Tooly takes your privacy seriously and is sensitive to potential concerns about how we use the personal information we collect from and about you. In addition to this Privacy Policy, we have internal policies and practices designed to keep your personal information secure and to ensure that information about you is only used consistent with this Privacy Policy. We actively apply principles of privacy by design and have a privacy team that is committed to helping to ensure that your personal information is safe and is handled properly.

This Privacy Policy describes how we collect, use, process, and disclose personal information of consumers. This Privacy Policy applies to Tooly.com, Inc. as well as Tooly's subsidiaries and affiliates,

The scope of this Privacy Policy covers both your use of the Tooly.com website and any other ways in which you may interact with Tooly, such as when you speak to us on the phone. It also describes the choices available to you regarding our use of your personal

information. Information for California residents and individuals located in the European Union are also included within this policy.

This Privacy Policy is incorporated into our Terms of Use and Terms of Service, and therefore governs your use of Tooly's website or services. By using Tooly's website and or services, you accept the terms of this Privacy Policy. If you have questions or concerns about the Privacy Policy, or would like to exercise any of your rights around how data about you is used, you can let us know using the form located here. Alternatively, you may contact Support at [email protected] or (888) 737-1337 . If you are a consumer with a disability and are having trouble accessing this Privacy Policy, you may request to receive this Privacy Policy by emailing[email protected] or by calling (888) 737-1337 .

Please Note: This Privacy Policy does not cover information that you may provide in connection with your use of Tooly's Identity Protection or Business Data Protection services. Instead, the information that you provide in connection with those services is governed by the Experian Privacy Policy, as described at the time of activation.

Information We Collect About Consumers.

In this section of the Privacy Policy, we explain what types of Personal Information we may collect about consumers. The Personal Information collected depends on the type of interaction we have with a consumer (such as calling, visiting our website, or using one of our mobile apps), the types of products a consumer considers or purchases, and what information Tooly's customers choose to share with us. This section includes all of the information that we may collect about consumers, but we will rarely collect all of these types of information about any single person.


As used in this Privacy Policy, Personal Information means information that relates, and is capable of being linked, to a particular person. It does not include de-identified or aggregate information.

Tooly Inc potentially collects the following categories of information about consumers, some of which may be collected or maintained in a manner such that it can be considered Personal Information:

Identifiers : Examples of the types of identifiers that Tooly Inc may collect include real names, nicknames, postal addresses, online identifiers, Internet Protocol addresses ("IP addresses"), email addresses, account numbers, Social Security numbers, driver's license numbers, passport numbers, and other government identification numbers.

Other types of information : Examples of other types of information include physical characteristics or descriptions of you, telephone number, insurance policy number, education, employment, financial information including bank account, credit card, and debit card numbers, and health insurance information. It also includes additional information provided to Tooly directly by you, such as when you complete a questionnaire, answer a survey, or receive a financial consultation. This category includes information identified as Personal Information in California Civil Code Section 1798.80(e) that is not otherwise categorized.

Characteristics protected under some laws : Examples of the types of characteristics that Tooly Inc may collect include age, national origin, citizenship, marital status, medical information, sex, sexual orientation, and veteran or military status.

Commercial information : Examples of the types of commercial information that Tooly Inc may collect includes records of business and other property owned, products or services purchased, obtained, or considered from Tooly Inc or our partners, and other purchasing or consuming histories or tendencies.

Internet information : Examples of the types of internet or other electronic network activity information that Tooly Inc may collect includes browsing history, search history, information about the device the consumer is using to access our website or applications, and information regarding a consumer's interaction with Tooly's or our partners' websites, applications, or advertisements. We may also collect information from visitors to our website such as browser settings, operating systems, referring/exit pages, and clickstream data. When we send you an email, Tooly may also collect information, including about how you interact with that email.

Geolocation information : Tooly Inc may collect information about where a consumer resides or is otherwise located.

Audio and visual information : Tooly Incmay make audio recordings of calls with

consumers. We may make visual recordings of consumers when they visit our premises or when consumers agree that Tooly may take their photograph or videotape them. We may also collect visual images of consumers when they are provided to us in connection with a product, such as


when they are submitted as part of a trademark order. We might collect thermal or olfactory information.

Professional and employment-related information : Examples of the types of professional and employment-related information Tooly Inc may collect includes information about professional status and affiliations, employment history, and employment status.

We do not collect biometric or education information that is maintained by an educational institution or party acting on an educational institution's behalf. We also do not collect inferences about consumers, although as described below, we may internally create inferences based on the information that we do collect.

Where We Collect Information About Consumers.

In this section of the Privacy Policy, we explain where and how we collect data about consumers. We receive information about consumers from several categories of sources. To learn more about which categories of information we collect from which source, please refer to the chart in the section below entitled Summary of Tooly's Practices Regarding Consumer Information .

Consumers : The vast majority of the information that Tooly Inc collects comes directly or indirectly from the consumer that it relates to. Information that is collected directly from you is information that you provide when you complete a form online, use a chat feature, or speak to us on the phone. We may also collect information indirectly about you when you interact with our website, through the use of cookies and other tracking technologies. Indirect collection is described in more detail in the section below called "How Tooly Inc Uses Cookies and Similar Technologies."

Related Consumers : We may collect information about you from someone you know. For instance, if you are a family member of Tooly client or employee of another affiliate company, we may be given information about you in order to complete the information to employer.

Employers : We may collect information about you from your employer if your employer has elected to provide you with employment benefits through Tooly Inc. For instance, your employer will tell Tooly when you are first eligible to receive services from Tooly as part of your benefits.

Service Providers : We may collect information about you from our Service Providers. As used in this Privacy Policy, Service Providers means entities that Tooly has contracted with to provide us with services to help fulfill our business needs. An example of the type of information that we may receive from a Service Provider is information about whether any Legal Mail has been received as part of our Registered Agent services. Service Providers may also assist us in collecting information both directly and indirectly from you.

Professionals (including Attorneys and other Professionals): We may collect information about you from the independent professionals with whom you may schedule a consult with


through our product offerings. An example of the type of information that we may receive from these professionals includes the fact that a consult has occurred. While we cannot control what information attorneys share with us, Tooly does not intend to collect any information from attorneys where the collection would result in a waiver of the attorney-client privilege.

Business Partners and Affiliates: We may collect information about you from our business partners and affiliates. An example of the type of information that we may receive from business partners and affiliates is information about the product you purchased from them after you indicated an interest in an offer that Tooly Inc presented to you.

Publicly/Commercially Available Information : We may collect information related to you from publicly available sources of information, including government records and commercially available sources of consumer information. Examples of the type of information we may collect from publicly available sources are whether you have recently expressed interest in purchasing a product that Tooly sells.

Unrelated Parties : We may receive information related to you from people and entities with whom Tooly does not have a direct relationship. An example of the type of information that we may receive from unrelated third parties is documents that we receive on your behalf.

How We Use the Information We Collect About Consumers.

In this section of the Privacy Policy, we explain our commercial and business purposes for collecting information about consumers. Tooly uses the information that it has collected about consumers, for the purposes listed below. In some instances, we may combine information that we have collected from multiple sources in order to fulfill these purposes. Tooly potentially uses each category of information that we collect for each of these purposes.

If, in the future, Tooly wishes to use information about you in a manner that is not consistent with the purposes outlined below, we will seek your consent prior to the expanded use if and where we are legally required to do so.

Providing Products and Services : Tooly collects information for the purpose of providing products and services. We may also use information to respond to inquiries from potential customers who are interested in learning more about our products and services. Examples of the types of uses of consumer information for these purposes include: administering the Tooly website, and displaying content based on consumer preferences.

Security : Tooly collects information for the purpose of ensuring that we maintain appropriate security over computer networks and our physical facilities. We may also collect information for the purposes of detecting fraud or other suspicious activities.

Meeting Legal Requirements : Tooly collects information in order to meet our legal obligations. These obligations may include satisfying screening requirements prior to assisting with providing proper documents for employers, background check, education and verification


of employment, maintaining records as required in our role as Registered Agent, or responding to subpoenas for information.

Marketing : Tooly collects information for use in marketing to current and prospective customers. More information about how you can control the marketing you receive from Tooly is located in the sections "How Tooly Uses Cookies and Similar Technologies" and "How You Can Control the Information Tooly May Have About You."

Product Development: Tooly collects information for use in improving our existing products and developing new products.

Analytics: Tooly collects information for use in performing various types of analytics. For example, Tooly uses information to analyze how visitors interact with our website, where visitors to our website arrive from and exit to and gaining insights into the types of consumers that may be interested in our products and services. We may also use information to develop inferences from the information we collect regarding consumer preferences, characteristics, predispositions, behaviors, and attitudes.

Operational Purposes: Tooly collects information for use for our operational purposes, and the operational purposes of our service providers and business partners. For instance, Tooly may use information for maintaining our website and other infrastructure, training and quality assurance, for conducting surveys or sweepstakes, to promote our brand, and to use in connection with our relationships with service providers and business partners.

Sharing with Business Partners : Tooly collects information in order to provide business partners' information in connection with consumers who have either expressed interest in hearing from the business partner or who have purchased a bundled product through Tooly.

Financial Reporting: Tooly collects information for use in various types of financial reporting and other similar internal uses. Examples of the types of financial reporting that Tooly may use consumer information in connection with are internal budgets and projections, calculation of compensation, and reporting to investors.

Business Transfers : If Tooly undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including information related to consumers in connection with the transaction or in contemplation of the transaction (such as conducting due diligence). If such an event occurs, your information may be treated like any other Tooly asset and sold, transferred, or shared with third parties, or used in ways not contemplated or permitted under this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on our site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

In addition to the purposes listed above, Tooly may also use de-identified or aggregate data that is not capable of being linked to any individual consumer for additional purposes not listed above.


How We Share Consumer Information and Who We Share It With.

In this section of the Privacy Policy, we explain who we share consumer information with, and under which circumstances we may do so. To learn more about which categories of information are shared with which third parties, please refer to the chart in the section below entitled Summary of Tooly's Practices Regarding Consumer Information.

Service Providers : Tooly may share information about consumers with Service Providers who assist us with completing the business purposes outlined in the "How We Use the Information We Collect About Consumers" section. These companies are not authorized to use the information we share with them for any other purpose other than providing services to Tooly or to you.

Professionals (including Attorneys and other Professionals): Tooly may share consumer information with the independent professionals that can be accessed through products such as our legal plans and attorney-assisted products.

Business Partners and Affiliates: Tooly may share information with business partners and affiliates in limited circumstances. These include:

· If you express interest in an offer made by a business partner, we may provide information about you in connection with the offer you have selected. If you later decide to opt-out from allowing Tooly to share your information with business partners for their marketing purposes, you may do so by contacting Support at [email protected] or (888) 737-1337. To the extent that Tooly has already shared your information prior to your decision to opt-out, you may opt out from future marketing by contacting our business partners directly.

· When you purchase a product from us that is bundled with a product offered by one of our business partners, we will share information about you with those business partners so that they can provide you with the product or services included with your

purchase. These companies are not authorized to use the information we share with them about you for their own marketing purposes without first asking for your permission.

Employers : Tooly may share information with employers who have elected to provide employment benefits through Tooly. This is done for operational purposes, such as verification of employee emails. Tooly does not share Personal Information that is collected during advice sessions with employers.

Related Consumers : In limited circumstances, we may provide information about you to someone you know. For instance, we may provide information connected to your account with Tooly to your authorized contacts.

Government Entities : Tooly may share information about consumers with government entities in order to fulfill the products purchased by our customers. Certain Personal Information


becomes public record when documents are filed with the federal or state government, or with a court. For example, a name, business address, and registered agent name become public information when its articles of incorporation are filed. A Secretary of State may publish this information to its website or provide this information to third parties for a fee. This Privacy Policy does not cover these or similar third-party actions.

Public Postings : Tooly Inc may publicly share information about consumers, such as by displaying the information on our website or having the information published in publicly available media, in a limited number of circumstances.

· We may share information publicly when it is necessary in order to fulfill a product that has been purchased by a customer. For example, in some states, names, including the name and address of the business owner.

· We may display personal testimonials of satisfied customers received through email surveys on our website or other marketing. If you wish to update or delete your testimonial, you can contact us at [email protected].

· When consumers leave us reviews either on the Tooly website, or on other publicly available websites, we may display these customer reviews on the Tooly website. If you provide a review that we display and wish to update or delete it, you can also contact us at [email protected]. We will delete your review at your request or if, at our discretion, we choose not to update your review as requested.

· Our website includes areas where users may interact with each other, including a question-and-answer section. Any information that is provided in these areas of our website may be publicly available. You should use caution when deciding whether to disclose your Personal Information in these areas of the site. To request removal of your information from our community forums, contact us at [email protected]. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

· When we collect publicly available information, we may share that information on our website.

Registered Agent Requests: If you designate a person or company other than Tooly to serve as the registered agent for your business entity, Tooly may provide your name and contact information to that party, if the designee requests.

Required by Law: Tooly Inc may disclose consumer information as required by law, such as in response to a subpoena, a lawful request by a public authority, including to meet national security or law enforcement requirements, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a legal request.

Related Parties: Tooly Inc may disclose consumer information with businesses controlling, controlled by, or under common control with Tooly Inc. If Tooly Inc is merged, acquired, or sold, or if some or all of our assets or equity are transferred, we may disclose or transfer consumer data in connection with the associated transactions.


In addition to the circumstances listed above, Tooly may also share de-identified or aggregate data that is not capable of being linked to any individual consumer with additional entities not listed above.

Summary of Tooly's Practices Regarding Consumer Information.

The following chart summarizes where Tooly Inc collects each category of information listed above, and how Tooly Inc shares each category of data. Tooly Inc may use each of the categories of information collected for the purposes described in the section above, entitled "How We Use the Information We Collect About Consumers."

Category of Information

Where We Collect the Information

Who We Share the Information With

Identifiers

Consumers, Related Consumers, Employers, Service Providers, Professionals, Business Partners, Publicly Available, Unrelated Parties

Service Providers, Professionals, Business Partners, Employers, Government Entities, Public, Registered Agents, Required by Law, Related Parties

Other

Consumers, Related Consumers, Employers, Service Providers, Professionals, Business Partners, Publicly Available, Unrelated Parties

Service Providers, Professionals, Business Partners, Employers, Government Entities, Registered Agents, Required by Law, Related Parties

Protected Characteristics

Consumers, Related Consumers, Employers, Service Providers, Professionals, Unrelated Parties

Service Providers, Professionals, Business Partners, Government Entities, Public, Required by Law, Related Parties

Commercial

Consumers, Related Consumers, Service Providers, Professionals, Business Partners, Unrelated Parties

Service Providers, Professionals, Business Partners, Employers, Government Entities, Public, Required by Law, Related Parties

Internet

Consumers, Service Providers

Service Providers, Business

Partners, Required by Law, Related Parties

Geolocation

Consumers, Related Consumers, Employers, Service Providers, Professionals, Business Partners, Publicly Available, Unrelated Parties

Service Providers, Professionals, Business Partners, Government Entities, Public, Registered Agents, Required by Law, Related Parties

Audio/visual

Consumers

Service Providers, Required by Law, Related Parties

Professional/employment

Consumers, Related Consumers, Employers, Publicly Available, Unrelated Parties

Service Providers, Professionals, Business Partners, Government Entities, Public, Required by Law,

Related Parties

How Tooly Inc Uses Cookies and Similar Technologies.

This section expands on how Tooly Inc uses internet technologies, such as cookies, to collect information about consumers.

Cookies . Tooly and its partners may use the standard cookie feature of major browser applications and third-party service providers, including Google Analytics features (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration and Google Analytics Demographics and Interest Reporting), or employ internally developed cookies and tracking codes, that allow Tooly Inc to store a small piece of data on a visitor's computer, or any other device a visitor uses to access our website, about his or her visit to the website or use of other plug-ins exchanging information with Tooly Inc. We also use similar technologies, such as JavaScripts or ETags, to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole. You can remove persistent cookies by following directions provided in your Internet browser's "help" directory.

You may also control which cookies are placed on your browser when you visit Tooly's website through our cookie preference center. If you reject cookies, you may still use our site, but your ability to use some areas of our site, such order forms, will be limited.

Web Beacons . We employ a software technology called clear gifs (a.k.a. web beacons), that help us track referrals from our partners and affiliates and better manage content on our website. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and

are used to track the online movements of web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence.

3rd Party Tracking. The use of tracking technologies by our service providers, technology partners or other 3rd party assets (such as social media links) on the site is not covered by our Privacy Policy. These 3rd parties may use cookies, clear gifs, images, and scripts to help them better manage their content on our site. We do not have access or control over these technologies.

Partner and Affiliate Tracking. Our partners and affiliates, including Google Analytics (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics and Interest Reporting), may use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. This means that these partners and affiliates may


show our ads on sites across the Internet based upon your previous visits to our website. Together with our partners and affiliates, we may use these cookies and web beacons to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to your visits to our site.

If you would like to learn more or opt out of receiving online display advertising tailored to your interests, please visit the Networking Advertising Initiative

at www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance

at http://aboutads.info/choices. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your online display advertising opt-out choice. You may also learn more about how Google Analytics uses your information by visiting Google's page How Google Uses Information From Sites or Apps ThatUse Our Service. You may also visit Google Analytics' Ads Settings to opt out of Google's use of cookies and customize Google Display Network ads, and Google Analytics' Opt Out Browser Add-on for the web.

Third Party Links

Third-Party Websites. Tooly Inc may maintain links to other websites and other websites may maintain links to Tooly's websites. This Privacy Policy applies only to Tooly.com and not to other websites accessible from Tooly Inc or that you use to access Tooly, each of which may have privacy policies materially different from this Privacy Policy. For instance, when using Identity Protection products (including Business Data Protection and Tooly Inc Identity Protection), you will visit websites maintained by Tooly's partner Experian, and the Experian privacy policy will govern the information you provide on that website. If you visit other websites, Tooly is not responsible for the privacy practices or content of those sites. It is your responsibility to review the privacy policies of non-Tooly websites to confirm that you understand and agree with them.

Social Media Widgets. Our website includes social media features, such as the Facebook "like" button and widgets, such as the "Share this" button or interactive mini programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

How You Can Control the Information Tooly May Have About You.

This section describes how you can access and control the information that Tooly Inc may have about you. It applies to all consumers worldwide, including individuals who have purchased from Tooly Inc or who believe that information about them may have been provided to us by a third party. Depending on where you reside, you may have additional rights beyond what is


described in this section. If you are a resident of California or the European Union or the United Kingdom, please review the sections "Information for California Residents" and "Information for EU and UK Customers and Visitors" for more information about your rights.

Confirmation of Possession of Information Related to You . Upon a verified request, and subject to the privacy interests of others and technical limitations, Tooly Inc will provide you with information about whether we hold any information related to you. At Tooly's sole discretion, unless otherwise required by law, we may in some instances correct or delete information upon a verified request. Please note, however, that in certain circumstances we may be required by law to retain your Personal Information or may need to retain your Personal Information in order to continue providing a product or service to you or another customer.

If you would like to submit a request about your data, you may do so by completing the form, or by calling us at (888) 737-1337 . After you submit the request, you will be asked to verify your email address and may also be asked to provide additional information in order to verify your identity.

User and Authorized Contact Access to Order Information. Tooly Inc will give you, or anyone listed as an authorized contact for your account, information about your order. This may include information about the nature and status of your order, information you provided to process your order, payment information, and contact information. If you want someone to have access to your order, you must list him or her as an authorized contact or they may not obtain information. You can confirm who is listed as an authorized contact for your account, add new authorized contacts, or remove authorized contacts by clicking first on "My Account", and then on "Account Information". We may send a confirmation email to your authorized contact(s), alerting them that they have been added as an authorized contact. For product-specific information about who may request information about your order, please

contact [email protected] or (888) 737-1337 .

User Access to and Ability to Update Personal Information through MyAccount. You may visit your personal account profile at any time by clicking on the "My Account" link, which will take you to the following URL: https://tooly.com/accounts/login/ Through My Account, you may: (i) review and update basic information about you; (ii) complete pending application/registration; and (iii) begin new order/application.

Opting Out of Email. We send promotional emails and newsletters from time to time to consumers who have provided us with their email address or whose email addresses we have obtained through other sources. You can opt-out of promotional communications by using the "Unsubscribe" link and following the unsubscribe instructions in an email you receive from us or by emailing us at [email protected]. We may also send service-related or transactional communications, which are not promotional. Generally, you may not opt-out of these communications. If you do not wish to receive service-related communications, you may terminate your account by contacting us at [email protected] or (888) 737-1337.


Opting Out of Marketing Calls. If you wish to be placed on Tooly's internal "Do Not Call," you can tell us either while speaking to us on the phone or by emailing us

at [email protected].

Opting Out of SMS/Text Messages. If you wish to stop receiving SMS or text messages from Tooly you can let us know by replying STOP to any SMS/text that you receive from us. You may also let us know by emailing or calling us at [email protected] or (888) 737-1337.

Data Retention. At minimum, we will retain your information for as long as needed to provide you services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Tooly may maintain some or all of this data in its archives even after it has been removed from the Site.

Information Processed On Behalf of Third Parties

In some instances, Tooly may process Personal Information on behalf of third-party

affiliates. Tooly acknowledges that in these instances, you have the right to access your Personal Information. Where Tooly Inc has no direct relationship with the individuals whose Personal Information it processes, individuals seeking access, or seeking to correct, amend, or delete inaccurate data, should direct their inquiry to the third party affiliate (the data controller).

How Secure Is the Personal Information We Collect?

Our Commitment to Data Security. We strive to make certain that our servers and connections incorporate the latest encryption and security devices. We have implemented physical, electronic, and managerial procedures to safeguard and secure the information we collect. Credit card and Personal Information are transmitted by secure servers (TLS). Documents are delivered to you via UPS or similar delivery services, the United States Postal Service, or electronically, including through online storage platforms or email. Unfortunately, no data transmission is guaranteed to be 100% secure and we therefore cannot guarantee the security of information you transmit to or from our website or through the use of our services, and you provide this information at your own risk. ACCORDINGLY, WE DISCLAIM LIABILITY FOR THE THEFT, LOSS, OR INTERCEPTION OF, OR UNAUTHORIZED ACCESS OR DAMAGE TO, YOUR DATA OR COMMUNICATIONS BY USING OUR WEBSITE AND OUR SERVICES. YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND ASSUME THESE RISKS.

IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED PLEASE CONTACT US IMMEDIATELY AT (888) 737-1337 .

Enforcement. We periodically review this Privacy Policy and our compliance with it to verify that both are accurate. We encourage you to contact us with any concerns, and we will investigate and attempt to resolve any complaints and disputes about our privacy practices.


Information for California Residents.

If you are a resident of California, this section provides information regarding your rights, and Tooly's responsibilities, regarding your Personal Information.

California Resident Rights

California law allows California residents, upon a verifiable consumer request, to request that a business that collects consumers' Personal Information give consumers access to certain information. This includes the specific pieces and categories of Personal Information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared.

California residents also have the right to submit a request for deletion of information under certain circumstances. This is not an absolute right and, in some circumstances, Tooly Inc may decline to delete the information, such as when Tooly Inc has an on-going business relationship with you, when we have a continued need to use the information for purposes outlined in this Privacy Policy, or when we are legally required to retain the information.

Consistent with California law, if you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your information.

How to Submit a Request for Access to Information or Deletion of Information

If you would like to submit a request about your data, we encourage you to do so by completing the a form or You can also submit a request by emailing [email protected] or by calling our toll-free number at (888) 737-1337 .

After you submit the request you will be asked to verify your email address and may also be asked to provide additional information in order to verify your identity, including potentially providing a declaration under penalty of perjury. Tooly Inc will attempt to verify your identity by asking for information that correlates with the information that we have previously collected about you. Where this is not possible, Tooly may request you submit additional information for verification, such as proof of residency or redacted government-issued identification. Please note that consistent with California law, we will be unable to satisfy your request until we have verified your identity.

You may also designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide Tooly Inc with written permission for the agent to make the request on your behalf or provide us with an executed power of attorney. You will also be required to submit your valid government issued- identification, and the authorized agent's valid government-issued identification.


Selling of Personal Information

Tooly Inc does not sell Personal Information to third parties and will not sell Personal Information. If, in the future, Tooly Inc does decide to sell Personal Information, any Personal Information collected prior to updating this Privacy Policy will be treated as if a valid request to opt-out from third party sales had been submitted by the consumer that the information relates to.

Information for EU and UK Customers and Visitors.

If you are located in the European Union ("EU") or the United Kingdom ("UK"), this section provides information regarding your rights, and Tooly's responsibilities, and additional information regarding the processing of your personal data.

Lawful Basis of Processing

Tooly Inc processes personal data of persons in the EU and UK based on the lawful basis outlined below.

Where multiple bases are provided, the basis that Tooly relies on for any particular processing will be context dependent.

Purpose of Processing

(Described in the section above entitled "How We Use the Information We Collect About Consumers.")

Legal Basis for Processing

Providing Products and Services

Performance of Contract, Consent,

Legitimate Interest

Security

Legitimate Interest

Meeting Legal Requirements

Compliance with Legal Obligation

Marketing

Consent, Legitimate Interest

Product Development

Legitimate Interest

Analytics

Legitimate Interest

Operational Purposes

Consent, Legitimate Interest,

Compliance with Legal Obligations

Sharing with Business Partners

Performance of Contract, Consent

Financial Reporting and Other Internal Uses

Legitimate Interest

Business Transfers

Legitimate Interest, Compliance with Legal Obligation


EU and UK User Rights

If you are located in the EU or the UK, you have the following rights with respect to how Tooly Inc processes your personal data.

(1) You have the right to request a copy of the personal data that Tooly has about you.

(2) You have the right to request that Tooly Inc correct the information about you if you believe it to be inaccurate.

(3) You have the right to request that Tooly erase or refrain from using your personal data. This is not an absolute right and, in some circumstances, Tooly may decline to erase or limit its usage of your data, such as when Tooly has an on-going business relationship with you or we are legally required to retain the information. If Tooly cannot honor your request, Tooly will inform you of this fact as well as the reasons for Tooly's decision.

To exercise any of these rights, please submit the request using a form Alternatively, you may contact [email protected] or (888) 737-1337 .

If you are located in the EU or the UK, you also have the right to raise any objections regarding the processing of your personal data and to raise any concerns you may have about Tooly's processing of your person data. You may make an objection or raise any other concerns by contacting [email protected] or (888) 737-1337 .

You may also choose to contact Tooly Inc with any objections or other concerns through our email [email protected].

While we hope that Tooly can resolve any of your privacy concerns to your satisfaction after you contact us directly, you also have the right to file a complaint regarding Tooly's handling of your personal data with the EU data protection authorities (DPAs) and/or the Information Commissioner's Office (ICO), the UK's Data Protection Authority. The ICO's contact information is:

Information Commissioner's Office Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

https://ico.org.uk/global/contact-us/email/

+44 1625 545 700

EU-U.S. Privacy Shield


Tooly.com participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework (the "Framework"). While the Framework has been overturned as a mechanism for effectuating cross-border transfers of data from the EU, Tooly Inc remains committed to subjecting all personal data received from the EU and UK to the Framework's applicable Principles. This specifically refers to all EU and UK personal data received by Tooly's U.S. websites. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce's Privacy Shield List.

Under the Privacy Shield Framework, Tooly Inc is responsible for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. Tooly complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and UK, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Tooly is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Changes to This Policy.

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, a notice will be posted on this page along with the updated Privacy Policy prior to the change becoming effective. We encourage you to review this page periodically for the latest information on our privacy practices.

If you have any questions regarding our Privacy Policy, please contact us by submitting your question through our Privacy web form, using the information below.

Mailing Address

Attn: Privacy Team

601 Pennsylvania Ave. NW, South Building, Suite 900, Washington, DC, 20004,

[email protected]

(888) 737-1337

Updated: May 20th 2021