## PRACTION PRIVACY POLICY

**Last updated: April 2023**

Praction LLC (“Praction”, “we”, “our”, or “us”) understands that privacy is important to our users. This Privacy Policy describes our practices regarding the collection, use, sharing, and protection of your personal information for the website located at Praction.co (the “Website”), and our other services, including our revenue modeling, diagnostic reporting, consulting, and recruitment tools (the “Services”) (collectively, the “Properties”). This Privacy Policy also tells you about the rights and choices you have with respect to your personal information, how you can assert those rights, and how you can contact us to get answers to your questions.

For more information about how users with disabilities can access this Privacy Policy in an alternative format, please contact us by emailing privacy@praction.co or calling (646) 389-1514.

BY USING OR ACCESSING THE PROPERTIES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE PROPERTIES OR PROVIDE US WITH ANY PERSONAL INFORMATION.

**WHAT OUR PRIVACY POLICY COVERS**

This privacy policy applies to the personal information that we obtain in various contexts, including through the Website, when you access or use the Properties, or when you communicate with us over email or text message, or otherwise via the Properties.

We may provide different or additional privacy notices in connection with certain activities, programs, and offerings. Additionally, we may provide additional “just-in-time” notices or notices at collection that may supplement or clarify our privacy practices or provide you with additional choices regarding your personal information.

**PERSONAL INFORMATION WE COLLECT FROM YOU**

We use the term “personal information” – also called “personal data” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. The following are the categories and types of personal information that we may collect from or about you, depending on how you interact with the Properties:

- Identifiers, such as your name and email address;
- Employment information, such as your company and title;
- Device and online identifiers and related information;
- Internet or other electronic network activity information;
- Any other personal information that you voluntarily provide us.

**HOW WE COLLECT YOUR PERSONAL INFORMATION**

**Personal Information You Provide**

We collect personal information that you provide to us directly. This may include:

- Information you provide when you contact us via email,
- Information you provide when you create a profile or account or subscribe to one of our Services;
- Information you provide when you participate in our sales associate training course;
- Content that you post to the Properties;
- Your responses to surveys that you choose to complete for us;
- Details relating to transactions that you carry out through our Properties;
- Your search queries on the Properties;
- Any other information that you provide us on or through the Properties.

**Personal Information We Collect Automatically**

When you visit our Properties, we or third parties we work with may automatically collect certain information using technologies such as cookies and other tracking technologies.

- **Cookies and Similar Technology:** "Cookies" are pieces of information that may be placed on your computer by a website for collecting data to enhance your communication and interaction with that website.
- **Analytics:** We may work with third-party vendors who use the technologies described in this section for website analytics to understand how visitors use our Properties.

**HOW WE USE YOUR PERSONAL INFORMATION**

We collect and use personal information for the following purposes:

- To communicate with you;
- To provide our products and services;
- For analytics and personalization;
- For security and fraud prevention;
- To comply with legal obligations;
- To support core business functions.

**HOW WE DISCLOSE OR SHARE YOUR INFORMATION**

We may disclose your personal information to other affiliates and entities in the following instances:

- **Service Providers.** We may share your personal information with third-party service providers.
- **Our Customers.** If you have successfully completed our sales employee training course, we may share your personal information with our customers.
- **Business Transfers.** We may share your personal information in connection with a merger or sale of assets.

**LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES**

We may create links to other websites that may be of interest to you. We do not endorse any other websites, providers, or services by providing such links, and this Privacy Policy applies only to our Properties. We are not responsible for the privacy policies of any websites and services we link to.

**HOW WE PROTECT YOUR PERSONAL INFORMATION**

Personal information is maintained on our servers or those of our vendors, accessible by authorized personnel as necessary for purposes described in this privacy policy. We use reasonable safeguards designed to promote the security of our systems. However, no method of safeguarding information is completely secure.

**DATA RETENTION**

We will retain your personal information for as long as your inquiry is active or as needed to provide you with the Properties.

**YOUR CHOICES**

You may exercise the choices described in this section regarding your personal information.

- **Opting Out of Messages:** You may unsubscribe from future messages in accordance with our standard unsubscribe process.
- **Cookies and Tracking Technologies:** Please refer to and adjust your web browser preferences to restrict cookies.

**CROSS-BORDER DATA TRANSFERS**

If you submit personal information to us, that information may be processed in a jurisdiction where privacy laws may be less stringent.

**EUROPEAN PRIVACY RIGHTS**  
IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

**Legal Basis**
We will only use your personal data when the law allows us to.

**Data Controller**
Praction is the data controller of all personal data collected through our Properties.

**Withdrawing your consent**
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time.

**Data Transfer**
We may transfer personal data from the EEA, Switzerland, and the UK to the USA and other countries, some of which may not provide adequate protection.

**Use of your personal data for marketing purposes**
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

**Data Subject Rights**
If you are in the EU, Switzerland, or the UK, you have the right to:

- Request access to your personal data;
- Request correction of your personal data;
- Request erasure of your personal data;
- Object to processing of your personal data;
- Request restriction of processing;
- Request the transfer of your personal data;
- Withdraw consent at any time.

**CHILDREN'S PRIVACY**
Our Properties are intended for users ages 18 and over, and we do not knowingly collect personal information from children under the age of 16.

**CHANGES TO THIS POLICY**
We reserve the right to update this Privacy Policy at any time and will notify you of any material changes.

**CONTACTING US**
If you have any questions about our privacy or security practices, you can contact us at [privacy@praction.co](http://privacy@praction.co/).