PRIVACY POLICY

Effective Date: October 1, 2020.

The website located at www.descomm.net, its sub-domains, and certain affiliated websites (the “Site”) is a collection of various intellectual properties that belong to Descomm, and its agents, employees, contractors, affiliates, subsidiaries, parent company, and other related companies (“descomm”, “Us”, “Our”, and “We”). This Descomm’s Privacy Policy (“Policy”) describes the information we gather from you when you use the Site, and related services (together, the “Services”) and how we use, process, and disclose that information. We may add to this Policy with other notices. We may also post additional privacy statements for some portions of the Services. By submitting personal information through our Services, you expressly consent to the transfer of your personal data to our servers in the United States for our collection, use, and disclosure in accordance with this Policy.

At Descomm, we are committed to safeguarding your privacy. We want you to know how we may collect, use, share, and keep information about you and the choices that are available to you.

When we provide Descomm products or services to you, we may also give you specific additional details about how we will use your personal information. If you have a Descomm product or service that is not provided by Descomm (such as a service rendered by one of our associated institutions), please review the relevant privacy notice that covers such product or service or contact your product or service provider for information about their privacy practices.

This online privacy statement applies to Descomm websites, online applications that run on smart phones, tablets, mobile devices (“apps”) if applicable, and other online services that we offer which link to this statement. It does not apply to those websites, apps or online services that have their own online privacy statements.

Since we may change this online privacy statement, we recommend that you check the current version available from time to time. If we make changes to this statement, we will update the “Effective Date” at the top of this page.

What information does this Online Privacy Statement cover?

This online privacy statement describes how we (and our Service Providers) may collect, use, share, and keep information that we get about you online. We gather Online Information if you:

• Visit or use our websites or apps;
• Receive or reply to electronic communications from us;
• View or click on our ads or other online content; and
• Interact with us through social media websites and other websites and apps.

In this statement, we also explain how we may combine Online Information with Other Information and how we then use the combined information.

What information do we collect online and how do we collect it?

The types of information we collect depends on which product or service you use.

Sometimes you provide information directly to us (or to our Service Providers). For example, you might provide us your name, account number, email, mailing address, phone number, or date of birth when you:

• Fill out an online form;
• Register, log into or update the settings on your account using our online services;
• Subscribe to our newsletters;
• Provide your testimonials to be published on our websites and/or marketing materials.
• Cookies and Tracking Technologies

We (and our Service Providers or Third-Party Ad-Servers) also collect information through Cookies and Similar Technologies. Most Cookies and Similar Technologies will only collect De-Identified Information such as how you arrive at our website or your general location.

We (and our Service Providers or Third-Party Ad-Servers) may collect information using Cookies and Similar Technologies about:

• The device you use to browse our websites or use our apps (for example, we may collect information about the operating system or the browser version and the type of device you use to open electronic communications from us);
• The IP Address and information related to that IP Address (such as domain information, your internet provider and general geographic location);
• Browsing history on our websites or apps (such as what you search for, the pages you view, how long you stay, and how often you come back);
• How you search for our websites or apps, from which website you came from, and which of our Business Partners’ websites you visit;
• Which ads or online content from us and our Business Partners you view, access, or click on;
• your browsing activities over time and across other websites, following your visit to one of our websites or apps;
• Whether you open our electronic communications and which parts you click on; and
• the location of your mobile device (for example, when you use mobile websites or apps to register to receive location-based content).

We (and our Service Providers or Third-Party Ad-Servers) may also collect information made available through third-party platforms and apps (such as online social media platforms), through online databases or directories, or that is otherwise legitimately obtained. This information may be governed by the privacy notice(s) provided by the third party at the time of collection.

How do we use the information we collect about you?

We may use Online Information we collect about you on its own or combine it with Other Information to:

• Deliver products and services, including to:
• Recognize you when you return to our websites or use our apps;
• Complete transactions;
• Tell you about updates to your accounts, products, and services;
  Update you about new features and benefits;
• Answer questions and respond to your requests made through our websites or apps and through third-party websites (including social media);
• Use the location of your mobile device for location-based services that you may request;
• Determine how to best provide services to you and manage your accounts, such as the best way and time to contact you;
• Advertise and market our products and services – and those of our Business Partners – including to:
• Present content that is tailored to your interests, including Targeted Advertising;
• Send or provide you with ads, promotions, and offers;
• Analyze whether our ads, promotions, and offers are effective;
• Help us determine whether you may be interested in new products or services;
• Conduct research and analysis, including to:
• Better understand our customers and our website visitors or app users;
• Allow you to give feedback by rating and reviewing our products and services and those of our Business Partners;
• Produce data analytics, statistical research, and reports;
• Review and change our products and services;
• Manage fraud and security risk, including to:
• Detect and prevent fraud or criminal activity;
• Safeguard the security of your information;
• Assess credit risks relating to our business, including to:
• Evaluate and process your applications for our products and services and manage your existing accounts; and
• Use it in other ways as required or permitted by law or with your consent.
• Allow you to give feedback by rating and reviewing our products and services and those of our Business Partners;

How do we treat your Personal Information?

We do not share Personal Information with anyone except as described below. We may share Personal Information as required or as permitted by law, such as:

• With credit bureaus and similar institutions to report or ask about your financial circumstances, and to report or collect debts you owe;
• With regulatory authorities, courts, and governmental agencies to comply with legal orders, legal or regulatory requirements, and government requests;
• With our Service Providers, regulatory authorities, and governmental agencies to detect and prevent fraud or criminal activity, and to protect the rights of Descomm or others;
• Within the Scorpion Capital Group Incorporated Family of Companies;
• With our Service Providers who perform services for us and help us operate our business (we require Service Providers to safeguard Personal Information and only use your Personal Information for the purposes we specify);
• With financial institutions or Co-brand Partners with whom we jointly offer or develop products and services (but they may not use your Personal Information – in particular your email address – to independently market their own products or services to you unless you consent that they can do so);
• In the context of a sale of all or part of the Scorpion Capital Group Incorporated Family of Companies or their assets; or
• For specific products or services, when you have given your consent.
  We may transfer Personal Information to Service Providers or companies within the Scorpion Capital Group Incorporated Family of Companies throughout the world, for example, to process transactions and provide you with our products or services. Regardless of where we process your information, we still protect it in the manner described in this online privacy statement and according to the applicable laws.

How we handle Aggregated and De-identified Information?

Aggregated Information or De-identified Information does not identify you individually; it helps us to analyze patterns among groups of people. We may share Aggregated Information or De-identified Information in several ways, for example:

• For the same reasons as we might share Personal Information;
• With Business Partners to help develop and market products or services and present targeted content and Targeted Advertising;
• With Business Partners to conduct analysis and research about customers and website visitors; or
• With Third-Party Ad-Servers to place ads (including ads of our Business Partners) on various websites and apps, and to analyze the effectiveness of those ads.

How do we keep and safeguard your information?

We use administrative technical and physical security measures to protect your Personal Information. These measures include computer safeguards and secured files and facilities. We take reasonable steps to securely destroy or permanently de-identify Personal Information when we no longer need it. We will keep your Online Information only as long as we must to deliver our products and services, unless we are required by law or regulation or for litigation and regulatory investigations to keep it.

What are your choices?

You may opt out of receiving marketing/promotional emails or SMS messages from Descomm by emailing us at support@descomm.net. If you opt out of receiving marketing/promotional emails and/or text messages, we may still send you non-promotional emails, such as emails about our ongoing business relations. You may also send requests about your personal information, including changes to your contact preferences, changes to or deletions of your information or content you post, and requests to opt-out of sharing your personal information with third parties by emailing support@descomm.net. Please note that deletion of your personal information or content does not ensure complete or comprehensive removal of the content or information posted on the Services.

When you visit the Site, most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies from our Site or from third parties. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site. To opt-out of Google Analytics web tracking for certain browsers, you can download Google Analytics Opt-out Browser Add-on. You may opt out of other cookies that may be present on the Site by following the directions on Google’s opt-out page. You can also choose to opt-out of use of cookies by some of our third-party advertising partners to deliver ads tailored to your profile and preferences. However, while we and others give you choices as described in this policy, there are many ways in which Web browser signals and other similar mechanisms can indicate your choice to disable tracking, and our Site may not be aware of or honor every mechanism.

You may decline to share certain data with Descomm, in which case we may not be able to provide you with some of the features and functionality of the Site or Service. You may have the right to know what personal information Descomm has about you and to correct any inaccuracies. Please direct any such requests by email to support@descomm.net or by one of the other means listed below.

Dispute Resolution

If you believe that Descomm has not adhered to this Policy, please contact Descomm by e-mail at support@descomm.net.We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.

Descomm Contact Information

Please contact Descomm with any questions or comments about this Policy, your information, our third-party disclosure practices, or your consent choices.

Descomm
Email: support@descomm.net