Privacy Policy

Our services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old, we will delete that information.

We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("Personal Information"). Personal Information does not include:

• Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.

• Lawfully obtained, truthful information that is a matter of public concern.

• Deidentified or aggregated consumer information.

• Information excluded from the CCPA's scope, like health or medical information covered by the Health Insurance Portability and Accountability Act (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; or

• Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act.

The chart below identifies the categories of personal information we collected from our consumers within the last 12 months.

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ("California Customer Records").

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

C. Protected classification characteristics under California or federal law ("Protected Classes").

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information).

D. Commercial information.

Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

F. Internet or other similar network activity.

Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites.

G. Geolocation data.

Physical location or movements

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information

I. Professional or employment-related information.

Current or past job history

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) ("FERPA Information").

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

L. Sensitive personal information.

Further identified in the chart below.

Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.

The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.

L.1. Government identifiers, such as your Social Security number (SSN), driver's license, state identification card, or passport number.

L.2. Complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password.

L.3. Precise geolocation, such as GPS data from a consumer's mobile device that can provide its location in a geographic area, with an approximate radius of 1,850 feet.

L.4. Racial or ethnic origin.

L.5. Citizenship or immigration status.

L.6. Religious or philosophical beliefs.

L.7. Union membership.

L.8. Mail, email, or text messages not directed to the Company.

L.9. Genetic data.

L.10. Neural Data, such as information generated by measuring a consumer's central or peripheral nervous system's activity that is not inferred from nonneural information.

L.11. Unique identifying biometric information.

L.12. Health information.

L.13. Sex life or sexual orientation information.

L.14. Children's personal information (under age 18).

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you, such as from the information you provide to the Company.

Indirectly from you, such as from your interactions with the Company's website or social media platforms.

From our service providers, such as connected providers, customer service providers, billing providers, technology partners, and other parties that help us operate.

Other customers, such as from referral programs.

• Automatic Collection of Data

• As you visit the site and interact with our services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include pages visited, referring website or search query, usage details, IP address, operating system, and browser type, and information collected through cookies, including details of your interactions with our services and which resource and service features you access and use. We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking).

• Using automatic collection technologies helps us to improve our services and deliver a better and more personalized experience.

• The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the services. We use three types of cookies:

• Essential cookies. These are required for the site to function. They cannot be disabled if you want to use core parts of the platform.

• Analytics cookies. These help us understand traffic and improve the product.

• Marketing cookies. These may be used to help deliver relevant advertisements and to track campaign effectiveness.

• You may opt out from use of these automated technologies by going to "Manage Cookies" on the login screen.

• Google Analytics: We use Google Analytics, a web analytics service provided by Google LLC ("Google") to help understand how visitors use our website. Google Analytics uses cookies and similar tracking technologies to collect and analyze usage data. Google may use the data collected to contextualize and personalize advertisements within its own advertising network. Information generated by Google Analytics about your use of the website (including your IP address) may be transmitted to and stored by Google on servers in the United States or other countries. You may opt out of Google Analytics tracking by:

• Installing the Google Analytics Opt-out Browser Add-on

• Adjusting your browser's cookie settings to block third-party cookies

• Using your browser's private/incognito mode

• For more information on how Google uses data collected via Google Analytics, visit Google Privacy & Terms.

• Marketing Attribution (UTM parameters): If you arrive at the website via a tracked link (for example, from an email campaign, social media post, or advertisement), the URL may contain UTM parameters such as utm_source, utm_medium, utm_campaign, utm_content, and utm_term. We capture and store these values so we can record which channel or campaign referred to you. This helps us measure the effectiveness of our marketing efforts. UTM values are stored temporarily in your browser and are submitted alongside your form data. They contain no personal information about you beyond what is encoded in the

• link you clicked.

• Bot-detection: We use a bot-detection service that replaces traditional CAPTCHA challenges with a privacy-preserving verification that typically runs invisibly in the background. To verify that we are interacting with a human and not an automated bot, we may collect and process the following signals from your browser: browser characteristics, IP address, interaction signals, cookie and browser storage data, and whether cookies are enabled and basic hardware fingerprinting signals. We process this data solely to issue a verification token confirming you are not a bot.

• When you interact with the services, there are third parties that may use automatic collection techniques to collect information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.

• Analytics companies.

• Your device manufacturer.

• Your internet or mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

We may use and disclose the personal information, we collect to advance the Company's business and commercial purposes, specifically to:

Develop, offer, and provide you with our products and services.

Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.

Fulfil the purposes for which you provided your personal information or that were described to you at collection, and as the CCPA otherwise permits.

Power AI-enabled research features, analytics, digests, screeners, watchlists, alerts, notifications, and related automations.

Generate, rank, summarize, and deliver AI-assisted outputs based on your inputs and available data.

Improve our products or services, marketing, or customer relationships and experiences.

Notify you about changes to our products or services.

Administer our systems and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.

Enable your participation in our websites' or mobile apps' interactive, social media, or other similar features.

Protect our Company, employees, or operations.

Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.

Make suggestions and recommendations to you and other consumers about our goods or services that may interest you or them.

Manage your consumer relationship with us, including for:

online account creation, maintenance, and security; and

reaching you, when needed, about your account.

Perform data analytics and benchmarking.

Administer and maintain the Company's systems and operations, including for safety purposes.

Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.

Comply with all applicable laws and regulations.

Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.

Respond to law enforcement requests and as required by applicable law or court order.

We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.

Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.

Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.

Ensuring physical safety.

Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:

disclose the sensitive personal information to another third party; or

use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.

Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.

Activities required to:

verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or

improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.

Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some of all of Podium's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Podium is among the assets transferred.

• With your consent.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

We may disclose the personal information we collect, including sensitive personal information, to service providers and contractors for the business purposes described in the Personal Information, Collection, Use and Disclosure Purposes section and in the table below, such as to support our business functions.

We only make these business purpose disclosures under written contract that describes the purposes, requires the recipient to keep the personal information confidential, prohibits using the disclosed information for any purpose except performing the contract, and meets the CCPA's other contract requirements for engaging service providers or contractors.

The list below identifies the personal information categories we disclose to service providers or contractors for a business purpose over the preceding 12 months and the specific business or commercial purpose for disclosing that information.

• Identifiers, California Customer Records, and commercial information to Customer Service Support Providers.

• Identifiers, California Customer Records, and commercial information to Billing Providers.

We do not sell your personal information to third parties and have not sold it in the preceding 12 months. We do not share your personal information with third parties for cross-context behavioral advertising purposes and have not shared your personal information in the preceding 12 months.

Depending on your state of residency, you may have certain rights related to your personal data. The exact scope of these rights varies by state. There are also exceptions where we may not have an obligation to fulfill your request. To exercise any of these rights, please email [email protected].

Nevada provides its residents with a limited right to opt out of certain personal data sales. However, please know we do not currently sell data triggering that statute's opt out requirements.

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the "right to know"), including the specific pieces of personal information we have collected about you (a "data portability request"). You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights, below), we will disclose to you:

The categories of:

personal information we collected about you; and

sources from which we collected your personal information.

The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.

If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:

disclosed for a business purpose to each category of persons; and

sold or shared to each category of third parties.

When your right to know submission includes a data portability request, a copy of your personal information, subject to any permitted redactions.

For more on exercising this right, see Exercising the Rights to Know, Delete, or Correct.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the "right to delete"). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.

For more on exercising these rights, see Exercise the Rights to Know, Delete or Correct.

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA's Permitted SPI Purposes (the "right to limit"). As we do not use or disclose sensitive personal information beyond the CCPA's Permitted SPI Purposes, we do not currently provide this consumer right.

You have the right to request that businesses stop selling or sharing your personal information at any time (the "right to opt-out"), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer's parent or guardian for consumers under age 13 (the "right to opt-in").

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

To exercise the right to know (including data portability), delete, or correct, described above, please submit a verifiable request to emailing us at [email protected].

Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice in a 12-month period.

Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information. To designate an authorized agent, email us at [email protected]. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your personal information.

We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use personal information provided in the request to verify the requestor's identity or authority to make the request.

We consider requests made through your password-protected account with our company sufficiently verified when the request relates to personal information associated with that specific account.

For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer's name, email address, or account username.

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact [email protected].

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request's receipt date.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will update the policy's effective date and post the updated policy on our website. We encourage you to check our Website to review the current Privacy Policy in effect.

If you have any questions or comments about this policy, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at [email protected].