Privacy Information

Introduction

This privacy policy explains who we are, how we collect, share and use your Personal Information (or “Personal Data”), and how you can exercise your privacy rights.

We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, you can be assured that it will only be used in accordance with this Privacy Policy.

We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

If you do not agree with the content of this Policy, then please remember it is your choice whether you want to use our Services. Your continued use of the resources made available on our Services following the posting of any changes to
this policy constitutes acceptance of those changes.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contacts provided below.

Data Controller

The data controller is Readibots Corp with registered office in Ottawa, Canada.

The requests relating to the exercise of the rights provided by the 2016/679 General Data Protection Regulation (“GDPR” or “Regulation”) can be sent, in writing also by e-mail message, to info@readibots.com

Contact Data Of The Data Protection Officer

The Company has appointed a “data protection officer” (so-called “Data Protection Officer” or “DPO”) provided for by the Regulation, who can be contacted at the following e-mail address: info@readibots.com

What Type Of Data We Collect

Personal Data processed by us has been voluntarily provided by you or may also be acquired by us in the exercise of our business or form third parties.

You are responsible for any personal and /or third party’s information that you share with us and warrant that you have the right to disclose it, discharging us of any liability towards third parties.

The data processed by us, either on its own or through third parties, could be:

• First and last name, the data relating to your education and job; company name, the Personal Data of the legal representative / attorney; address and other elements of personal identification (date of birth, place of birth);
  demographic information such as postcode; fiscal code; contact information including email, phone number. If you purchase our Services, billing and communications information (your credit card details and billing address,
  identification details of banking relationships as IBAN), preferences and business interests.
• Personal Data we process on your behalf: If you purchase our Services, you need to provide us information about Services’ users, such as their names and email addresses, their devices and usage of the Services. We use and process
  these information to provide the Services in accordance with your instructions.
• Personal Data we collect from other sources: We may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps
  to ensure that such third parties are legally or contractually permitted to disclose such information to us. Examples of the information we receive from other sources include demographic information, device information, location
  (such as city and state), and online behavioural data.

We do not collect, access or scan any of your organisation’s content including, but not limited to:

• Email messages
• Calendar entries
• Contact lists or Address books
• SharePoint Documents or content

We do not process neither any “particular” Personal Data, such as, for example, the Personal Data suitable to reveal the state of health, political opinions, religious beliefs, etc…

What We Do With Personal Data We Gather

We use your Personal Data for a variety of purposes including:

• Management of relations with you deriving from the signed contract;
• Compliance with legal obligations;
• Improve our activity and our Services (eg. Detection of the degree of customer satisfaction on the quality of services rendered and on the activity carried out by us, the preparation of studies and market research);
• Inform you with marketing communications about our products and / or services that we think you may be interested in (subject to your specific, express consent).

The provision by you of Personal Data necessary for the purposes referred to in point a.) is not mandatory, but the refusal to supply them may make it impossible for us to provide the Services. Their processing does not require your
consent.

The provision of Personal Data necessary for the purposes referred to in point b) is mandatory and the relative processing does not require your consent.

The provision of Personal Data necessary for the purposes referred to in point c) is not mandatory and the relative processing requires your consent.

The provision of data necessary for the purposes referred to in the letter d) is not mandatory and their processing requires your consent, freely expressible and modifiable at any time as better described below (“Your rights”).

Legal Basis For Processing

We process Personal Information about you as a data controller as described in this section, where such processing has a legal basis or is in our legitimate interests and not overridden by your data protection interests or fundamental
rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; and ensuring the security of the Services.

Additional Data Processing Purposes

If additional data processing purposes are added to the above we will let you know prior to process whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the
consequences, if any, of not providing the information.

Processing Arrangements

Your Personal Data could be processed by a third party acting as separate controller or, if necessary, as Data processor, on our behalf, in a predominantly automated and computerized manner, in order to guarantee security and
confidentiality and to prevent unauthorized access to the data themselves. We do not perform automated decision-making, including profiling.

We may need to communicate your Personal Data to third parties belonging to the following categories:

• People involved in technical and organizational activity on our behalf (including payroll activity)
• Subsidiaries, parent companies and affiliates of Readibots Corp;
• Business/marketing partner;
• Authorities and in general, subjects, public or private, with functions of public importance;
• External companies and / or professionals that assist us;
• Third-party companies for processing aimed for promotional initiatives, if you have expressed your consent.

Your Personal Data could be processed also by our personnel, acting as authorized or System administrator, according to their role in our company.

We will not sell, distribute or lease your Personal Information to third parties unless we have your permission or are required by law to do so. Your Personal Data will not be disseminated.

Your Rights

The European Economic Area (EEA) provides certain rights to data subjects (including access, rectification, erasure, restriction of processing, data portability, and the right to object and to complain). We undertake to provide you the
same rights no matter where you choose to live.

As available and except as limited under applicable law, the rights afforded to individuals are:

1. Right of Access (the right to be informed of and request access to the Personal Data we process about you);
2. Right to Rectification (the right to request that we amend or update your Personal Data where it is inaccurate or incomplete);
3. Right to Erasure (the right to request that we delete your Personal Data);
4. Right to Restrict (the right to request that we temporarily or permanently stop processing all or some of your Personal Data);
5. Right to Data Portability (the right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service);
6. Right to Object (the right, at any time, to object to us processing your Personal Data on grounds relating to your particular situation);
7. Right to object to your Personal Data being processed for direct marketing purposes;
8. Right not to be subject to Automated Decision-making (the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a
   similarly significant effect);
9. the right to lodge a complaint with the Guarantor in the event of a breach in the processing of data pursuant to art. 77 of Regulation 2016/679;
10. the right to appeal to the courts in the event of unlawful processing of the data, even against the acts undertaken by the Guarantor pursuant to art. 78 of Regulation 2016/679.

If you have previously opted in to our marketing emails, you can opt out at any time by clicking the “unsubscribe” link at the bottom of our marketing messages.

If you decide to withdraw your consent, we may continue to send you non-promotional communications, unless you decide to unsubscribe from the contact list. Please note that some communications (such as service messages, account
notifications, billing information) are considered transactional and necessary for account management, and you cannot opt out of these messages unless you cancel your account.

If you have any questions or concerns about your rights regarding the use of your Personal Information, please contact us at: info@cloudbridgeplatform.com . We will reply as soon as possible after verifying your identity.

Retention Of Data

Your Personal Data will be stored for a period of time not exceeding that necessary to achieve the purposes for which it was collected and in any case for the maximum time required by applicable law (for example, a ten-year prescription
for civil and administrative / accounting data).

Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:

• Whether we have a legal or contractual need to retain the data.
• Whether the data is necessary to provide our Services.
• Whether our Customers have the ability to access and delete the data within their accounts.
• Whether our Customers would reasonably expect that we would retain the data until they remove it or until their accounts are closed or terminated.

When we have no ongoing legitimate need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely
store your Personal Data and isolate it from any further processing until deletion is possible.

Regarding the processing for marketing purposes, your data will be processed and stored for a reasonable period of time in relation to the interest you have shown towards our initiatives, which we will periodically check, except for
your opposition or request for revocation of the authorization to receive commercial communications.

Our Security

We take appropriate and reasonable technical and organizational measures to protect your Personal Data from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the
processing and the nature of the Personal Data.

Disclaimer

Our Services are intended for use by our Customers. As a result, for much of the Personal Information we collect and process about Users through the Services, we act as a processor on behalf of our Customers. We are not responsible for
the privacy or security practices of our Customers, which may differ from those set forth in this privacy policy.