E Shells, Inc.

Platforms Privacy Policy

Last Revised: April 13, 2021

E Shells, Inc. (collectively with its subsidiaries, “Shells,” “Company,” “we,” “us,” and “our,”) respects your privacy and is committed to protecting your privacy through our compliance with this Platforms Privacy Policy (the “Policy”). This Policy should be read in conjunction with our Platforms Terms of Use, into which this Policy is incorporated by reference.

This Policy describes:

• The types of information we collect from you or that you may provide when you visit our website available at https://www.shells.com/l/en-US/ (our “Website”), as well as the E Shells desktop cloud system (the “Application,” and together with the Website, the “Platforms”).

• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on the Platforms or in emails and other electronic messages between you and the Platforms, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by Shells or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Platforms (for further information, see below, “Third-party Platforms”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Platforms. By using our Platforms, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Platforms after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and share information about you in accordance with this Policy.

Information You Provide to Us

Personal Information is any information that can be used to individually identify you from a larger group, such as data including, but not limited to, your:

• first and last name;

• email address;

• display name;

• zip code;

• apply for a job;

• credit card number; and

• comments or messages provided in free text boxes.

You may provide us Personal Information when you:

• request information;

• download the Platforms;

• subscribe to our blog or any automated emails; and

• register yourself with the Platforms.

The information that you provide in each case will vary. Although we may ask for your credit card information, Shells does not store, process, or otherwise have access to credit card information. Any credit card information you provide will be processed by a trusted third-party PCI-DSS compliant processor, such as Stripe, Inc.

In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting Shells to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers or other sensitive personal data. Additionally, we may ask you to create a username and password that should only be known to you.

Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Platforms. Some of the tools we use to automatically collect information about you may include:

1. Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:
   
   (1) session cookies, which do not stay on your device after you close your browser, and
   
   (2) persistent cookies, which remain on your device until you delete them or they expire.

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Platforms’ features or lose access to some functionality.

2. Analytics Services. The Website may send aggregated, non-Personal Information to analytic services such as Google or HubSpot for the purpose of providing us with the ability to conduct technical and statistical analysis on the Platforms’ performance.

3. Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Platforms. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.

4. Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

5. Third-party Platforms and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Platforms and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.

Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested.

If we ever provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

Information of Minors

We do not intentionally seek to gather information from individuals under the age of eighteen (18). We do not target the Platforms to minors, and would not expect them to be engaging with our Platforms or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• Assisting you with items such as personalized experiences, facilitation of product usage, and enforcement of the Terms of Use.

• Preventing malicious activity and providing you with a secure experience.

• Providing service and support for services you request.

• Providing marketing communications that are effective and optimized for you.

• Keeping you up-to-date with the latest benefits available from us.

• Preventing unwanted messages or content.

• Measuring the performance of our marketing programs.

• Contacting you about services and offers that are relevant to you.

How We Share Your Information

We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to our trusted third-party business partners in accordance with this Policy. We work with a number of partners that help us process your requests, deliver customer service and support, send email marketing communications, and provide experiences that you have come to expect from us. We will share your Personal Information with these third parties in order to fulfill the service that they provide to us. These third-party partners are under contract to keep your Personal Information secure and not to use it for any reason other than to fulfill the service we have requested from them.

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:

• Responding to duly authorized information requests from law enforcement or other governmental authorities.

• Complying with any law, regulations, subpoena, or court order.

• Investigating and helping prevent security threats, fraud, or other malicious activity.

• Enforcing or protecting the rights and properties of Shells or its subsidiaries.

• Protecting the rights or personal safety of Shells’ employees.

There are circumstances where Shells may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, Shells will ensure your information is used in accordance with this Policy.

Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Platforms may link to third-party websites and services such as Facebook, Twitter, Instagram, and Reddit, but these links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

Your California Rights

Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.

Other than as disclosed in this Policy, the Platforms do not track users over time and across third-party websites to provide targeted advertising. Therefore, the Platforms do not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.

For Platforms’ Users Outside of the United States

We do not warrant or represent this Policy or the Platforms’ use of your Personal Information complies with the laws of any other jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

For Platforms’ Visitors in the European Union (“EU”)

Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU are afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR. For the purposes of this Policy, Shells operates as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Policy.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

The Data Controller is:

NAME: E Shells, Inc.

ADDRESS: 8550 W. Charleston Blvd., Unit 102, Box 104, Las Vegas, Nevada 89117

EMAIL ADDRESS: [email protected]

You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:

• Access. You may email us at [email protected] to request a copy of the personal data our Platforms’ databases currently contain.

• Automated Processing and Decision-Making. You may email us at [email protected] to request that we stop using your personal data for automated processing, such as profiling. In your email, please explain how you wish us to restrict automated processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.

• Correction or Rectification. You can correct what personal data our Platforms’ database currently contains by accessing your account directly, or by emailing us at [email protected] to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.

• Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to [email protected]. In your email, please explain how you wish us to restrict processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

• Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to [email protected]. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

• Portability. Upon request and when possible, we can provide you with copies of your personal data. You may submit a request via email to [email protected]. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.

• Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through the Platforms by notifying us via email at [email protected]. Using the same email address associated with your Platforms’ account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

• Erasure. If you should wish to cease use of our Platforms and have your personal data deleted from our Platforms, then you may submit a request by emailing us at [email protected]. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.

• Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.

Changes to this Policy

If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any unauthorized use.

How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at [email protected].

5900 Wilshire Blvd., Unit 2110
Los Angeles, CA 90036