Version 1.2. Latest update: 05/17/2021

Collection and Use of Personal Information

We collect the following personal information from everyone:

• IP Address.

• Contact information such as name, email address, mailing address, phone number

• Preferences information such as email subscription type preferences and communication preferences

• Information about your business such as company name, company size, industry

• Demographic information such as region, job title, interests and zip code

• Only when necessary to determine suitable products and services, may we collect financial information such as bank or brokerage account numbers, types of investments, income, revenue, assets, credits, deductions, expenses, and bank account information

• As is true of most websites, we also automatically gather information about your cookies, as detailed the section regarding Cookies and Other Tracking Technologies

We use this information to:

• Assess the needs of your business to determine suitable products and services

• Send you requested product or service information

• Send you marketing communications, such as newsletters and blog posts Improve our website and marketing efforts

• Conduct research and analysis

• Display content based upon your interests

In addition to the information above, the following data is collected from clients to fulfill our contractual obligation to deliver accounting and tax products and services:

• Billing information such as credit card number and billing address

• Financial information such as bank or brokerage account numbers, types of investments, shareholder information such as cap table, income, revenue, assets, credits, deductions, expenses, and bank account information

• Unique identifiers such as user name, account number, and password

• Date of Birth

We use this information to:

• Establish your identity

• Assess the needs of your business to determine if any suitable products or services are necessary

• Send you requested product or service information

• Send product updates

• Respond to customer service requests

• Administer your account

• Provide requested financial services

• Respond to your questions and concerns

Choice/Opt-Out

You may choose to stop receiving our marketing or sales emails by following the unsubscribe instructions included in these emails or you can contact us at hello@soraban.com.

Information Obtained from Third Parties

If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. An example of this is when you refer a friend or colleague to Soraban.By providing Soraban with a friend or colleague’s personal information, you act as the authorized party to disclose that information to Soraban so that we may collect, use, and disclose such information for the purposes described in this Privacy Policy. This means that you must take reasonable steps to ensure the individual concerned is aware of and/or consents to topics in this Privacy Policy, including the collection of their personal information, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to obtain access to that information, Soraban’s identity, and how to contact Soraban.Where requested to do so by Soraban, you must also assist Soraban with any requests by the individual to access or update the personal information you have collected from them.

Consent to Receive Electronic Communications from Company

By registering for the Service and providing your name, email, postal or residential address, and/or phone number through the Service, you expressly consent to receive electronic and other communications from Company, over the short term and periodically, including email communications. These communications will be about the Service, new product offers, promotions, and other matters. You may opt out of receiving electronic communications at any time by following the unsubscribe instructions contained in each communication, or by sending an email to hello@soraban.com. You agree that these electronic communications satisfy any legal requirements that communications or notices to you be in writing.

Account Information from Third Party Sites

Through the service, you may direct company to retrieve certain information maintained online by third-party financial institutions or providers with which you have a customer relationship, maintain accounts or engage in financial transactions (“account information”). You agree to provide your username, password, pin and other log-in information and credentials necessary to access your account with such institutions or providers ('access information'), and you hereby grant company permission to use the access information and account information for the purposes contemplated by this agreement.By using the service, you expressly authorize company to access, store and use your account information maintained by identified third parties, on your behalf as your agent. You hereby authorize company to store and use your access information to accomplish the foregoing and to configure the service so that it is compatible with the third party sites for which you submit account information. This may include, without limitation, monitoring your usage (including the location of relevant clicks and links) of such third party sites (when accessed through the service) solely to facilitate such compatibility and our contemplated access to your relevant account information in connection with the service. For purposes of this agreement, you grant company a limited power of attorney, and appoint company as your attorney-in-fact and agent, to access third party sites using access information, and to retrieve, store and use your account information with the full power and authority to do and perform each thing necessary in connection with such activities, as you could do in person solely in connection with company’s provision of the service. You acknowledge and agree that when company accesses and retrieves account information from third party sites, company is acting as your agent, and not as the agent of or on behalf of the third party. You acknowledge and agree that the foregoing does not imply sponsorship or endorsement by any third party services accessible through the service. You represent and warrant that neither the foregoing (or anything else in this agreement) nor your use of the services will violate any agreement or terms to which you are subject, including without limitation, those with respect to any third party site or service.

Information Sharing

We will share your personal information with third parties only in the ways that are described in this privacy statement. We do not sell your personal information to third parties.We may provide your personal information to companies that we partner with in joint marketing efforts. In this case, the webpage on which you are submitting your personal information will explicitly state that the data will be shared, and who it will be shared with.We may provide your personal information to companies that provide services to help us with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us.We may also disclose your personal information:

• As required by law such as to comply with a subpoena, or similar legal process.

• 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 government request.

• If Soraban is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

• To any other third party with your prior consent to do so.

Cookies and Other Tracking Technologies

We use cookies to keep track of your preferences and profile information. Cookies are also used to collect general usage and volume statistical information that does not include personal information. We use another company to place cookies on your computer to collect non-personally identifiable information to compile aggregated statistics for us about visitors to our site.Our webpages may contain electronic images known as Web beacons (sometimes called single-pixel gifs) that are used along with cookies to compile aggregated statistics to analyze how our site is used. They are also used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.Our webpages may also contain Web beacons that are set by our third party partners. Web beacons are used along with cookies in order to enable our partners to compile aggregated statistics to analyze how our site is used.We use a third party to gather information about how you and others use our website. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our site is used in order to deliver a better experience for you.

Links to Other Websites

Our Site includes links to other websites whose privacy practices may differ from those of Soraban. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

Security

The security of your personal information is important to us. When you enter sensitive information on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.If you have any questions about security on our website, you can contact us at hello@soraban.com

Where Data is Processed & Stored

To provide you with products and services, we may store, process, and transmit information in the United States and locations around the world. Information may also be stored locally on the devices you use to access our products and services.

How Long We Retain Your Personal Information

In accordance with applicable laws, we keep your information for as long as needed to serve you and maintain your account as needed to operate our business, or to improve our offerings or develop new ones.We retain your information for as long as your account is active or as needed to provide you services. We may retain or use your information as necessary to comply with our policies, legal obligations, resolve disputes, and enforce our agreements.

Purposes of the data processing

We process your information for purposes based on real and legitimate business reasons, the promise we outline in our contract with you, compliance with our legal obligations, and your consent. Below we clearly outline how and why we use the personal information we collected.As a data controller, Soraban collects your personal data fairly and lawfully and in accordance with any applicable law (including the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016) and applicable California Consumer Privacy Act (CCPA), with our Terms of Service and with any Data Processing Agreement. The main purpose of collecting personal data is to provide you with a safe, optimal, efficient, and personalized experience.We may use your personal data to:

• Allow you to use our Services and to provide you with related services.

• Send you information and meet your requests.

• Carry out statistical analyses and develop our Site and Services.

• Comply with the current laws and regulations and our Terms of Services.

Soraban may use the data collected for other purposes, which you will be informed of at the time the data is collected and be asked to accept.If you are a citizen of the European Union (EU), you have certain rights regarding the processing of your personal data:

• You have the right to access and correct your information.

• You have the right to obtain erasure of your information, object to or restrict processing activities related to your information, or withdraw your consent to the processing of your information after you have provided it.

• You have the right to obtain a copy of your information in a structured, commonly used, machine readable format.

• You have the right to lodge a complaint with your local supervisory authority regarding our processing of your information.

• Also, if the information you provide contains special categories of personal data, we will only process it with your explicit consent, which can be withdrawn at any time.

• For assistance in exercising any of these rights, please contact us at hello@soraban.com.

Correcting and Updating Your Personal Information

To review and update your personal information to ensure it is accurate, contact us at hello@soraban.com.

Notification of Privacy Statement Changes

We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Do-Not-Track Disclosure

Soraban does not respond to “Do Not Track” signals sent by browsers.

Children’s Policy

Soraban does not solicit or knowingly collect Personal Information from children under the age of 13. If Soraban obtains actual knowledge that it has collected Personal Information from a child under the age of 13, Soraban will immediately delete such information from its database. Because Soraban does not collect Personal Information from children under the age of 13, Soraban has no such information to use or disclose to third parties. Soraban has designed this Privacy Policy to comply with the Children’s Online Privacy Protection Act (“COPPA”).

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service. The following service providers are in use or planned for use:

• Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service.

• Facebook: Facebook tracks and reports traffic from our ad campaigns

• FullStory: FullStory is a digital experience analytics platform for on-the-fly funnels, pixel-perfect replay, custom events, heat maps. Check their terms of service and privacy policy at https://www.fullstory.com/legal/terms-and-conditions and https://www.fullstory.com/legal/privacy-policy

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Push Notifications

If you are a user of our applications, we may send email or text message notifications even when you are not logged in. We may use push notifications to send you notifications related to the Services and various triggers based on your selections. You can manage your push notification preferences or deactivate these notifications by contacting us or messaging us to STOP. If you choose not to receive push notifications, you may still receive notifications from us.

Contact

You may contact Company by email to hello@soraban.com.