WILLOW NETWORK, INC (‘Company’) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at www.TrustWillow.com (the ‘Site’) and related services (collectively, ‘Services’).

1. USER CONSENT. By submitting Personal Data through our website, Products, or related services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Data in accordance with this Privacy Policy.

2. A NOTE ABOUT CHILDREN. We do not intentionally gather Personal Data about visitors who are under the age of 13.

3. A NOTE TO USERS OUTSIDE OF THE UNITED STATES. Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. BY USING OUR SITE OR SUBMITTING PERSONAL DATA THROUGH OUR SITE OR SERVICES, YOU EXPRESSLY CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA ACCORDING TO THIS PRIVACY POLICY.

4. TYPES OF DATA WE COLLECT. Company collects Personal Data and Anonymous Data from you when you visit our site, when you send us or our Coaches information or communications, and/or when you download and use our Products. ‘Personal Data’ means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. ‘Anonymous Data’ means data that is not associated with or linked to your Personal Data. Anonymous Data does not permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

Personal Data You Provide to Us. We collect Personal Data from you, such as your email address when you provide it voluntarily on the Site. If you provide us feedback or contact us via e-mail (e.g., in response to an employment opportunity posted on our website), we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply, and any information that you submit to us, such as a resume. When you participate in one of our surveys, we may collect additional profile information. When you post messages on the message boards of our website, the information contained in your posting will be stored on our servers and other users will be able to see it. We also collect other types of Personal Data that you provide to us voluntarily, such as your Twitter name or Facebook profile. We may also collect Personal Data, such as demographic information from you via the Products or at other points in our website that state that Personal Data is being collected.

Personal Data Collected via Technology. To make our Site, products, and related services more useful to you, our servers (which may be hosted by a third party service provider) collect Personal Data from you, including your IP address or HTTP referrer. We also use Cookies (as defined below) and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and the solutions and information for which you searched and which you viewed. Like most Internet services, we automatically gather this Personal Data and store it in log files each time you visit our website or access your account on our network. ‘Cookies’ are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our website. Persistent Cookies can be removed by following Internet browser help file directions. If you choose to disable Cookies, some areas of our website may not work properly. We have also enabled Google Analytics features, including Demographics and Interest Reporting to gather demographic information provided by these features. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads by changing your Google Ads Settings.

Recordings. By using our Services you consent to the audio or video recording of conversations between your Coach and yourself and the use of such recordings and any data relating thereto by Willow in order to improve the services and products offered by Willow. Any data from such recordings shall only be used in to improve our Services as described in the section titled “Creation of Anonymized Data” below.

Willow is a member of the Digital Advertising Alliance (DAA) self-regulatory program and adheres to the DAA self-regulatory Principles for Online Behavioral Advertising. We work with a variety of advertisers, ad networks and analytics companies (“Ad Partners”) that collect information about your use of our services. You can opt out of the use of interest-based advertising at any time by visiting the Digital Advertising Alliance consumer choice page.

Our Relationship with Social Networking Sites. We have created, and may offer You, interfaces that allow You to connect with social networking websites such as Facebook and Twitter (‘SN Sites’) through our Site. We will work with the SN Site’s application protocol interface (better known as their developer API) in a way that allows You to authorize us to access Your account on that SN Site on Your behalf. In order to provide this authorization, You will not provide us with Your user name or password to the SN Site, but You will need to log-in to that SN Site directly through our Site. Once authorized by You, the SN Site will provide us a token that allows the SN Site to recognize us when we ask, on Your behalf, for access to Your account information or to post information. You will be able to revoke our access to any SN Site at any time by amending the appropriate settings from within Your account settings on the applicable SN Site, though such revocation may limit the Services we are able to provide You.

5. USE OF YOUR DATA.

General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. Company uses your Personal Data in the following ways:

Provide you with the Services and customer support; Respond to your requests, resolve disputes and/or troubleshoot problems; Verify your compliance with your obligations in our Terms of Use or other policies; Improve the quality of the Site and the Services; Communicate with you about the Site and the Services; Market our products and services (and those of third parties) to You that we believe may be of interest to You. If you prefer that we do not send you these messages, please see the section below on YOUR CHOICES REGARDING YOUR PERSONAL DATA to learn how to opt-out. Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our products and services and improve site navigation. Company reserves the right to use and disclose Anonymous Data to Third Party Companies in its discretion. [a]

6. DISCLOSURE OF YOUR PERSONAL DATA.

Affiliates. We may share some or all of your Personal Data with any parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, ‘Affiliates’), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires Company or our assets, that company will possess the Personal Data collected by it and us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas or warrants served on Company; or (b) protect or defend the rights or property of Company or users of the Products or related services.

7. THIRD PARTIES.

Personal and/or Anonymous Data Collected by Third Parties. We may receive Personal and/or Anonymous Data about you from other sources like telephone or fax, or from companies that provide our products or services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website (‘Third Party Companies’). Our Third Party Companies may supply us with Personal Data, such as your email address, in order to help us establish the account. We may add this information to the information we have already collected from you via our website in order to improve the products and services we provide.

Our provision of a link to any other website or location, such as the payment processing websites, is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our site and go to another site. During this process, another entity may collect Personal Data or Anonymous Data from you.

We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

Disclosure to Third Party Service Providers. Except as otherwise stated in this policy, we do not generally sell, trade, share, or rent the Personal Data collected from our services to other entities. However, we may share your Personal Data with third party service providers to facilitate creation of accounts or to provide services to us that enable us to make the Site or Services available to you or to our Coaches to provide a service to you. You expressly consent to the sharing of your Personal Data with our contractors and other service providers for the sole purpose of providing services to you.

Disclosure to Third Party Companies. We may enter into agreements with Third Party Companies. A Third Party Company may want access to Personal Data that we collect from its customers. As a result, we may disclose your Personal Data to a Third Party Company. The privacy policies of our Third Party Companies may apply to the use and disclosure of your Personal Data that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of our Third Party Companies, you should read and understand their privacy policies.

NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS (AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83).

A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY, OR HOUSEHOLD PURPOSES (A ‘CALIFORNIA CUSTOMER’), MAY REQUEST INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH THIS LAW BY E-MAILING LACY@TRUSTWILLOW.COM. PLEASE NOTE THAT WE ARE REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR, AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER THAN THROUGH THIS E-MAIL ADDRESS.

8. YOUR CHOICES REGARDING YOUR PERSONAL DATA.

Choices. We offer you choices regarding the collection, use, and sharing of your Personal Data. We will periodically send you free newsletters and e-mails that directly promote the use of our site or the purchase of our products or services and may contain advertisements for Third Party Companies. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to ‘opt-out’ by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Should you decide to opt- out of receiving future mailings, we may share your e-mail address with third parties to ensure that you do not receive further communications from third parties. Despite your indicated e-mail preferences, we may send you notices of any updates to our Terms of Use or Privacy Policy.

Changes to Personal Data. You may request deletion of your Personal Data by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.

9. SECURITY OF YOUR PERSONAL DATA. Company is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. Despite these measures, you should know that Company cannot fully eliminate security risks associated with Personal Data and mistakes may happen.

10. CONTACT INFORMATION. Company welcomes your comments or questions regarding this Privacy Policy. Please e-mail us at lacy@staging8.trustwillow.com or contact us at the following address or phone number:

Willow Network, Inc

Attn: Lacy Garcia

226 Causeway Street, 6th Floor, Boston, MA 02114, USA

11. DISPUTE RESOLUTION. If you believe that Company has not adhered to this Statement, please contact Company by email at lacy@staging8.trustwillow.com. 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.

12. CHANGES TO THIS PRIVACY POLICY. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our website. Any material changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our site. These changes will be effective immediately for new users of our website or related services. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Continued use of our website or related services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

This Privacy Policy was last updated on April 17, 2020.

[a] This is addressed more fully in the TOS.