PRIVACY POLICY

I. Introduction

The 3 Squared Circles, LLC (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (this “Policy”). This Policy describes how we collect, use, disclose, and otherwise process information when you download, install, access, or use of any Application (the “App”).

For purposes of applicable data protection laws, Company is the “controller” (under the GDPR/UK GDPR) and/or “business” (under the CCPA/CPRA) with respect to personal information processed through the App. Questions or requests may be submitted to: infrastructure@3squaredcircles.com and/or 3 SQUARED CIRCLES, LLC, 6137 Crawfordsville Road Ste. F, MB # 191 Speedway IN. 46224 USA If required, Company’s designated data protection contact is: “Privacy Team”.

This Policy applies only to information we collect through the App, including in connection with communications initiated through the App (e.g., in-app chat, support requests, emails prompted by the App), and information collected via App-related technologies such as SDKs, analytics tools, and crash reporting.

This policy DOES NOT apply to information that:

Our websites and apps, and these other third parties [may] have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, create an account, or use this App. By downloading, creating an account, or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Notice to California Residents. If you are a California resident, please see Your State Privacy Rights below for additional disclosures, including categories of personal information we collect, purposes, and your rights under the CCPA/CPRA.

Notice to EEA/UK/Switzerland Users. If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, please see EEA/UK/Switzerland Privacy Rights (added below) for information on legal bases, international transfers, and your rights.

II. Children Under the Age of 13

The App is not directed to children and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will delete it. If you are located in the EEA/UK, we do not knowingly collect personal information from children under the age required by applicable local law for consent to online services (often 16, but may be lower in certain countries). Parents/guardians who believe we may have collected information from a child may contact us at infrastructure@3squaredcircles.com.

Residents of certain states under 13, 16, or 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

III. Information We Collect and How We Collect It

We collect information from and about users of our App:

• Directly from you when you provide it to us.

Unless explicitly requested by specific App features and permitted by law, please do not provide sensitive personal information through the App (e.g., government ID numbers, precise geolocation, health information). If the App does collect sensitive information for certain features, we will describe it in this Policy and provide any required choices/consents.

IV. Information You Provide to Us

When you download, create an account, or use this App, we may ask you provide information:

Personal information may include identifiers such as your name, email address, telephone number, mailing address, username/account credentials, and any other information you choose to provide through the App. Depending on App features, personal information may also include payment-related information (processed by third-party payment processors), customer support communications, and any content you submit. This information includes:

• Information that you provide by filling in forms in the App. This includes information provided at the time of creating an account on the Customer Portal Website , and subscribing to our service ,and posting material, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App.
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through the App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App.
• Your search queries on the App.

You may also provide information for publication or display (“Posted”) on public areas of the app or websites you access through the App (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Applications, including when you download, access, or use the App, we may use automatic data collection technologies to collect certain information about your browsing, usage activity and patterns.

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).

The technologies we use for automatic information collection may include:

• Cookies (or web cookies). A cookie is a small file placed on your computer. It may be possible to refuse to accept web cookies by activating the appropriate setting in your web browser. However, if you select this setting you may be unable to access certain parts of our Apps.
• SDKs and Similar Technologies. The App may use third-party software development kits (“SDKs”) and similar technologies for analytics, crash reporting, customer support, fraud prevention, and advertising measurement. These providers may collect or receive device and usage data in accordance with their own privacy policies and our agreements with them.
• Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages [or opened an email] and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie non-personal information collected automatically to personal information about you that we collect from other sources or that you provide to us.

V. Third-Party Information Collection

Third-Party Information Collection. The App may include third-party SDKs and integrations that collect or receive information from your device and your use of the App. These third parties may include analytics providers, crash-reporting providers, customer support tools, security/fraud prevention vendors, payment processors, and (if applicable) advertising or attribution partners.

These providers may collect information such as device identifiers, advertising identifiers, IP address, app activity, and diagnostic information, and may use that information to provide services to us. We do not control these third parties’ data practices; however, we require vendors to process information on our behalf consistent with this Policy where applicable.

Targeted Advertising (If Applicable). If the App uses targeted advertising, you may be able to limit ad tracking through your device settings (e.g., “Limit Ad Tracking”/”Tracking” permissions) and/or through any in-app settings we provide. See Choices About How We Use and Disclose Your Information and Your State Privacy Rights.

VI. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

• Provide and operate the App, including account creation, authentication, feature delivery, and customer support.
• Process transactions (if applicable), including subscription management and purchase fulfillment (typically via third-party processors).
• Communicate with you, including service-related messages (e.g., security alerts, updates, policy changes) and responding to requests.
• Improve and develop the App, including analytics, debugging, crash reporting, and testing.
• Protect the App and users, including security monitoring, fraud prevention, and enforcement of our agreements.
• Comply with legal obligations and respond to lawful requests.
• Marketing (if applicable), where permitted by law and subject to your choices.

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our App according to your individual interests.
• Speed up your searches.
• Recognize you when you use the App.

Data Retention. We retain personal information for as long as reasonably necessary to provide the App, maintain your account, comply with legal obligations, resolve disputes, enforce our agreements, and for other legitimate and lawful business purposes. Retention periods vary based on the type of information and the purposes for which it is processed.

Legal Bases (EEA/UK/Switzerland). If you are located in the EEA/UK/Switzerland, our legal bases for processing include: (a) performance of a contract (providing the App), (b) legitimate interests (e.g., security, improvement, fraud prevention), (c) compliance with legal obligations, and (d) consent where required (e.g., certain marketing, device permissions, and certain advertising activities).

VII. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

• To our subsidiaries and affiliates.
• To vendors and service providers who process information on our behalf for business purposes such as hosting, analytics, crash reporting, customer support, payment processing, security, and fraud prevention, subject to contractual obligations to protect personal information and use it only as directed by us.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of 3 SQUARED CIRCLES, LLC's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by 3 SQUARED CIRCLES, LLC about our App users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our App, we will transmit the contents of that email and your email address to the recipients.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including the End User License Agreement and Terms of Service [https://www.3squaredcircles.com/Terms], and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of 3 SQUARED CIRCLES, LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

International Transfers. If you access the App from outside the United States, your information may be transferred to and processed in the United States or other countries where we or our vendors operate. Where required by law (e.g., EEA/UK), we use appropriate safeguards for cross-border transfers such as Standard Contractual Clauses and/or other lawful transfer mechanisms.

VIII. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

• Device Permissions. You can control the App’s access to certain device features (e.g., location, camera, contacts) through your device settings.
• Push Notifications. You can opt out of push notifications by changing your device notification settings for the App.
• Email Communications. If you receive promotional emails from us (if applicable), you may opt out via the unsubscribe link in the email or by contacting us at infrastructure@3squaredcircles.com. Service-related messages (e.g., account, security, or transactional notices) may still be sent.
• Cookies/SDK Controls. Depending on your device and platform, you may be able to reset or limit your advertising identifier and opt out of certain interest-based advertising through your device settings.
• Targeted Advertising (If Applicable). If we engage in targeted advertising, you may opt out where required by law via the customer portal and/or the methods described in Your State Privacy Rights.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website.

Residents in certain states, such as California, may have additional personal information rights and choices.

IX. Accessing and Correcting Your Personal Information

Accessing, Correcting, and Deleting Your Information. You may be able to access, update, or correct certain account information through the Customer Portals account settings (https://customer.3squaredcirlces.com/Account/Manage). You may also request access to, correction of, or deletion of personal information by contacting us at infrastructure@3squaredcircles.com. We may need to verify your identity before completing your request. Certain information may be retained as required or permitted by law (e.g., for security, fraud prevention, or legal compliance).

X. Your State Privacy Rights

Your State Privacy Rights (U.S.). Depending on your state of residence, you may have rights regarding personal information, including the right to: (a) confirm whether we process personal information; (b) access personal information; (c) delete personal information; (d) correct inaccuracies; (e) obtain a portable copy; and (f) opt out of certain processing such as targeted advertising, “sales,” or certain profiling (as those terms are defined by applicable law). Some states also provide rights related to sensitive personal information.

California (CCPA/CPRA) Disclosures.

• a. Categories of Personal Information Collected. We may collect the following categories (depending on App features): identifiers (e.g., name, email), internet or other electronic network activity information (e.g., app usage), device identifiers/advertising identifiers, geolocation data (if enabled), commercial information (e.g., purchase history if Paid Features exist), and customer service communications.
• b. Purposes. We collect and use personal information for the purposes described in How We Use Your Information, including providing the App, security, analytics, and customer support, and marketing if applicable.
• c. Selling/Sharing. We do not “sell” or “share” personal information as those terms are defined under the CPRA. If we engage in targeted advertising or share certain identifiers with advertising partners, that may be considered “sharing.”
• d. Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes that require a right to limit under the CPRA.

How to Submit a Rights Request. You (or an authorized agent where permitted by law) may submit a request by:

• Email: infrastructure@3squaredcircles.com
• In-app: https://customer.3squaredcirlces.com/Account/Manage We will verify your request using information associated with your account or App usage.

Appeals (Certain States). If we decline to take action on your request, you may appeal by contacting infrastructure@3squaredcircles.com with the subject line “Privacy Appeal” and describing your request and our response.

Non-Discrimination. We will not discriminate against you for exercising privacy rights, subject to lawful incentive programs (if any), which will be described at the time offered.

XI. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. However, no method of transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for any activity under your account.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. [We urge you to be careful about giving out information in public areas of the App. The information you share in public areas may be viewed by any user of the App.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures included through the App.

XII. Changes to Our Privacy Policy

We may update this Policy from time to time. We will update the “Last modified” date at the top of this Policy. If we make material changes, we may provide additional notice through the App, by email (if you have provided one), or as otherwise required by law. Your continued use of the App after changes become effective means you accept the revised Policy.

XIII. Contact Information

Contact Information.

Email: infrastructure@3squaredcircles.com

Mailing Address: 3 SQUARED CIRCLES, LLC, 6137 Crawfordsville Road Ste. F, MB # 191 Speedway IN. 46224 USA

Complaints (EEA/UK). If you are located in the EEA/UK, you may lodge a complaint with your local supervisory authority. We encourage you to contact us first so we can try to resolve your concern.