VICEROY'S PRIVACY AND SECURITY STATEMENT

Last modified: June 2019

THE HIGHLIGHTS:

Viceroy Technologies Inc. and our subsidiaries (“Viceroy” or “we”) are committed to complying with data protection legislation, including the data protection regime introduced by the GeneralData Protection Regulation (EU Regulation 2016/679). This privacy notice contains informationon what personal data we collect, what we do with that information, and what rights you have.We process some personal data in order to run our business. There are a limited number ofcircumstances where we may share your information with third parties (for example, pursuant toa court order, if we are part of a merger, or with our business partners and service providerswho support our business or collaborate with us). We take the security of your informationseriously and take steps to keep your information secure. Please read the full Privacy andSecurity Statement below and you can always contact us if you have questions.


THE DETAILS:

INTRODUCTION

We respect your privacy and are committed to protecting it through our compliance with thisPrivacy and Security Statement. This Privacy and Security Statement (together with our Termsof Use) describes the types of information we may collect from you or that you may provide—forexample, when you visit any of our websites or contact us—and how we use, protect, anddisclose that information.

This Privacy and Security Statement does not apply to information collected on any third-partysite or application (including advertising) that may link to or be accessible from our websites. Weare not responsible for the privacy policies or data collection, use and disclosure practices ofthose sites. We encourage you to review the privacy policies of each site you visit.

Please read this Privacy and Security Statement carefully to understand our policies andpractices regarding your information and how we will treat it. By accessing or using any of ourwebsites or services (including email communications), you agree to this Privacy and SecurityStatement. This Statement may change from time to time, and these changes may affect howwe use the information described below, so please check the Privacy and Security Statementperiodically for updates.

NOTICE ABOUT HOW WE USE AND PROTECT PERSONAL INFORMATION

We collect several types of information for our business operations, including but not limited to:

Information you provide to us. When you navigate our websites or contact us, we may requestor you may choose to provide us with certain information. This may include information by which you may be personally identified (“personal information”), such as name, employer, e-mailaddress or telephone number, and records and copies of your correspondence with us. Forsecurity purposes, we may also collect personal information from you if you visit one of our offices.

Information collected from forms on our websites.

This includes information provided at the timeof registering to use portions of our websites or our products and services, posting material, orrequesting further services. We may ask you for information when you report a problem with ourwebsites, products or services.

Usage details, IP addresses, and cookies

As you navigate through and interact with ourwebsites, we may automatically collect certain information about your equipment, browsingactions and patterns using common internet technologies, such as cookies and Web beacons.This may include details of your visits to our websites, including information about yourconnectivity, such as your IP address and browser information, location data, logs, and othercommunication data, and the resources that you access and use on the websites. Thisinformation helps us to improve our websites and to deliver better and more personalizedcontent and services by enabling us to estimate our audience size and usage patterns andrecognize you when you return to our websites.

Email marketing.

As a current or previous customer or user of our products or services, you mayperiodically receive emails from us containing details about features of the products you useand/or about similar products or services that we offer. Such processing may include the placingof beacons, or pixels, that let us know if you have opened our email and how long the email wasopen. We do this in order to see which emails are effective and which are not so that we canimprove our content and services. It helps us make sure that you are getting emails from us thatyou find useful and relevant. In doing so, we will never track your location or device information.

General business-related information.

We may also receive other personal information from orabout you in the ordinary course of our business.

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

  • To present our websites, products, and services to you and continuously improve uponthem

  • To provide you with information, products or services that you request from us.

  • To notify you about changes to our website, products or services (including newofferings) and promotions or events.

  • To maintain the integrity and security of our websites, products, and services.

  • For our ordinary business operations, including human resources, recruiting, equityinvestments, and business research and outreach.

Legal basis for the processing

We are not allowed to process personal data if we do not have avalid legal ground. Therefore, we will only process your personal data if:

  • the processing is necessary to perform our contractual obligations towards you or to takepre-contractual steps at your request, such as when we authenticate your log-in to ourservices or ensure that you only have access to the services and data we have agreedto provide you with;
  • the processing is necessary to comply with our legal or regulatory obligations, such astax reporting or regulatory requirements;
  • the processing is necessary for the legitimate interests of ​Viceroy​, and does not undulyaffect your interests or fundamental rights and freedoms (see below);
  • the processing is necessary for the performance of a task carried out in the publicinterest; or
  • in some cases, and as may be requested from you from time to time, we have obtainedprior consent.

To the extent that we process any special categories of data relating to you, we will do sobecause:

  • the data has been manifestly made public;
  • the processing is necessary for the establishment, exercise or defense of a legal claim;
  • the processing is necessary for reasons of substantial public interest; or
  • you have given your explicit consent to us to process that information (where legallypermissible).

DISCLOSURE OF YOUR INFORMATION

Protecting your personal information is important to us and we neither rent nor sell yourpersonal information to anyone. We may disclose or transfer personal information that wecollect or you provide as described in this Privacy and Security Statement, including:

  • To a buyer or other successor in the event of a merger, acquisition, divestiture,restructuring, reorganization, dissolution or other sale or transfer of some or all of Viceroy​’s assets, in which personal information held by ​Viceroy​ about our websites’users is among the assets transferred.
  • To our subsidiaries, affiliates, agents, contractors, service providers and other thirdparties we use to support our business or collaborate with and who are bound bycontractual obligations to keep personal information confidential and use it only for thepurposes of providing services for or with us.
  • To comply with any court order, law or legal process, including to respond to anygovernment or regulatory request.
  • To enforce or apply our Terms of Use and other agreements that govern the sale or useof our products and services.
  • To protect the rights, property or security of ​Viceroy​, our employees, our users or others

ONWARD TRANSFER OF YOUR INFORMATION

To facilitate our global operations, and in accordance with applicable laws, we may transfer yourpersonal information to, and access your personal information from, our corporate offices,subsidiaries, and affiliates in the various countries in which we operate, including the UnitedStates. Non-EEA countries may not offer the same level of personal data protection as EEAcountries.

If your personal data is transferred outside the EEA, we will put in place suitable safeguards toensure that such transfer is carried out in compliance with applicable data protection rules. Toensure this level of protection for your personal information, we may use a data transferagreement with the third-party recipient based on standard contractual clauses approved by theEuropean Commission or ensure that the transfer is to a jurisdiction that is the subject of anadequacy decision by the European Commission or to the US under the EU-US Privacy Shieldframework. You may request additional information in this respect and obtain a copy of therelevant safeguard by exercising your rights as set out below. Where ​Viceroy​ transfers personaldata to other group companies, we rely on the standard contractual clauses.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. Here are a couple of ways you can have control over your information:

  • Tracking Technologies and Advertising. Depending on your browser, you may be able tochange settings to refuse all or some browser cookies, or to alert you when cookies arebeing sent. If you disable or refuse cookies, please note that some parts of the site maythen be inaccessible or not function properly. In relation to email, you can disable mostemail tracking technology by preventing the loading of embedded pictures in the email.You can do this using your email software settings
  • Promotional Offers from the Company. If you do not wish to receive promotional e-mailmessages from us, you can opt-out by sending us an e-mail at ​privacy@viceroy.tech asking to be omitted from future e-mail distributions.

DATA INTEGRITY AND PROPORTIONALITY

We only collect and retain as much personal information as needed for specific, identifiedpurposes described in this Privacy and Security Policy and we will not use it in any way that isincompatible with those purposes.

WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

You may have a right to access and to obtain a copy of your personal data as processed by Viceroy​. If you believe that any information we hold about you is incorrect or incomplete, youmay also request the correction of your personal data.

You may also have the right to:

  • object to the processing of your personal data;
  • request the erasure of your personal data;
  • request restriction on the processing of your personal data; and/or
  • withdraw your consent where ​Viceroy​ obtained your consent to process personal data(without this withdrawal affecting the lawfulness of any processing that took place prior tothe withdrawal).

We will honor such requests, withdrawal or objection as required under applicable dataprotection rules but these rights are not absolute: they do not always apply and exemptions maybe engaged. We will usually, in response to a request, ask you to verify your identity and/orprovide information that helps us to better understand your request. If we do not comply withyour request, we will explain why.

EXERCISING YOUR RIGHTS

To exercise the above rights, you may send an email to ​data-subject-request@viceroy.tech. Ifyou are not satisfied with how we process your personal data, please let us know and we willinvestigate your concern. Please raise any concerns by contacting our Data Protection Team at privacy@viceroy.tech​.

If you are not satisfied with our response, you have the right to make a complaint to the dataprotection authority in the jurisdiction where you live or work, or in the place where you think anissue in relation to your data has arisen. The contact details of each Data Protection Authoritycan be found at the following website:

http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.html

SECURITY

We take your security seriously and take reasonable steps to protect and secure your personalinformation from unauthorized access, use, and disclosure. We have implemented adequatetechnical and organizational measures to protect personal data against unauthorized, accidentalor unlawful destruction, loss, alteration, misuse, disclosure, or access and against all otherunlawful forms of processing. These security measures have been implemented taking intoaccount the state of the art of the technology, their cost of implementation, the risks presentedby the processing and the nature of the personal data, with particular care for sensitive data.

The safety and security of your information also depend on you. Where we have given you (orwhere you have chosen) a password for access to certain parts of our websites, products, orservices, you are responsible for keeping this password confidential. Please do not share yourpassword with anyone.

Although we take reasonable security measures to protect your personal information, forexample, by using Secure Socket Layer encryption when you transmit your password, wecannot guarantee the security of your personal information transmitted to our websites. Thetransmission of information via the internet is not 100% secure and we cannot ensure or warrantthe security of any information you transmit to us. We are not responsible for circumvention ofany privacy settings or security measures contained on the websites.

HOW LONG DO WE STORE YOUR DATA?

We will only retain personal data for as long as necessary to fulfill the purpose for which it wascollected or to comply with legal, regulatory or internal policy requirements.

CHANGES TO OUR PRIVACY AND SECURITY STATEMENT

We may amend this Privacy and Security Statement from time to time. We encourage you torevisit this page periodically to read the current version of this Statement in effect. If you haveany concerns or questions about this Statement or if you would like to lodge a complaint, pleasecontact ​privacy@viceroy.tech

CHILDREN UNDER THE AGE OF 13

Our websites are not intended for children under 13 years of age. If you become aware thatyour child has provided us with personal information without your consent, please contact us at privacy@viceroy.tech​ and we will work to delete it. We do not knowingly collect personalinformation from children under 13.

DATA PROTECTION TEAM

To communicate with our Data Protection Team, please email ​privacy@viceroy.tech

CONTACT INFORMATION

If you have any questions or comments about this Privacy and Security Statement, pleasecontact us by emailing us at ​privacy@viceroy.tech.

or by writing to us at:

Viceroy Technologies Inc.
Attention: General Counsel
1340 Reynolds Avenue #116-1003
Irvine, CA 92614

COPYRIGHT

Copyright © 2018–2019 Viceroy Technologies, Inc. All rights reserved.