The following Privacy Policy outlines how your personal information is collected, used, disclosed and otherwise processed by EDSOMA, Inc. (“EDSOMA,” “we,” “our,” or “us”) when you visit https://EDSOMA, our mobile apps, or any other site or application where this Privacy Policy is posted (collectively, the “Services”). EDSOMA is located at Edsoma Inc., 2021 Eagles Ridge Dr, Brock, TX 75087, USA, and is responsible for the content of the site as well as the collection and management of user information. By accessing or using our Services, 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.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

  • If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.
  • Nevada residents may opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. We do not sell personal information as defined by Chapter 603A of the Nevada Revised Statutes.

Personal Information Collection and Use

We collect personal information you provide through our Services or give to us in any other way, including over the phone or on paper. In connection with these activities, we collect the following:

  • Contact and other information. We receive personal information, including but not limited to, email address, and telephone number, when you communicate with us through the Services through the “Contact Us” page, enter a contest, sweepstakes or other promotion, apply for a job, or otherwise communicate with us. We may also collect any communications between you and EDSOMA and any other information you provide to EDSOMA. We use personal information collected through our Services for the purposes described in this Policy

or as otherwise disclosed to you on or in connection with our Services. For example, we will use your contact information to communicate with you directly about the Services and answer your questions, issues or concerns you or other users have; send you marketing communications, including news about products and services offered by us and our selected partners; or respond to employment opportunities for which you’ve applied.

  • Social Network Information. When you interact with us through a social media site or third-party service, such as when you like, follow, share or connect to EDSOMA content on Facebook, Twitter, Pinterest, Instagram or other sites, we may receive information from the social network including your profile information and any other information you permit the social network to share with third-parties. We use this information to communicate or interact with you on the social network, to better understand the demographics of our visitors and to personalize content and advertising. The data we receive from these third-party sites is dependent upon that third-party’s policies and your privacy settings on that third-party site. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Services.
  • Information Collected Through Tracking Technologies. When you use the Services, we collect information about such use, including the browser or device you use to access the Services, read our emails or engage with us. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, embedded scripts, and similar technology (collectively, “tracking technologies”), and we may utilize third-party services to assist us with this effort. For example, we collect:
    • Information about your browser or device, 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 also collect information about your geographical location data at the city level or may approximate your location by analyzing other information like an IP address.
    • Information about how you access and use the Services, such as 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 Services, and other actions you take on the Services.

We collect and use this information for internal purposes to: (a) provide access to features on our sites and applications; (b) provide customized content and information; (d) provide and monitor the effectiveness of our Services; (e) perform analytics and detect anonymous usage patterns on our Services for use by EDSOMA; (f) diagnose or fix technology problems; (g) detect or prevent fraud or other harmful activities, (h) otherwise to plan for and improve our Services; and (i) to otherwise support the operations of the Services.

Analytics. We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Services and to understand more about our users by monitoring aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

Your choices to control tracking technologies. 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 not accepting cookies may negatively impact your experience using the Services, as some features and services on our Services may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies and these browser settings that block cookies may have no effect on such techniques. 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.

Sharing of Personal Information

We share personal information in the following ways:

  • Service Providers.We share personal information with third-party vendors, consultants and other service providers who perform functions or services on our behalf and under our instructions to support our Services’ operations. For example, we may share personal information with service providers for auditing, compliance, corporate governance functions, identifying and serving contextual advertisements, mailing services, contest and sweepstakes fulfilment, and web hosting.
  • Promotional Partners.From time to time, we may share personal information with third-parties with whom we partner to provide contests and sweepstakes or other promotions. If these promotional partners will use your personal information in a manner which differs from this Privacy Policy, we will identify the Partner and relevant data practices in the Official Rules of the contest or sweepstakes.
  • Law Enforcement, Regulators and Other Parties for Legal

Reasons. We may share personal information:

  • in connection with the establishment, exercise, or defense of legal claims;
  • to comply with laws or to respond to lawful requests and legal process;
  • to protect the rights and property of us, our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
  • to detect, suppress, or prevent fraud;
  • to reduce credit risk and collect debts owed to us;
  • to protect the health and safety of us, our customers, or any person; or
  • as otherwise required by applicable law.
  • Business Transaction or Reorganization. We may share personal information as part of a corporate business transaction, such as in connection with or during negotiation of any merger, sale of company assets, financing, or acquisition of all or a portion of our business. We may transfer personal information to a third-party as one of the business assets in such a transaction. We may also disclose personal information in the event of insolvency, bankruptcy, or receivership. You will be notified via email and/or a prominent notice on any affected Service of any change in ownership, as well as any choices you may have regarding Personal Information about you as a result of the transaction.
  • Third-parties with Your Consent. We may share personal

information about you with other third-parties, as disclosed with you when we collect your personal information, and with your consent.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

Control Over Your Information

Email Communications Preferences. From time to time, we may send you marketing emails including information about products/services we offer. If you wish to unsubscribe from marketing emails, simply follow the instructions in any such email you receive. Note that you may not opt out of service-related communications and other transactions (e.g., account verification, changes/updates to features of the Services, technical and security notices).

Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our website or publicly displayed content, you can contact us directly at support@edsoma.com. We may not be able to modify or delete your information in all circumstances, unless required by applicable law.

Children’s Privacy

This Privacy Policy and our Services are designed to comply with COPPA. The Children’s Online Privacy Protection Act (COPPA) gives parents control over what information websites can collect from their kids. The COPPA Rule puts additional protections in place and streamlines other procedures that companies covered by the rule need to follow. Our Service is intended for users of all ages and their families and we take special precautions to protect the privacy of our users, regardless of age.

Much of our Services collect only limited amounts of personal information, if any. Below, we describe the instances in which we could potentially collect information from children under 13:

  • Support for the internal operations of our Service. We may collect a persistent identifier and other device and usage information when a user visits our website or uses the Service, such as an IP address or a partial IP address, location (at the city level), browser or device type, and a unique identifier which allows us to uniquely identify the browser, device, account, or application, as well as account usage information such as the day/time stamp, referring/exit pages and URLs, pages viewed and similar information. We use this information for our internal purposes, in order to provide access to features, secure the Service, customize content and improve our sites and applications, generate reporting on website usage and other analytics, and to otherwise support our Service.
  • Email contact and support services. If we receive an email or customer support inquiry from a child under 13, we may use the information in order to respond one time to the request and maintain such information only as long as necessary to address the communication. We do not direct promotional email communications to anyone we know to be under the age of 13.

We may share or disclose personal information in a limited number of instances, including:

  • We share information with our trusted vendors, third-party service providers and individuals to provide services for us on our behalf, which may include analytics providers and hosting services.
  • We may also share personal information if we have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; (c) detect, prevent or otherwise address fraud, security or technical issues; (d) protect the rights, property, or personal safety of EDSOMA, its users, or the public; or (e) as required or permitted by law.
  • We may also share aggregate or de-identified information in a manner that cannot be reasonably used to identify an individual user.

Advertising. We do not permit third-parties to collect information from our website visitors over time for the purpose of serving targeted advertisements on our Services or on other websites and services. We use Google Analytics to help us measure traffic and usage trends for the Services and we have taken steps to minimize this tracking activity, to the extent we have control over a third-party’s practices. For example, we utilize Google’s “child-directed treatment” tag to alert Google that our Service may be directed to an audience that includes children and have enabled Google’s “restricted-data processing” by default. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete that information or immediately seek parental consent. If you believe that we might have any information from a child under 13 in a manner inconsistent with COPPA, please contact us at support@edsoma.com.

Links to Third-party Websites and Services

Our Services may contain links to other sites. When you leave our site and go to another site, you are leaving the EDSOMA environment, and those sites may have their own privacy policies, or no privacy policies at all. EDSOMA is not responsible for the privacy practices employed by other sites and those other sites have not agreed to our Privacy Policy. We do not sponsor, endorse, or otherwise recommend such sites or any products or services they may offer. In short, once you leave our Site, we are no longer responsible for the collection practices of the companies operating those sites. We strongly recommend that you read their privacy policies and terms of use to understand how they collect, use, and share personal information.

We do not share the personal information of users with third-parties, including persistent identifiers such as device id or IP addresses, except as follows:

With third-party vendors, consultants and other service providers who are working on our behalf and need access to a user’s personal information to provide the services. These companies are prohibited from using your personal information for purposes other than those requested by us or required by law.

EDSOMA does not, nor does it allow third-parties to, collect personal data (including persistent identifiers) for behavioral advertising, amassing a profile, or any purpose other than to support its internal operations.

Data Retention

We will retain your personal information only for as long as reasonably necessary to maintain the Services, fulfill contractual obligations, meet legal and accounting obligations, and for the purposes described in this Privacy Policy. We may anonymize and/or aggregate personal information and store it in order to analyze aggregate metrics and trends.

Security of Personal Information

We take reasonable and appropriate security measures to protect unauthorized access, alteration or destruction of all data located on and collected by our site. However, no security system is impenetrable, and no data transmission over the Internet can be guaranteed to be 100% secure. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Policy Changes

We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the “Last Updated” date at the end of this Privacy Policy. If we make material changes that results in personal information being used in a materially different manner than was disclosed when the information was collected, we will notify you in any of the following methods: (1) by email to your registered email address, (2) by prominently posting the notice on our Services, or (3) through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

How to Contact Us

Please contact us at the mailing address, email, or phone number below with questions about our privacy policies and collection and use practices:

EDSOMA, Inc.

Contact: info@edsoma.com

Email: support@edsoma.com

California Privacy Notice

This California Privacy Notice (the “CA Disclosures”) supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California (“consumers” or “you“).

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Policy or as otherwise defined the CCPA. California law requires us to disclose certain information regarding the categories of personal information we collect and the rights you may have in connection with such information. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”), and does not include information that is (i) publicly available, (ii) deidentified or aggregated such that it is not capable of being associated with you, or (iii) that is excluded from the CCPA’s scope, such as personal information covered by certain sector-specific privacy laws, such as the HIPAA, the FCRA, GLBA or the Driver’s Privacy Protection Act of 1994. These CA Disclosures also do not apply to information relating to our employees, contractors, and other personnel.

Collection and use of personal information

We collect personal information from and about you for a variety of purposes. For example, we use personal information to fulfill your requests, process your transactions and provide our Services to you; to communicate with you; for marketing and advertising purposes; to monitor, improve, and develop our products and services; and to protect the security and integrity of our business, comply with legal requirements and obligations; for our business and operational purposes; and as otherwise permitted or required by law.

To learn more about the types of personal information we collect and the purposes for which we collect this information, please refer to the Personal Information Collection and Use section of the Privacy Policy.

The personal information we collect may depend on the manner in which you use our Service.

In the last 12 months, we may have collected the following categories of personal information:

DISCLOSURE of personal information

We share personal information with third-parties for business purposes. The categories of third-parties to whom we disclose your personal information for a business purpose include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) promotional partners, if you participate in a promotion; (vi) analytics providers; (vii) social networks. To learn more about how we disclose data to third-parties, please refer to the Sharing of Personal Information section of our Privacy Policy.

In the previous 12 months, we have disclosed the following categories of personal information to third-parties for a business purpose: All of the categories of personal information we collect, explained in the table above.

In the last 12 months, we have not sold personal information about you.

YOUR RIGHTS AND CHOICES

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

  • The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
    • The specific pieces of personal information we have collected about you;
    • The categories of personal information we have collected about you;
  • The categories of sources of the personal information;
  • The categories of personal information that we have disclosed to third-parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold and the categories of third-parties to whom the information was sold; and
  • The business or commercial purposes for collecting or selling the personal information.
  • The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
  • The Right to Opt Out of Personal Information Sales to third-parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

HOW TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS

You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account, if you have one. In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To exercise your California Consumer Rights, please submit a request by:

Please note: we do not sell personal information.

Authorized Agents. If you are submitting a California Consumer Rights request on behalf of another individual or your minor child, we may require additional documentation to verify that you are properly authorized to request this information and it may take additional time to fulfil your request.

Minors. We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

California’s “Shine the Light” Law. California’s “Shine the Light” law (Civil Code

Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third-parties for their direct marketing purposes. In the past 12 months, we have not sold personal information to third-parties for their direct marketing purposes, as defined by the Shine the Light law.

Do Not Track Signals. 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 or mobile application at this time.

Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the “Last Updated” date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you by email to your registered email address, by prominent posting on our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us: support@edsoma.com

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to support@edsoma.com .