Scope

This Privacy Policy applies to personal information processed by Alder FM, LLC DBA Alder(“Alder,” “we,”“us,” and “our”) in the course of operating our business, including on our website (the “Site”), our mobile application (the “App”)(together, the “Platform”) and through providing our related Services set forth in the applicable Terms of Service (collectively, the “Services”).

An Important Note: Unless otherwise stated, this Privacy Policy does not apply to any of the personal information that we process on behalf of our customers through their use of our Services (“CustomerData”). Our customers’ respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Policy.Any questions or requests relating to Customer Data should be directed to our customer.

All capitalized terms not defined in this PrivacyPolicy will have the meanings set forth in the applicable FacilitiesMarketplace Terms of Service.

PERSONAL INFORMATION WE COLLECT

We may collect the following categories of personal information.

Information You Provide to Us.

Account Creation. As a Customer, you will be provided with an “Account” for the use of the Platform andServices by your business. When you create an Account to use our Services, we collect your name, email address, business address and phone number.

Payment Information. We will collect payment information in order to charge you for the Services. Please note that we use a third-party service provider to collect and process payment card information on the Services. Alder does not directly collect or store any payment card information provided to the Services, but it may receive information associated with your payment card information (e.g., your billing details).

Your Communications with Us. We collect personal information from you such as email address, phone number, company affiliation, and location when you request information, request technical support, or otherwise communicate with us.

Customer Service and Support. If you call or otherwise interact with Alder’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.

Interactive Features. Alder may offer interactive features such as blogs, review forums, chat services(e.g., Slack channels), and social media pages. Alder and other individuals who use our Services may collect the information you submit or make available through these interactive features. Any information shared on the public sections of these channels will be considered “public” and may not be subject to the privacy protections referenced herein.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings,IMEI, MAC address, Technologies including cookie identifiers, mobile advertising and other unique identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with your Account and the devices you use.

Cookies, Pixel Tags/Web Beacons, and Personalized Advertising. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with the Services.

·      Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, theServices may not work properly.‍

·      Pixel Tags/Web Beacons. A pixel tag(also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information aboutGoogle Analytics, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

Conferences and Trade Shows. We may attend conferences and trade shows where we collect personal information from individuals who interact with or express an interest in Alder and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

Information from Other Sources. We may obtain information about you from other sources, including from third parties and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings. This supplemental information allows us to verify information that you have provided to us and provide you with information about our business, products, and the Services.

HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to:

Fulfill our contract with you and provide you with our Services, such as:

·      Providing you with the Service you requested;

·      Providing you with reminders about the Services(including SMS reminders sent via an automatic telephone dialing system);

·      Managing your information and Account;

·      Responding to your questions, comments, and other requests;

·      Providing access to certain areas, functionalities, and features of our Services;

·      Communicating with you about your Account, activities on our Services and policy changes;

·      Processing your financial information and other payment methods for products or Services purchased; and

·      Answering your requests for customer or technical support.

Analyze and improve our Services pursuant to our legitimate interests, such as:

·      Measuring interest and engagement with ourServices and/or in our other products and services;

·      Conducting research (including marketing research) and development;

·      Developing new products and services;

·      Ensuring internal quality control;

·      Verifying your identity;

·      Fraud prevention;

·      Network and information security;

·      Detecting bugs or other software issues;

·      Preventing potentially prohibited or illegal activities;

·      Auditing related to transactions;

·      Enforcing our Terms of Service; and

·      To comply with our legal obligations, protect your vital interest, or as may be required for the public good.

Other Uses – Your Consent.

Alder may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you may include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising.”

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in the Contact Us section below.

Use De-identified and/or Aggregated Information. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. De-identified and aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through a referral. The referral capability may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to visit our Services.

Automatic Collection Technologies

Our uses of Technologies fall into the following general categories:

Operationally Necessary. This includesTechnologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;

Performance Related. We may useTechnologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;

Functionality Related. We may useTechnologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include keeping track of your specified preferences, interests, or past items viewed;

Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

We may share your personal information with the following categories of third parties:

Service Providers. We may share any personal information we collect about you with our third-party service providers. The types of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services;(ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment processing; (v)customer service activities; and (vi) the provision IT and related services.

Marketplace Vendors. If you use ourMarketplace Services to inquire about the services of or book a third-party vendor(each a “Marketplace Vendor”), Alder may share related personal information with Marketplace Vendors in order to get bids and facilitate your transaction. Your personal information may also be subject to the Marketplace Vendor’s privacy policy. We are not responsible for theMarketplace Vendor’s processing of your personal information.

MailChimp. We use Mailchimp to help us with our marketing and related email services. For more details, please see the Mailchimp PrivacyPolicy.

Business Partners. We may share any of the categories of personal information that we collect in accordance with this policy with service providers who act on our behalf, our partners, or others operating at your direction or where legally necessary or appropriate.  We do not share personal information with third parties for their own marketing purposes.

Affiliates. We may share personal information with our affiliated companies.

Advertising Partners.  Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising”or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions in the Technologies and Personalized Advertising Section below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or OtherAsset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. When we conduct such transfers, we put in place appropriate safeguards (such as standard contractual clauses) in accordance with applicable legal requirements. Information located outside of your home country may be subject to access by that country’s government or its agencies under a lawful order. For more information on the appropriate safeguards in place or to obtain a copy of the standard contractual clauses, please contact us as set forth in the Contact Us section below.

YOUR CHOICES

General. You may have certain choices about your personal information.

Modifying Your Information. You can access and modify the personal information associated with your Account by logging into your Account.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to ourTerms of Service or this Privacy Policy).

Mobile Devices. We may send you push notifications through our App. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our App and have enabled this collection. You may opt-out of this collection by changing the settings on your mobile device.

“Do Not Track”. Do Not Track (“DNT”)is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Technologies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, theDigital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights.

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information;(iii) receive an electronic copy of your personal information or ask us to send that information to another company; (iv) restrict or object to our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vi) withdraw your consent; and (vii) request erasure of personal information held about you by Facilities Marketplace, subject to certain exceptions prescribed by law.

If you would like to exercise any of these rights, please contact us as set forth in the Contact Us section below. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to theCalifornia Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Alder has collected about them and whether FacilitiesMarketplace disclosed that personal information for a business purpose (e.g.,to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by Alder

Categories of Third Parties Personal Information is Disclosed to for a Business Purpose

Identifiers, including name, email address, phone number,  business address, and title/role.

·        Service providers

·        Marketplace Vendors whose services you inquire  about

·        Advertising partners

Personal information categories listed in Cal. Civ. Code § 1798.80(e), including name,  email address, phone number, business address, and title/role.

·        Service providers

·        Marketplace Vendors whose services you inquire  about

Commercial information, including business address, details  about your business’ physical space (e.g. square footage, number of floors)  and instructions for providing services.

·        Service providers

·        Marketplace Vendors whose services you inquire  about

Internet or other electronic network activity, including IP  address, user information, date, service, and data that was changed or added.

·        Service providers

‍

·        Advertising partners

Professional or employment-related information, including  the identity of the company you are seeking services on behalf of and your  individual title.

·        Service providers

·        Marketplace Vendors whose services you inquire  about

Inferences drawn from such personal information to create a  profile about a consumer.

·        Service providers

·        Advertising partners

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth above.

Additional Privacy Rights for California Residents

“Sales” of Personal Information under theCCPA. For purposes of the CCPA, Alder does not “sell”personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. 

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth in the Contact Us section below.

Verification. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the email address associated with any personal information we have about you.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us at:

Alder FM, LLC

920 Broadway, 8th Floor, New York, NY 10010

support@alderfm.com

We will process such requests in accordance with applicable laws.

De-Identified Information. If we create or receive de-identified information, we will not attempt to re-identify such information, except to comply with applicable law.

SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada RevisedStatutes Chapter 603A. If you have any questions, please contact us as set forth in the Contact Us section below.

DATA RETENTION

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

THIRD PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

CHILDREN’S INFORMATION

The Services are not directed to children under 13(or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth in the Contact Us section below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information.

SUPERVISORY AUTHORITY

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this PrivacyPolicy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this policy, please contact us at:

Alder FM, LLC

920 Broadway, 8th Floor, New York, NY 10010

support@alderfm.com