Patrocinium Systems, Inc. (“Patrocinium”) is committed to maintaining your privacy. This privacy policy and agreement (our “Privacy Policy”) specifies the personal information that we ask you to provide in order to use the ArcAngel Platform effectively, and governs how we treat this personal information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. YOUR CONSENT TO THE TERMS OF THIS PRIVACY POLICY CREATES LEGAL OBLIGATIONS FOR YOU AND FOR US. PLEASE READ SECTION 2 (YOUR CONSENT) TO LEARN WHAT CONSTITUTES “CONSENT” UNDER THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE REFRAIN FROM USING THE ARCANGEL PLATFORM.

Capitalized terms are defined in context or in the Definitions Section provided at Section 16.

1. Who We Are and What We Do. Patrocinium has created its ArcAngel software application and personal safety information website (collectively, the “ArcAngel Platform” or the “Platform”) to provide an online platform for coordinating and communicating information for civilians and first responders in the event of an emergency situation (an “Emergency”). The ArcAngel Platform functions as follows: (i) First Responders register with us to receive Incident Information in the event of an Emergency; (ii) Institutions contract with us to coordinate use of the Platform for their Community; (iii) Civilians register with us to participate in the Emergency Coordination Services facilitated by the ArcAngel Platform; and (iv) we provide ongoing hosting and support to assist in the Emergency Coordination Services facilitated by the ArcAngel Platform.

2. Your Consent. Please read this Privacy Policy carefully; once you consent to this Policy’s terms, it creates legal obligations on you and on Patrocinium. We ask you to show your consent to the terms of this Privacy Policy in different ways, depending on your relationship to the Platform. The procedures for consenting to this Policy are (a) less formal if you are simply a casual Site Visitor, and (b) more formal if you are seeking to become an ArcAngel User on the Platform.

2.1 Consent by Site Visitor. By accessing and using our Site as a Site Visitor, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it. If you do not agree with the terms of this Privacy Policy, please refrain from using our Site or our ArcAngel Platform.

2.2 Consent by ArcAngel Users. If you register as a user of the ArcAngel Platform, you will be prompted to click an “I Accept” button linked to this Policy during the registration process. Clicking “I Accept” confirms your agreement to be bound by this Privacy Policy.

2.3 Eligibility. We do not intentionally collect Personally Identifiable Information from children under the age of 18 (“Minors”) without parental or legal guardian consent. By registering to use the ArcAngel Platform and consenting to this Privacy Policy, you represent that (i) you are at least 18 years of age, and (ii) you are either consenting for yourself or on behalf of your child or a child in your legal care. If you are a parent or guardian consenting to this Privacy Policy for the benefit of your child, please review Section 5.4 (Emergency Contact Information and Minors) closely, as it relates to use of the Platform by Minors.

3. Our Services Rely In Part On Information from You. Information you may provide or that we may collect from you while visiting our Site or while participating in our Services falls into two broad categories: (i) Personally Identifiable Information, and (ii) Anonymous Information. We use the term “Personally Identifiable Information” to mean any information that could reasonably be used to identify you, including your name, address, e-mail address, birth date, financial information, photograph, telephone number or any combination of information that could be used to identify you. “Anonymous Information” is information that does not identify you, and may include statistical information concerning, for example, your use of our Platform, the pages on our Site that you visited, or your proximity to an Emergency.

4. Site Visitors Only Provide Anonymous Information. As a Site Visitor, we allow you to decide whether you wish to provide us with Personally Identifiable Information. Accordingly, we have structured our Website so that you may visit our Site, and review selected information about our Platform, without revealing your identity or providing any Personally Identifiable Information. In that case, the only information we collect from your visit will be Anonymous Information that does not identify you in any way. Our obligations concerning, and permitted uses of, Anonymous Information are also set out below in Section 8 (Anonymous, Aggregate Information).

5. Personally Identifiable Information; Our Uses of this Information. To facilitate the effective functioning of the ArcAngel Platform, including facilitating the exchange of Incident Information between ArcAngel Users, we obtain Personally Identifiable Information from you. We will only share Personally Identifiable Information you choose to provide to us via the Website or ArcAngel Platform with third parties as expressly disclosed in this section. We will not share it in any other way. We collect information from ArcAngel Users at different points through the ArcAngel Platform, and use this information as follows:

5.1 Registration Information; User Names. In order to obtain full and effective use and benefits from the ArcAngel Platform, we require that you provide complete registration information. Our registration form will specify the information that you must provide for use of the ArcAngel Platform, including (i) name, (ii) address, (iii) phone number, (iv) email address, (v) birth date, (vi) photograph, and other information that may be used to identify you (“Registration Information”). Our registration form may additionally request information, which you may, at your option, choose to provide or withhold. To the extent this additional information constitutes Personally Identifiable Information, we will treat it as Personally Identifiable Information in the manner specified in this Privacy Policy.

5.1.1 Completing Your Registration as an ArcAngel User; User Passwords. The registration process provides ArcAngel Users with a user name and password, which allows them to gain access to the password protected areas of Website and the ArcAngel Platform.

5.1.2 Protecting Your Password. Please keep in mind that we will treat anyone who uses your user name and password as “you.” We will provide this user with all of the rights and privileges that we provide to you, and we will hold you responsible for the activities of the person using your password. Therefore, we recommend that you maintain your user name and password in confidence, and that you refrain from disclosing this information to anyone who might “pretend” to be you with respect to the ArcAngel Platform. We also ask that you notify us immediately if you suspect that someone is using your user name and/or password in this or any inappropriate manner.

5.2 ArcAngel Users Provide Financial Information, Emergency Contact Information, Geolocation Information, and Other Similar Personally Identifiable Information.

5.2.1 Baseline Information. To register as an ArcAngel User and be able to fully participate in the ArcAngel Platform, you first need to provide Registration Information, and complete the steps required to be an ArcAngel User, including enabling GPS/location services for the ArcAngel App on your mobile device.

5.2.2 Emergency Contact Information. We collect information from you related to individual(s) you want to receive notifications about your status in the event of an Emergency (“Emergency Contact Information”). Emergency Contact Information includes (i) name, (ii) mobile phone number, (iii) email address, and (iv) relationship to the ArcAngel User for each person you want to receive notifications. Your provision of Emergency Contact Information is optional and you may update or change your Emergency Contact Information at any time. By providing Emergency Contact Information, you represent and warrant that you have the permission of each individual you designate as an Emergency Contact to provide their contact information. We will only use the Emergency Contact Information you provide in the event of an Emergency and for no other purpose. For example, in the event of an Emergency, if you activate the ArcAngel App or otherwise provide status information via the ArcAngel App, we will notify your Emergency Contacts regarding your location and status (if known).

5.2.3 Geolocation Information. In order to provide Incident Information to First Responders, the ArcAngel App will utilize the GPS feature on your mobile device to determine your location (your “Geolocation Information”). You must enable the GPS/location services for the ArcAngel App on your mobile device in order for this feature of the ArcAngel Platform to function effectively in the event of an Emergency. To the extent your Geolocation Information is combined with any Personally Identifiable Information, we will treat it as Personally Identifiable Information under this Privacy Policy. We may use your Geolocation Information to determine your proximity to an Emergency in order to provide notifications to you regarding the Emergency. We will only share your Geolocation Information with First Responders and your Emergency Contacts in the event of an Emergency. NOTE: The ArcAngel App may increase mobile device battery usage when using Geolocation Information in the event of an Emergency.

5.3 How We Use Your Personally Identifiable Information.

5.3.1 Provision of the ArcAngel Platform. We use your Personally Identifiable Information in the operation of our ArcAngel Platform and to comply with Applicable Law. You cannot use the ArcAngel Platform if you seek to opt-out of these uses of your Information.

5.3.2 Email Addresses. Both Site Visitors and ArcAngel Users may wish to provide us with questions, comments, and feedback concerning the Platform generally. By communicating with us for these purposes, you may provide us with your email address and other Personally Identifiable Information. In these instances, we use any information you provide to us strictly for the purposes for which you submit the information.

5.4 Emergency Contact Information and Minors. Where a parent or legal guardian has registered a Minor to use the ArcAngel Platform, the parent/legal guardian may include him/herself or other family members as Emergency Contact Information for the Minor. The ArcAngel Platform will provide a notification to these Emergency Contacts in the event the Minor is involved in an Emergency, including circumstances where the Minor calls 911.

5.5 Push Notifications. In the event of an Emergency, increased threat level, or other incident near your location, we may send a push notification via the ArcAngel App to you and will use Personally Identifiable Information to send such communications. You cannot use the ArcAngel Platform if you seek to opt-out of these uses of your Information.

5.6 Informational Notices and Bulletins. Periodically, we may choose to send news, bulletins, or other information to ArcAngel Users, and will use Personally Identifiable Information to send such communications. If we choose to undertake such communications, you will have the ability to opt out of receiving these communications as provided in Section 7 (Changing or Removing Information; Opting Out).

6. We Do Not Disclose Personally Identifiable Information to Unaffiliated Third Parties; Limited Exceptions. We will not disclose your Personally Identifiable Information to unaffiliated third parties without your express consent, except in the following limited circumstances:

6.1 Patrocinium Vendors. We may employ other companies to perform functions on our behalf, such as hosting or maintaining the ArcAngel Platform or the Site, providing services related to the ArcAngel Platform, collecting information, responding to and sending electronic mail, or other functions necessary to our business. We may need to share your Personally Identifiable Information with these companies (collectively, “Vendors”). We will provide Vendors with only that information necessary to perform their functions, and we will not allow them to use your Personally Identifiable Information for any other purpose.

6.2 Question of Harm. We may reveal your Personally Identifiable Information to our attorneys or law enforcement agencies if we believe (a) that you are in risk of harm from another, (b) that you are harming or interfering (or will harm or interfere) with others, or (c) that you are violating (either intentionally or unintentionally) our End User License Agreement or otherwise violating legal rights.

6.3 Legal. Patrocinium will reveal your Personally Identifiable Information, to the extent we reasonably believe we are required to do so by law. If we receive legal process calling for the disclosure of your Personally Identifiable Information we will attempt to notify you via the email address you supplied during registration within a reasonable amount of time before we respond to the request, unless such notification is not permitted.

6.4 Transfer of Site. Patrocinium shall be entitled to transfer to a third party information it collects, including any Personally Identifiable Information, in connection with a sale of all or substantially all of the assets of the business entity responsible for the information under this Policy, provided the acquiring third party has agreed to safeguard your Personally Identifiable Information with protections that in all material respects are the same as or more protective than those set out in this Privacy Policy.

7. Changing or Removing Information; Opting Out.

7.1 Discretionary Account Information. To allow appropriate control over Personally Identifiable Information, you can access your account (after supplying your user name and password) to change or update the information that you have previously submitted.

7.2 Opt-Out. If we choose to send to you bulletins, updates, or other unsolicited communications that are marketing-related materials, we will provide you with the ability to decline — or “opt-out of” – receiving such communications. Instructions for opting-out will be provided if and when we determine to send you such a communication. Please understand that you will not be allowed to “opt-out” of formal notices concerning operation of the Platform, and legal and other related notices concerning your relationship to the Platform.

7.3 Deleting Information. Finally, if you request, we will remove your name and all other Personally Identifiable Information from our databases. Please understand, however, that it may be impossible to remove this information completely, due to backups and records of deletions. In addition, please understand that, if you request deletion of your information, you will be unable to utilize associated features of the ArcAngel Platform. You may not remove de-identified, anonymous, or aggregate data from our databases.

8. Anonymous, Aggregate Information. We use Anonymous Information to analyze the effectiveness of the ArcAngel Platform, to improve the Platform, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users of the Platform and the characteristics of visitors at our Site. We may collect Anonymous Information through features of the software that supports our Platform, through cookies, and through other means described below. Rest assured, though, we will never sell your Personally Identifiable Information to a third party.

8.1 IP Addresses; Logs. Patrocinium may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your computer), your computer’s name, the type and version of your web browser, referrer addresses and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used, and for security and monitoring purposes.

8.2 Cookies. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website. You may set your browser so that it does not accept cookies. Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our Services.

8.3 Click-Throughs. We may send email messages, which use a “click-through URL” linked to content on our Website. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked simply do not click text or graphic links in the email, or notify us in accordance with Section 7 (Changing or Removing Information; Opting Out).

8.4 Computer Configuration. In order to determine whether your computer or mobile device is supported by our system, we may collect certain Anonymous Information. This information includes, but may not be limited to, your operating system and browser, as well as the presence of any software that our Platform may require to operate with your computer/mobile device or other third party software on your computer/mobile device. This information is kept strictly confidential and is not shared with third parties, except as provided for in this Privacy Policy.

9. Any Information Linked With Your Personally Identifiable Information Is Protected As “Personally Identifiable Information.” To enable us to better understand the characteristics of our ArcAngel Users and/or to provide services tailored to your needs, we may link (a) the Personally Identifiable Information you have provided; with (b) Anonymous Information. If we combine or link any Anonymous Information or other information with your Personally Identifiable Information, the resulting combination will be treated and protected as Personally Identifiable Information under this Privacy Policy. Accordingly, no unrelated third parties will have access to this information, and any of our service providers who are granted access to this information will be bound to protect it in accordance with this Policy.

10. Security. We have put in place security systems designed to prevent unauthorized access to or disclosure of Personally Identifiable Information you provide to us, and we take all reasonable steps to secure and safeguard this Information. Our Platform’s password-protected areas require users to give us unique identifiers such as their user name and password. Patrocinium employees are required to acknowledge that they understand and will abide by our policies with respect to the confidentiality of Personally Identifiable Information. Additionally, we ensure that Patrocinium’s Vendors’ security policies are at least as protective of your information as our policy. Moreover, we provide access to our databases containing Personally Identifiable Information on a need-to-know basis only.

Our security systems are therefore structured to deter and prevent hackers and others from accessing information you provide to us. We also use software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. Please understand, though, that this information should not be construed in any way as giving business, legal, or other advice, or warranting as fail proof, the security of information provided by or submitted to Patrocinium. Due to the nature of Internet communications and evolving technologies, we cannot provide, and disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

11. Notice of Security Incident. If we detect, despite the safeguards set out above, an intrusion or other unauthorized access to or use of Personally Identifiable Information (an “Intrusion”), we will (i) notify affected users of the Intrusion if the information at issue is sensitive, in our discretion, (ii) deliver this notice by the means we deem most efficient under the circumstances (such as, for example, first class mail or email); (iii) use contact information for each effected user that is current in our files; and (iv) use commercially reasonable efforts to accomplish these steps and effect this notice in a timely manner. To the extent applicable law requires steps in addition to those specified above, we will under all circumstances comply with applicable law.

12. Participation by Children and Teens; Advisory. Due to federal law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT ALLOW INDIVIDUALS WHO WE KNOW ARE UNDER 13 TO PARTICIPATE IN OUR PLATFORM WIHTOUT PARENTAL CONSENT. YOU MUST BE AT LEAST 13 YEARS OLD TO USE OUR PLATFORM. IF YOU ARE BETWEEN 13 AND THE APPLICABLE AGE OF MAJORITY, PLEASE REVIEW THIS AGREEMENT WITH YOUR PARENT OR GUARDIAN. Please understand that we cannot necessarily tell if a user is providing us with his or her true age.

13. Notification of Changes. From time to time, Patrocinium may change its Privacy Policy. If we make any changes regarding disclosure of Personally Identifiable Information to third parties, we will attempt to contact you prior to the date the modified policy is scheduled to take effect. We will post notice of the new Policy from the privacy link on our Website. With respect to Site Visitors, your use of our Site following any such change constitutes your agreement to follow and be bound by the Privacy Policy, as changed. With respect to ArcAngel Users, no such changes will take effect unless and until you have provided us with your consent to such changes, in accordance with Section 2.2 above.

14. Relationship to End User Agreement and Other Contracts. This Privacy Policy must be read in conjunction with our End User Subscription Agreement (“End User Agreement”), and the provisions of our End User Agreement are incorporated herein. To the extent the End User Agreement conflicts with the terms of this Privacy Policy, the terms of this Privacy Policy will control.

15. Further Resources. If you wish further information concerning privacy policies in general, you should visit the following sites:

https://www.ftc.gov/privacy/index.html

16. Definitions

16.1 ArcAngel Administrator. The term “ArcAngel Administrator” means either (i) the administrator designated by an Institution to coordinate use of the ArcAngel Platform within the Institution Community, or (ii) the First Responder fielding a report of an Emergency from an ArcAngel User.

16.2 ArcAngel Platform. The term “ArcAngel Platform” means the ArcAngel software provided via mobile application and also accessible via the ArcAngel Website through which ArcAngel Users can manage their information and participate in the Emergency Coordination Services.

16.3 ArcAngel Users. The term “ArcAngel Users” means, collectively, Civilians, First Responders, and Institutions.

16.4 Civilian. The term “Civilian” means an individual who has registered to use the ArcAngel Platform, including Minors who have been registered to use the Platform by their parents or legal guardians.

16.5 Community. The term “Community” means the population of ArcAngel Users associated with an Institution, including, by way of example, (i) the students, faculty and staff of an educational institution, (ii) the employees of a business, and (iii) the individual occupants of a multi-tenanted building.

16.6 Emergency. The term “Emergency” means an incident threatening the wellbeing and safety of individuals involved in and/or located in proximity to the incident.

16.7 Emergency Contact Information. The term “Emergency Contact Information” means the information related to each individual an ArcAngel User designates to receive notifications in the event the ArcAngel User is involved in an Emergency, including the individual’s (i) name, (ii) mobile phone number, (iii) email address, and (iv) relationship to the ArcAngel User.

16.8 Emergency Coordination Services. The term “Emergency Coordination Services” means the collection and coordination of Incident Information facilitated by the ArcAngel Platform in the event of an Emergency.

16.9 First Responders. The term “First Responders” means individuals and their respective organizations tasked with responding to emergency events, including but not limited to 911 dispatchers, police, fire departments, emergency medical crews, and federal investigative agencies.

16.10 Geolocation Information. The term “Geolocation Information” means geographic location information related to an ArcAngel User that is obtained by Patrocinium through the GPS services on the User’s mobile device in connection with the ArcAngel App.

16.11 Incident Information. The term “Incident Information” means information related to an ongoing Emergency, including (i) the identity, location and safety status of ArcAngel Users, (ii) the nature, location and identity (if known) of individuals or objects posing an active safety threat, and (iii) videos, photos, audio or other data related to the incident.

16.12 Institution. The term “Institution” means a business who has contracted with Patrocinium to utilize the ArcAngel Platform within its Community.

16.13 Website or Site. The term “Website” or “Site” means the ArcAngel website located at http://www.patrocinium.com at which (i) general information about the ArcAngel Platform can be obtained, and (ii) the ArcAngel software, including the personal safety information system, can be accessed by ArcAngel Users.

17. Contact Us. If you have any questions about this Privacy Policy, our practices with regard to Personally Identifiable Information, or your dealings with us, please contact us:

You may contact us, for any reason, as follows:

arcangel@patrocinium.com

18. Effective Date. The effective date of this Privacy Policy is June 13, 2018.

COPYRIGHT AND LEGAL NOTICE.

Copyright ©2019 Patrocinium Systems, Inc. All Rights Reserved.

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