Launched - 2019

All Rights Reserved

Global Privacy Policy

Effective Date: 07/21/2019

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Please don’t space out because this Privacy Policy is a very important contract between us. Don’t worry, it’s not rocket science, and if you have any questions, you can contact us.

Aestell, LLC (“Aestell,” “we,” “our,” or “us”) considers your privacy of the greatest importance and are committed to protecting it through our compliance with this policy. Therefore, please read and understand this Privacy Policy as it covers the services that are offered by Aestell, LLC. It also describes the types of Personal Data we collect through our products and services (“Services”), including our main website at https://aestell.com (our “Sites”).

This policy covers what information might be collected about you and how we might use your information, when we might use that information, with whom we share that information, and your rights and choices about the personal information you give to us. By downloading, accessing or using our Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

This policy does not apply to third-party websites, products, or services, including services by other companies linked to our Services or Sites. Those companies have their own privacy and cookies policies and the information that you provide them will be subject to their rules and not ours. Please make sure to check their privacy policy so you are familiar with and understand how they might use your information.

Children under the age of 13

Our Site is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.

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WHAT INFORMATION DO WE COLLECT AND FOR WHAT PURPOSE?

Aestell collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”Personal Data”). We might ask for your name and contact details, financial details or your date of birth, depending on what you’re doing. For example, if you make a purchase for a product or service on Aestell’s website, we may ask for information, including your name and payment details.

Aestell obtains Personal Data about you from several sources to provide and manage our Services and Sites. “You” can be a visitor to https://aestell.com or to one of Aestell’s websites or a user of our Service or Services (“User”). If You visit or use our sites, for example, we may collect Personal Data that You submit on our website or when you contact us by email. When You create an Aestell Account, You provide us with personal information, such as your name and a password. You also might to choose to provide us information, such as an email address to receive updates about our services.

We collect information to provide better services to all our users and assist us in ensuring our platform and services are compliant, safe, and secure. Our operations are critically dependent on the information Aestell collects, and how that information is used. In order for us to effectively manage, prevent, and monitor fraudulent activities, all of which protect our users, our detection services may engage in verification processes, such as the monitoring of patterns or other online signals and insights to reduce to risk of harmful activities for us and our Users.

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Personal Data

When You register for an Aestell account we collect your full name, email address, and account log-in information.

• When You fill-in our support contact forms, we will collect your full name, email, country, and anything else you input regarding the context in which you provide the data.

• When You select the “Remember Me” preference, we collect your email address and log-in credentials. If you select this feature at a checkout procedure, we collect your email address, payment card number, CVC code and expiration date.

• Any response to Aestell emails, surveys, or feedback forms may be collected, such as name, postal address, telephone number, and email address. In certain cases, we may also receive financial and personal information about you, such as your date of birth or any other government identifiers associated with you or your organization (such as your tax number or EIN).

• If you are a Customer, we will receive your transaction information. The information that we collect will include payment method information, purchase amount, purchase date, and method of payment (such as whether you paid with a credit or debit card number). As such, different payment methods may require different categories of information to be collected. We will determine the payment methods to be used, and the payment method information that we collect will depend upon the payment method you choose to use from the list of available payment methods that are offered to you.

• When we conduct fraud prevention and detection operations, we may also receive Personal Data about you from our affiliates, financial service providers, identity verification services, and publicly available sources, in order to confirm Your identity and prevent unauthorized or fraudulent endeavors. Aestell’s fraud monitoring services may rely on technology to help us assess the risk associated with an attempted transaction that is enabled on our platform or the application that collects information.

• We collect information on your activity in using our Services, such as the interaction of Your apps, browsers, and devices with our Services, including IP address, crash reports, system activity, and the time and date, which we use to help us provide features like automatic product updates and to build better features for our servers and Services.

You may also choose to submit information to us through methods that include: (a) responses to marketing or other communications, (b) social media or other online forums, (c) offers, programs, or other promotions, (d) actual or potential business relations with us, (e) business card or contact details provided at trade shows or other events.

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HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGY TO COLLECT INFORMATION

Aestell’s platform uses cookies and other technologies to build better services and function effectively. These technologies record information on Your use of our websites including the following.

• Browser and device data

o These include IP address, device type, operating system, Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, extensions, and add-ons.

• Usage data

o These include the time spent on websites, pages visited, links clicked, and the pages that led you to us.

We may also collect information about online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services. For example, we may use Google Analytics on our websites to help us analyze Your use of our platform and Services and to diagnose any technical issues or disruptions.

We, and our third-party partners, automatically collect certain types of usage information when You visit our Service, read our emails, or otherwise engage with us.

We typically collect this information through a variety of tracking technologies, including cookies, file information and similar technology (collectively, "tracking technologies"). For example, we collect information about your device and its software, such as Your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify Your browser, mobile device or Your account, and other such information.

• We may collect information about the way You use our Service, for example, the site from which You came and the site to which You are going when you leave our website, the pages you visit, the links You click, how frequently You access the Service, whether You open emails or click the links contained in emails, whether You access the Service from multiple devices, and other actions You take on the Service.

• When You access our Service from a mobile device, we may collect unique identification numbers associated with Your device or our mobile application, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device's location by analyzing other information, like an IP address.

• We may collect analytics data, or use third-party analytics tools including Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser.

We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our service.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. We and our third-party partners may also use cookies and tracking technologies for advertising purposes.

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USING THE INFORMATION THAT WE COLLECT

Aestell may use the information we collect from all our services for the following purposes.

• Provide our services

o We may use your information to deliver our Services, such as the verification of your purchase by name or email address.

• Maintenance and improvements to our services

o We may use your information to ensure our Services and platform are operating as intended. This includes tracking a disruption in service or outage in addition to troubleshooting issues that you report to us. In certain cases, we may use your information to assist us in making improvements to our Services.

• Develop new services and integrating our services

o We may use the information we collect in our existing services to help us in developing new services. For example, if we notice that the majority of our Users use our services during a particular band of hours in a twenty-four-hour day, we may increase the capabilities of our servers and platforms to be able to handle the extra demands of increased use during a particular timeframe.

We may send you email marketing communications about Aestell products and services, invite you to participate in our surveys or events, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. For organizations and entities: When we collect your business contact details through your participation at events, such as trade shows or other such engagements, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.

When you visit our websites or online services, Aestell and certain third parties may collect information about your online activities over time and across different sites to provide you with advertising on products or services that are personalized for your individual interests. These third parties may implement or recognize a unique cookie or other technology on your browser (for example, the use of pixel tags). Where required by applicable law, we will obtain your consent before processing your information for the purpose of internet-based advertising.

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DISCLOSING PERSONAL DATA

Aestell does not sell or rent Personal Data to marketers or unaffiliated third parties. We may, however, share your Personal Data with trusted entities and affiliates, as described below.

• We may share Personal Data with internal entities in order to provide our Services and for internal or administrative purposes.

• We may share Personal Data with certain service providers. We have service providers that provide a variety of services on our behalf, such as identity verification services, webhosting services, data analytical services, information technology services and other such infrastructure services, customer service providers, email delivery services, auditing services, and data processing services. These services providers might access Personal Data to perform their services. We may authorize such service providers to use or disclose the Personal Data only as necessary to perform their services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf.

• We may share Personal Data with third party business partners when it is necessary to provide our Services to our Users. Examples of third parties to whom we may disclose Personal Data include financial institutions and payment method providers (such as credit card networks) and other payment processing service providers (such as PayPal or Stripe).

• We may share Personal Data with Users as necessary to maintain a User account and provide the Services. We share information with parties directly authorized by the User to receive Personal Data, such as when a User authorizes a third-party service provider to access their Aestell account. The use of Personal Data by an authorized third party is subject to the third party’s privacy policy.

• In the event that we enter into, or have an intent to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.

• We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Stripe, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

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USER RIGHTS AND CONTROL

Your choices regarding Aestell’s use and disclosure of Personal Data:

• If you no longer wish to receive marketing-related emails from us, you may opt-out by clicking the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as practicable. If you opt-out of receiving our marketing-related emails, you may still receive important administrative messages from us that are required to provide you with our Services.

• If you would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to your Aestell account or by contacting us.

• According to your location and subject to applicable law, you may have certain rights regarding the Personal Data we control about you:

o Right to request confirmation of whether Aestell processes Personal Data relating to you, and if so, to request a copy of that Personal Data;

o Right to request that Aestell rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;

o Right to request that Aestell erase your Personal Data in certain circumstances provided by law;

o Right to request that Aestell restrict the use of your Personal Data in certain circumstances, such as while Aestell considers another request that you have submitted (including a request that Aestell make an update to your Personal Data); and

o Right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.

In cases that the processing of your Personal Data is according to your previously given consent, you have the right to withdraw your consent at any time.

You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.

• You may contact Aestell if you would like to exercise your data protection rights. Our contact information is provided in the Contact Us section below. Aestell treats each request equitably and will comply with your request to the extent required by applicable law. Aestell will not be able to respond to requests if we no longer hold your Personal Data. You may, of course, consult with the data protection authority in your country if you feel that you have not received an adequate, reasonable, and satisfactory response from us.

For protection purposes, we may need to verify your identity before responding to your request. For instance, we may need to verify that the email address from which you send the request reconciles or matches your email address that Aestell has on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for purposes of responding to your request.

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SECURITY AND DATA PROTECTION

Aestell exercises reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against fraudulent or unauthorized access, destruction, loss, alteration or misuse. Within Aestell, Personal Data is only accessible to a limited number of personnel who require access to the information in order to perform their duties. In any event, however, no data transmission or storage system can be guaranteed to be 100% secure. If you have any reason to believe that your interaction with us is no longer secure — for example, if for any reason you feel that the security of your account has been compromised — please contact us immediately.

If you are an Aestell User, we retain your Personal Data as long as we provide the Services to you. We retain Personal Data after we cease providing Services to you, even if you close your Aestell account, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. In cases that we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

• Data storage and transfer

o Your information collected through our website may be stored and processed in the United States or any other country in which Aestell or its affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which the Aspen or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

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USE BY MINORS AND CHILDREN’S PRIVACY

The Services are not directed to individuals under the age of thirteen (13), and we respectfully request that they not provide Personal Data through the Services.

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PRIVACY POLICY UPDATES AND NOTIFICATIONS

We sometimes change this Privacy Policy. For example, we may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. Any changes are effective when we post the revised Privacy Policy on the Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through your Aestell “Admin Console,” email address and/or the physical address listed in your Aestell account.

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LINKS TO OTHER WEB SITES AND SERVICES

The Services may provide an ability to connect to other websites. These websites may operate and offer services independently from us and may have their own privacy notices or policies, which we urge you to review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.

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JURISDICTION-SPECIFIC PROVISIONS

For purposes of applicable law, such as EU data protection laws (“GDPR”), Aestell is a data controller (i.e., Aestell is responsible for, and controls the processing of, your personal data

Residents of the European Economic Area (EEA) and Switzerland.

• The entity responsible for the collection and processing of Personal Data for residents of the EEA and Switzerland is Aestell, LLC., incorporated in Delaware, United States.

California residents.

• If you are a California resident, then, subject to certain limits under California law, you may ask us to provide you with (i) a list of certain categories of Personal Data we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year; and (ii) the identity of those third parties. To make this request, California residents may contact us as specified in the Contact Us section below.

Australian residents.

• If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Privacy Policy, you may wish to contact the Office of the Australian Information Commissioner.

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CONTACT US

If You have any questions or complaints about this Privacy Policy, please contact us electronically. You can email us at [email protected]