Introduction and Acceptance

DLZP Group, LLC (referred to as “DLZP”, “we, “our” or “us”, as the context may require) values our relationships with our users, guests, and customers, and we respect your privacy and are committed to protecting your Personal Information (as defined herein) through compliance with this privacy policy ("Policy"). This Policy describes the types of information we may collect from you (referred to as “customer”, “User”, or “you”, as the context may require) when using our website located at www.stage.dlzpgroup.com (“Site”) and our policies and practices for collecting, using, maintaining, protecting, and sharing that information. The Policy applies to the Site and all on-line services provided by DLZP (“Services”). Please read this Policy carefully. This Policy does not apply to any products, services, websites, experiences, applications, events and content that are offered by third parties or have their own privacy policy or notice. In providing Services to our customers we use one or more Amazon Web Services, Inc. (“AWS”) offerings and your Personal Information is shared with AWS, whose privacy notice can be found at https://AWS.amazon.com/privacy/. You should read AWS’s privacy notice, and our other business partners privacy notices, carefully and check back frequently to ensure you understand each current policy. By accessing and by using our Site or Services, each User agrees to be bound by this Policy. This Policy may be updated by DLZP from time to time by posting a new version on the Site. It is our practice to post any changes we make to our Policy on this page with a notice that this Policy has been updated on the Site. Use of any of the Site or our Services following such changes will be deemed acceptance of such changes. The date this Policy was last revised is identified at the bottom of this Policy (see Last Updated Date below). Our business develops and changes. You should check this page frequently to ensure you understand our current Policy. The Policy applies regardless of User’s method of access (i.e. computer browser, Outlook application, smart phone, etc.). The Site is operated in the United States, and please be on notice that any information you provide to us or your use of the Site will be transferred to and through the United States. Your use of the Site is your consent to such transfer and consent and awareness that the United States may not provide the same protections or level of such as lAWS, codes and/or regulations in other countries.

Information We May Collect and How We Collect It

User retains ownership rights in any content, data, or other such materials User uploads or otherwise actively provides to DLZP through the Site (the "Content"). User grants to DLZP (and its employees, agents, successors, and assigns) a worldwide, irrevocable, perpetual, fully-paid license to use such Content in any manner reasonably necessary for DLZP to operate the Site and to provide the Services in connection with the Site.

We collect several types of information from and about individuals who access and use our Services and Site, including information:

• By which you may be personally identified, such as information directly connected to your name, for example, your e-mail address, virtual face or picture, mailing address, and other details about you (“Personal Information”)
• That is about you but individually does not identify you, such as search queries; and
• About your internet connection, internet service provider, the equipment you use to access our Services and Site, usage details and other similar information.

We collect this information:

• Directly from you when you provide it to us, including information you provide for the purpose of registering with us via a customer information form (for example, user-created username virtual face or picture, mailing address, email address and other details about you) and
• Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

In addition to the information above, we may collect additional information through the Services and Site, including:

As you navigate through and interact with our Site and the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to the Site, including traffic data, location data, logs, and other communication data and other resources that you access and use on the Site and
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and may include Personal Information or may be maintained or associated with Personal Information we collect in other ways.

Cookies

The technologies we use for automatic data collection may include “cookies” or “browser cookies”. A cookie is a small file placed on the hard drive of your computer for record-keeping purposes and sometimes to track information about you. You may modify the settings on your browser so that you refuse to accept browser cookies or so that you are alerted when cookies are being sent by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Services or Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Services or Site.

As mentioned above, in providing Services we use third party product and service offerings, which generates statistical and other information about the use by means of cookies stored on users' computers. You should review the AWS cookies notice carefully, and it is located at https://AWS.amazon.com/legal/cookies/.

How We Use the Information We Collect

We may use the information that we collect about you or that you provide to us, including any Personal Information:

• To enable your use of the Services available on the Site, run a promotion, contest or other site feature;
• To enable your use of the Services available on the Site, run a promotion, contest or other site feature;
• To provide you with customer service, notices about any orders, inform you of or changes to or new services, products or provide other information we need to communicate to you or that you have requested;
• To send you billing and collection information along with general communications and periodic emails in response to your inquiries, questions, and/or other requests, inquiries and complaints;
• In any other way, we may describe when you provide the information; and
• For any other purpose with your consent.

With Whom We Share Information

In addition to the disclosures reasonably necessary for the purposes identified elsewhere in this Policy, we may disclose information about aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Information that we collect or you provide as described in this Privacy Policy, including disclosing information:

• To fulfill the purpose for which you provide it
• To third parties who provide services, software, content, data backup or recovery, cloud computing capabilities, and other functions and support to our business and who are obligated to use it for the purposes for which we disclose it to them and bound by applicable data protection law;
• To a buyer or other successor in the event of a merger, reorganization, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about the Site and our users is among the assets transferred; and
• At your option, to others with your consent after you have received notice when Personal Information about you might be shared with third parties.

We may also disclose your Personal Information:

• To the extent we are required to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• To establish, exercise or defend our legal rights and to enforce or apply our terms and conditions and any other agreements, including for billing and collection purposes; and
• For the protection of us, our customers and others if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of DLZP, such as exchanging information for the purposes of fraud protection and credit risk reduction.

We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

California Civil Code Section § 1798.83 permits Users of our site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us, in writing, as specified below in the Section entitle, General Contact Information.

We have implemented and adopted appropriate commercially reasonable measures designed to secure your Personal Information against unauthorized access, alteration, disclosure or destruction. All information you provide to us is stored on secure servers behind firewalls. Any Personal Information or payment-related information exchanged will be protected using encrypted, protected with digital signatures, and transported over an SSL secured communication channel.

No transmission of information via the internet or any electronic commerce is completely secure. Although we use appropriate commercially reasonable efforts and standards to protect your Personal Information, we cannot guarantee the security of the Personal Information transmitted to our Site and through our Services. Any transmission of Personal Information is at your own risk and you should consider taking pro-active steps to secure and protect yourself, your Personal Information and all information online and with any electronic commerce. You are responsible for keeping your password and user details confidential and we will not ask for your password in any correspondence between us. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. We reserve the right to contact or notify you about any information regarding this Policy, security, our Services or the Site electronically along with other means of notification. If you rely upon third-party software integrated into the Service, User’s information will be handled by such third-party and DLZP cannot assure User that such information will be handled in a secure manner.

Compliance and Related Information Regarding Minors

No one under the age of 13 may provide any Personal Information to our site(s) and we do not knowingly collect Personal Information from children under the age of 13 (or 18 without parental/guardian consent). If you are under the age of 13, do not use or provide any Personal Information on our sites or provide any information to us about yourself, including your name, address, telephone number, email address, screen name or user name you may use. If we learn we have collected or received Personal Information from a child under the age of 13 (or under the age of 18 without parental/guardian consent), we will delete that information. If you believe we might have any Personal Information from or about a child under the age of 1e (or 18 without parental/guardian consent), please contact use at our contact information specified below.

Additional Users

When a customer requests that an individual be given access to customer’s account, DLZP shall send the potential individual user an invitation to register to access the site. By requesting that access be given to an individual user, customer represents and warrants to DLZP that customer has an existing business relationship with such additional user sufficient to avoid liability under any law that applies to unsolicited email. Customer will be deemed to be the sender of any such email (or other electronic communication) and DLZP will be deemed to merely be a service provider facilitating Customer’s sending of the email (or other electronic communication).

Email Communications

DLZP may periodically communicate with User via email, including by emails that verify password and user name information, or which provide updates, service announcements, administrative messages, and/or other important information about the Services. These emails are tied to the Service and contain important information about the Service or User’s use thereof. Such communications can only be unsubscribed from by cancelling User’s account.

Correcting or Updating Personal Information

If User’s Personal Information changes, or if User has a reason to believe that User’s Personal Information maintained by DLZP is incorrect, User may contact DLZP and DLZP will accommodate such reasonable requests for such changes.

DLZP will use commercially reasonable efforts to timely make any changes request by Users. Many such changes are accomplished using batch processing (i.e. collecting a number of similar change requests and making all such changes at once), so the changes may not be immediately effective but may take thirty (30) days or longer. If User requires an immediate change to User’s Personal Information and User is unable to make such a change using the available site resources, please contact DLZP at info@dlzpgroup.com.

Retention of Personal Information

DLZP keeps your Personal Information for as long as necessary to provide Services and the relevant purposes described in this Policy, as may be required by law (including for our tax and accounting purposes), or as we otherwise notify you.

Deactivating Account, Connecting, and Unsubscribing

A User may deactivate their account at any time by contacting DLZP at info@dlzpgroup.com.

By agreeing to the terms of this Privacy Policy, User further agrees that DLZP may connect (i.e. stitch) any of User’s authenticated and non-authenticated browsing sessions.

For questions about User’s privacy rights, please contact DLZP at info@dlzpgroup.com. Please note, it may not be possible for User to opt out of receiving certain communications (such as those related to User’s account information or system status) or to halt the sharing of certain information; User’s only option will be to terminate User’s account.

General Contact Information

In the event that a User feels that DLZP is not abiding by this Policy or a User has any questions regarding this Policy, User may contact DLZP Group at info@dlzpgroup.com.

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. We will be the controller of your Personal Data processed in connection with the Services. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.

If you have any questions about this section or whether any of the following applies to you, please contact us at info@dlzpgroup.com.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below. The legal bases depend on the Services you use and how you use them.

Contractual Necessity: We also process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

• IP Address
• Profile Data
• Device ID
• Cookie Data

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties (which is not overridden by your data protection interests):

• IP Address
• Profile Data
• Device ID
• Cookie Data

Examples of these legitimate interests include:

• Operation and improvement of our business, products and services
• Marketing of our products and services
• Provision of user support
• Protection from fraud or security threats
• Compliance with legal obligations
• Completion of corporate transactions
• Consent: In some cases, we may process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time-to-time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Personal Data of Children: We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at info@dlzpgroup.com.

What Rights Do You Have Regarding Your Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email to info@dlzpgroup.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary, to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by updating any of the information contained in your user profile.
• Erasure: You can request that we erase some or all your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note; however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all our Services.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about DLZP’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data: The Services are hosted and operated in the United States (“U.S.”) through DLZP and our service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to DLZP in the U.S. and will be hosted on U.S. servers, and you authorize us to transfer, store and process your information to and in the U.S., and possibly other countries. DLZP is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

What If You Have Questions Regarding Your Personal Data? If you have any questions about this section or our data practices generally, please contact us using the following information:

info@dlzpgroup.com

Attn: Legal Department – Personal Data

281-912-3597

Effective Date: September 12, 2019