of building an interesting and useful on-line environment and, if applicable, applications designed for download and use on mobile or other digital communication devices. Company wants to contribute to providing a safe and secure environment for you, the individual, whether as a sole individual or acting on behalf of an entity, if you choose to become an interactive participant on this Company Web Site (“Site”) and a subscriber to or user of Company's products and/or services.

You acknowledge because you are accessing and using this Site that you have read, understood and agreed to the terms and conditions of this Privacy Practice Statement and expressly consent to the practices described herein below.

Company has designed its Site with this belief in mind, and has created this page so that you have easy access to information about Company’s privacy practices. At any time, however, Company may change its privacy practice and privacy practice statement. In the event Company does so, Company will post these changes here so that you will always know what information Company will gather, how Company might use that information and whether Company will disclose the information to anyone. Your continued use of this Site constitutes acceptance of these changes. Notwithstanding the foregoing, we are not required to provide you any notice about any changes and you waive the right to receive any notice; and as a result, you are obligated to check this Site frequently for any changes.

Your California Privacy Rights:

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. Further, you acknowledge that certain California laws will come into effect during the term herein and that you will have rights under those laws and, in particular, the California Consumer Privacy Act (effective January 1, 2020). If you are a California resident and would like to make such a request, please submit your request in writing to:

Valid Evaluation Inc. (“Company”) – Contact Information:

Contents:

• What Information Does Company Collect On-line?
• What Sort of Information Will Company Not Collect?
• How Does Company Use the Information It Collects?
• “Cookies” or Web Beacons — What are They and How Does Company Use Them?
• How Does Company Use Email or Messages?
• What Information may Company Share with Others?
• What Information will Company Not Share With Others (with special attention to children)
• How to Contact Company with Questions or Comments
• Choices for Your Site Interaction
• Security and Retention of Your Personal Information

What Information Does Company Collect On-line?

When you visit Company’s Site and/or subscribe to or access and use Company’s products and/or services, Company asks you to provide information by filling out and submitting an on-line form. This information may include your name, registration name, account name, registration name, billing address, business or home address, cell phone number, wireless email address, physical location, mailing address, Internet email address and, in the case of service and/or product transactions that are subject to acceptance of applicable agreements, your credit card number. Company asks for this information so that Company can provide to you your selected products and/or services. The information is stored in Company’s customer file in a secure environment separate from the Site. You can always choose whether or not to disclose any or all of the information requested; however, certain information is required for subscribing to or using our services and/or products as recited in applicable agreements.

Company may also occasionally send details about our sales, new products, new services, new partnerships, special offers, market expansion and promotions to the email address you provide.

Additionally, Company automatically gathers certain usage information like the number and frequency of visitors to the Site or the number and type of customers that access and obtain Company’s product and/or service offerings or apply for Company employment positions. Such information may also include demographic information such as date of birth, age or gender. Company only uses and analyzes such information in the aggregate, not at the individual level, to make improvements to its Sites and to its product, goods and service offerings or employment opportunities. Therefore, any individual and personal information, such as your name and email address, is not included in this analysis.

Information provided when users establish an account, such as their email address, username, password, and other contact information provided, as well as information they provide in connection with their other digital device account, such as a profile picture. If a user is a customer, we may also collect their information about how they use and interact with Company, and when they use their digital devices to view product or service offerings and purchase products or services under applicable agreements.

Information related to a user’s purchase, if applicable, of products and services by using a credit/debit card, billing address, the products and services purchased, and other related transaction information.

Information about a user’s Internet connection, browser, or computer/device, IP address or digital device ID, and information on how they use and interact with digital devices, such as pages, portals, platforms or features they access.

If a user links their social media profiles and accounts on this Site or other digital devices through social media networks (e.g., by clicking a Facebook “like” button), information may made available to, and collected by Company, through those social media profiles and accounts. In addition, if a user elects to connect their third - party devices or third-party applications (collectively “Third-Party Apps”) to this Site or digital devices in order to utilize certain features, services, platforms and functionalities, we may collect information from such Third-Party Apps.

If a user accesses via a mobile device this Site through an application or accesses this Site from other external devices or sources, Company applies these privacy practices to the foregoing.

The user acknowledges that this Site is for the provision of services/products through a portal on a platform described on the Site and the privacy issues described herein are applicable to users of the Company’s services/products.

Information We Collect:

• We collect the information you give us in order to provide you products and/or services, inform you about our products and/or services, to provide you access to particular tools and/or services, to send you personalized emails or secured messages pertaining to your use of the services and/or products and to fulfill your product and/or service requests.
• Administer your account or registration.
• We may work with consumer marketing companies to help us better target our services and/or product communications to you.
• Statistically analyze user behavior and activity.
• Conduct research and measurement activity.
• We do use cookies and other Internet technologies including web beacons, to manage our Site and email programs, and to personalize your interactive experiences.
• When you access our Site, we will log your IP address in our web server logs. We also collect related information such as browser type, operating system, and Web pages visited to help manage our Site.

What Sort of Information will Company Not Collect?

Company does not follow your browsing path outside of the Site.

How Does Company Use the Information It Collects?

Company may use the information it collects to improve the Site, enhance Company’s product and/or service offerings, bring you new product and/or service offerings and meet your needs related to your use of the Site and/or products and/or services.

In the end, Company hopes this information will help Company tailor its communications and/or products and/or services to your particular needs so that you receive more of what you want from Company and its products and/or services and less of what you don’t want. If you access and use Company’s products and/or services and/or visit the Site, Company will periodically supply you with information about Company’s products and/or services. If you do not wish to receive this information, please email Company at the contact below with instructions to disengage you from the receipt of such information.

How We May Use Certain Personal Information:

• We use personal information to deliver products/services, or to carry out the transactions you have requested.
• We use the information collected to send communications to you, such as your transactions status (e.g., agreement confirmations), information about products and/or services available from Company and its corporate affiliates, promotional offers, and surveys.
• We use the information to customize, analyze, and improve our products, services (including our Site), technologies, communications and relationship with you.
• We use the information to enforce our conditions of payment under applicable agreements, Site terms and/or separate contracts (if applicable) with you.
• We use information to prevent fraud and other prohibited or illegal activities.
• We use information for transaction fulfillment.
• We use information to communicate special offers, promotions and information about our products and/or services.
• We use information to send newsletters, announcements, reminders and other opportunities.
• We use your information to send out product and/or service alerts, product and/or service pricing change alerts, product and/or service availability alerts and associated Company information.
• We use information to administer your account or registration.
• We use information to provide you access to and use of certain tools and/or services.
• We use the information to respond to your inquiries, including personalized emails.
• We use information to obtain feedback.
• We use information to statistically analyze user behavior and activity.
• We use the information to conduct research and measurement activities.
• We use the information to administer your account for providing services.
• We use the information to comply with legal requirements or to respond to legal process; to maintain the security of our products and services; and to protect Company’s proprietary rights and interests.

“Cookies” or Web Beacons — What are They and How Does Company Use Them?

A cookie is a small file stored on your computer by a Site to give you a unique ID. Cookies help make it easier for you to use the Site, and they help Company provide you with the information you need — when and where you need it.

A cookie generated by a Site contains no information about you. It contains only a numeric ID that, for example, allows you to retrieve your information so that you can check on the product or service to which you have access and use. Company encourages you to update your information periodically so that Company may provide you with the best possible on-line service in connection with your platform services access and use.

Company may also use web beacons (single-pixel graphic files also known as “transparent GIFs”) to access cookies and to count users who visit the Site or open our HTML-formatted email messages. Another example of information that we automatically collect as you navigate the Site is information about your computer’s connection to the Internet. This information allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Site.

In keeping with Company’s standard policy on customer information, Company analyzes data gathered via cookies and web beacons only in aggregate, not at the individual user level.

How Does Company Use Email or Messages?

Company will send one or more emails or messages to confirm each account, registration or project service request which you elect, and Company may occasionally use email addresses or messages for promotion of services and/or products, or other items of interest to our users. If you receive an email or message from Company that you would rather not receive, please email Company at the contact below with instructions to disengage you from the receipt of such information. Please note that Company does not sell or share email addresses with other companies, except as indicated below.

Company encourages you to email info@valideval.com with your questions or comments. Company reads every email it receives.

What Information may Company Share with Others?

You must provide Company with your name or email address if you determine that you will access and use the Cohort Services described at and provided at the Site. The Cohort Services characterizers various categories of end- users as defined in the Cohort Services Agreement and End-User License Agreements (EULAs). The category of end-users comprise: Judges, Teams and Organizers. If you are accessing and using the Cohort Services for a particular Cohort (a specifically identified event, program or activity) as a Judge or a Team, your name, email address and all the information you enter on your profile will be shared with the Organizer, who is managing the specific Cohort in which you wish to participate provided that you are an authorized end-user, who has executed a EULA. Additionally, there may be additional agreements that need to be executed in order to use Company products and/or services, and as a result, Company will obtain those agreements, which are either in electronic or tangible form and may be subject to providing certain Personally Identifiable Information (PII). The access to and use of the Site does not require any registration that requests Personally Identifiable Information (PII) absent the desire to obtain the access to and use of Company products and/or services.

Company may also provide aggregate information (never information about you personally) to Company’s business partners for the purposes of enhancing Company product and/or service offerings to you.

Protecting Personal Information:

We understand the importance of ensuring that your PII is secure and protected. We respect your provision of your PII in connection with your use of the Site and your access to and use of Company products and/or services. We use a variety of security technologies and procedures to help protect your PII from unauthorized access, use, and disclosure.

Your use of the Site and/or access and use of Company products and services is considered your consent to Company’s collection, use and disclosure, as provided herein, of your PII. However, you shall also be responsible for complying with all applicable data protection and privacy laws when providing such PII data to Company via the Site or as a result of accessing and using Company’s products and/or services. You acknowledge that email may be an unsecured medium and that data encryption may not be available when transmitted via the Internet and that transmission of such PII may not be guaranteed by Company and that such PII may be intercepted, lost or breached before such PII is imported into Company’s system for processing and storage. Additionally, your PII will always be available to you for you to review, control, edit, update or delete. You, also, can disable PII data collection capabilities such as cookies. Company may engage in state of the art technical methods and processes to encrypt, verify, process, collect, store, import and export and erase such PII data once imported into the Company’s system, and implement physical security measures for physical data storage employing strict security measures and restrictions with respect to access and use of such PII data.

Company products and/or services are personalized within a computing environment that enables you to seamlessly roam and access services, products, preferences and content across a variety of computing and data transmission devices. Rather than residing as a static software program on your device, key components of Company services and/or products are cloud-based, and both cloud and local elements of the software associated with the Company services and/or products are updated regularly, providing you with the latest improvements and features. In order to provide this computing experience, we collect data about you, your device, and the way you use the Company products and/or services. You have choices about the PII data we collect and how we use it. Note that if your device is managed by your entity, your entity may use centralized management tools to control device settings, device policies, software updates, data collection by Company or the entity, or other aspects of your device, and in that event, Company shall assume no liability or responsibility for any personal data transmission or content.

Company uses all reasonable and technical availability to adhere to the principles, whether currently effective or which will come into effect (e.g., California Consumer Privacy Act (January 1, 2020), of the EU-U.S. and Swiss- U.S. Privacy Shield frameworks that were designed by the U.S. Department of Commerce, and the European Commission and Swiss Administration, respectively, to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring PII data from the European Union and Switzerland to the United States in support of transatlantic commerce. Further, if your access and use of the Site and/or Company products and/or services requires the provision of PII data that is subject to the EU’s General Data Protection Regulation that went into effect May 2018, Company shall use all reasonable resources to comply with the requirements recited thereunder and applicable to such PII data. On July 12, 2016, the European Commission deemed the EU-U.S. Privacy Shield Framework adequate to enable data transfers under EU law and on January 12, 2017, the Swiss Government announced the approval of the Swiss-U.S. Privacy Shield Framework as a valid legal mechanism to comply with Swiss requirements when transferring PII data from Switzerland to the United States. The Privacy Shield program is administered by the International Trade Administration (ITA) within the U.S. Department of Commerce to facilitate the Privacy Shield framework in the U.S. and enables U.S.-based organizations to join one or both of the Privacy Shield Frameworks in order to benefit from the adequacy determinations. To join either Privacy Shield Framework, a U.S.-based organization will be required to self-certify to the Department of Commerce (via this website) and publicly commit to comply with the framework’s requirements. While joining the Privacy Shield is voluntary, once an eligible organization makes the public commitment to comply with the Framework’s requirements, the commitment will become enforceable under U.S. law. All organizations interested in self-certifying to the EU-U.S. Privacy Shield Framework or Swiss-U.S. Privacy Shield Framework should review the requirements in their entirety. Compliance with the foregoing requires a link to: https://www.privacyshield.gov and the provision of relevant information and compliance with Privacy Shield requirements and remedies. Participation in the foregoing Privacy Shield is subject to the payment of fees. As the Privacy Laws evolve and come into effect, the new requirements will be updated into this Privacy Practice Statement at the sole discretion of the Company.

In the event of a conflict between this Privacy Practice Statement and the terms of any agreement(s) between you and Company, the terms of those agreement(s) will control.

Company utilizes, if applicable, a payment arrangement and/or service as indicated on the Site (including the checkout page) that is consistent with reasonable industry standards for obtaining and processing payments and engages in practices as recommended by the payment administrator and/or processor. The use of this arrangement and/or service is to facilitate privacy concerns regarding payment information used and processed at this Site or under an applicable product or service agreement.

Disclosing Personal Information:

• We may share your PII with corporate affiliates to carry out transactions you request or to make our business or that of our corporate affiliates more responsive to your needs.
• We may share your PII with business partners that help Company carry out transactions you request or that help Company to customize, analyze and/or improve our communications or relationship with you, and then only with business partners who share Company's commitment to protecting your PII. We may also share your PII in the event of a merger, reorganization or sale of Company.
• We may disclose your PII in connection with law enforcement, fraud prevention, or other legal action as required by law or regulation, or if Company reasonably believes it is necessary to protect Company, its customers or the public or as it relates to any user understandings in connection with this Site or any agreement with Company or to enforce any tangible or intangible property rights and interests or for any other property, health or safety reasons or threats of any person of which we become cognizant as a result of interaction with this Site, including fraud or your identity verification.
• We employ other parties to carry out certain functions or operations on our behalf, who are authorized to use the PII solely for our purposes (e.g., web site developers, analyzing user data).
• We may share PII with Social Networks when users interact with this Site or other digital devices (e.g., clicking the “like” button on Facebook) or Third-Party Apps.
• Except as described above, we will not disclose your PII to other third parties unless you have provided consent.

What Information Will Company Not Share with Others?

PII from you is not made available to others visiting the Site. However, as provided under the relevant Cohort Services Agreement or End-User License Agreement or such other agreement that Company uses to provide products and/or services are never made available to others that are not participating in the same Cohort and associated Cohort Activity utilizing the Cohort Services.

Company will not share, sell or trade email addresses, which are personal to you, and that are collected as part of a survey, with others. Except to verify credit card information to complete your registration, service and/or product transaction, where applicable, Company will not use or release to others any credit card or financial information for any purpose. For privacy purposes, all information relating to our customers is stored on a highly secure server that is not accessible via the Internet.

Third-party web sites, apps or other digital devices are not under our control except to the extent that you use the foregoing to access the Site. The foregoing have their own privacy notices independent of this Site and the privacy practice described herein applies to this Site only when accessed via digital devices. If you have opted in to login to the Site with LinkedIn, this is third-party policy is important for you to understand: https://www.linkedin.com/legal/privacy-policy.

Special Attention to Children:

Company takes special care to protect the safety and privacy of young people accessing and using our services and/or products. Company does not specifically collect information about children and believes that children should get their parents’ consent before giving out any PII. Company encourages you to participate in and supervise your child’s Internet experience. Specifically, children under age 13 will not be subject to collection or storage of PII by us if we know the user to be 13 or younger and more specifically, we do not knowingly collect PII from or solicit persons under 13 years of age. Users 14- 18 must have parental permission to interact with the Site or digital devices.

How to Contact Company with Questions or Comments:

Company is always happy to answer your questions and listen to your comments, and Company offers several options for you to contact us.

Choices for Your Site Interaction:

• You may instruct Company to stop sending you certain promotional materials (e.g., email messages, newsletters) by following the unsubscribe instructions provided in our materials; or you can selectively opt out of certain mailings without affecting your use of the Site.
• You may request that Company remove you from (opt out of) direct mail, telephone, fax, message or email communications.
• You may choose to view or edit your PII that has been stored online by visiting the account section of the Site. For the security of your account, you will be required to sign in with your login ID and password.
• You may contact Company to determine the types of PII that we process and to correct or update your PII.
• Note, this Privacy Practice Statement is specific to the United States. Privacy practices vary from country to country, and you will be responsible for knowing local country privacy requirements and compliance therewith. Company shall not be liable for privacy compliance outside the United States. You will be responsible for knowing the existing privacy requirements in each state from which you access this Site.

Security of Your Personal Information and Retention of Your Personal Information:

We take what we believe to be reasonable precautions and have implemented managerial and technical procedures to try to protect the security of data and information, including PII. However, we cannot guarantee against any loss, misuse, unauthorized disclosure, or alteration or destruction of data or PII. You provide your PII to us at your own risk. You acknowledge that: (1) there are security and privacy limitations in computer systems and on the Internet, including any type of digital communication or mobile devices, which are beyond our control; (2) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Site, including PII, cannot be guaranteed; and (3) any such information and data, including PII, may be viewed or tampered with by a third party while such information or data is being used, transmitted, processed, or stored. Where your use of the Site includes the processing of PII data, the foregoing personal data processing, storage and erasure will apply. For the purposes of any agreement in effect, you are the data exporter. Within fourteen (14) days of the date of termination, Company, at your request, we will export or download your data; or in the alternative, delete, destroy and erase all data and confirm such destruction with written confirmation. After the lapse of such thirty (30) days, we will have no further obligation to maintain the data or return any data to you and we will delete, destroy and erase the data.

We keep your PII only as long as we need it for the purposes for which it was originally collected (or to which you have subsequently consented) or for other legitimate purposes (such as regulatory compliance), or as permitted by applicable law.

BY SUBMITTING YOUR PII TO US, YOU ARE CONSENTING TO THE PROCESSING OF YOUR PII IN THE UNITED STATES OR IN ANY OTHER COUNTRY IN THE WORLD AND TO OUR USE OF YOUR PII AS SET FORTH IN THIS PRIVACY PRACTICE STATEMENT. IF YOU ARE SUBMITTING PII OF THIRD PARTIES TO US, YOU WARRANT AND REPRESENT THAT YOU HAVE FULL AUTHORIZATION AND CONSENT FROM THE THIRD-PARTY TO PROVIDE PII TO US, AND THAT YOU WILL HOLD US HARMLESS FROM AND AGAINST CLAIMS BY SUCH THIRD-PARTY INDIVIDUALS RELATING TO OUR PROCESSING AND USE OF SUCH THIRD-PARTY PII WITHIN THE TERMS OF THIS PRIVACY PRACTICE STATEMENT.

Links to Other Websites

We are not responsible for the practices employed by websites linked to or from our Site nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of this Site.

Please remember that when you use a link to go from this Site to another website, our Privacy Practice Statement is no longer in effect. Your browsing and interaction on any other website, including websites which have a link on this Site, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.

Your Consent

By using this Site you consent to our collection and use of your PII as described in this Privacy Practice Statement. If we change our privacy policies and procedures, we will post those changes on this Site to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it.

Consent to United States Law

Please note that your PII will be stored and processed on our computers in the U.S. or, at our discretion, outside of the U.S. If you access this Site or our products and services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from U.S. laws, please be advised that through your continued use of this Site, you are transferring your PII to the U.S. and you consent to that transfer and this Privacy Practice Statement. Additionally, you understand that your PII may be processed in countries (including the U.S.) where laws regarding processing PPI may be less stringent than in your country.

You and Company also agree and hereby submit to the exclusive personal jurisdiction and venue of the competent courts in the State of Colorado, county of Denver or the nearest Federal Court with respect to such matters. Company makes no representation that materials on this Site are appropriate or available for use in other locations, and accessing them from territories where their contents are illegal is prohibited. Those who choose to access this Site from other locations do so on their own initiative and are responsible for compliance with local laws. You shall adhere to U.S. Export Administration Laws and Regulations, and to International Internet Laws, Rules and Regulations.

The Terms of Use shall serve to supplement this Privacy Practice Statement and is incorporated herein by reference, and in the event of conflict, the terms recited in this Privacy Practice Statement shall prevail.

Changes to this Privacy Policy (Privacy Practice Statement)

We reserve the right, at any time, to add to, change, update, or modify this Privacy Practice Statement by posting such change, update, or modification on the Site. Any such change, update, or modification will be effective immediately upon posting on this website.

CONTACT: Please let us know if you found the above useful with respect to your access and use of the Site. Any questions, clarifications, changes to PII or opt out needs, or any other concerns regarding this Privacy Practice Statement, please contact:

Valid Evaluation Inc. (“Company”) – Contact Information: