Privacy Policy
FIBRUM (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy
explains how your personal information is collected, used, and disclosed by FIBRUM.
This Privacy Policy applies to our website, and its associated subdomains (collectively, our“Service”) alongside our applications. By accessing or using our Service, you signify that you
have read, understood, and agree to our collection, storage, use, and disclosure of yourpersonal information as described in this Privacy Policy and our Terms of Service.
Definitions and key terms
To help explain things as clearly as possible in this Privacy Policy, every time any of these terms
are referenced, are strictly defined as:-Cookie: small amount of data generated by a website and saved by your web browser. It is
used to identify your browser, provide analytics, remember information about you such as yourlanguage preference or login information.
-Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to FIBRUM LLC,
(KARAVA 2, 2643, NICOSIA, CYPRUS) that is responsible for your information under thisPrivacy Policy.
-Country: where FIBRUM or the owners/founders of FIBRUM are based, in this case isCYPRUS-Customer: refers to the company, organization or person that signs up to use the FIBRUM
Service to manage the relationships with your consumers or service users.
-Device: any internet connected device such as a phone, tablet, computer or any other device
that can be used to visit FIBRUM and use the services.
-IP address: Every device connected to the Internet is assigned a number known as anInternet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP
address can often be used to identify the location from which a device is connecting to theInternet.
-Personnel: refers to those individuals who are employed by FIBRUM or are under contract toperform a service on behalf of one of the parties.
-Personal Data: any information that directly, indirectly, or in connection with other information— including a personal identification number — allows for the identification or identifiability of anatural person.
-Service: refers to the service provided by FIBRUM as described in the relative terms (ifavailable) and on this platform.
-Third-party service: refers to advertisers, contest sponsors, promotional and marketing
partners, and others who provide our content or whose products or services we think mayinterest you.
-You: a person or entity that is registered with FIBRUM to use the Services.

Information automatically collected
There is some information like your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our platform. This information may be
used to connect your computer to the Internet. Other information collected automatically could
be a login, e-mail address, password, computer and connection information such as browser
plug-in types and versions and time zone setting, operating systems and platforms, purchasehistory, (we sometimes aggregate with similar information from other Users), the full Uniform
Resource Locator (URL) clickstream to, through and from our Website that may include date
and time; cookie number; parts of the site you viewed or searched for; and the phone number
you used to call our Customer Services. We may also use browser data such as cookies, Flashcookies (also known as Flash Local Shared Objects) or similar data on certain parts of ourWebsite for fraud prevention and other purposes. During your visits, we may use software tools
such as JavaScript to measure and collect session information including page response times,
download errors, length of visits to certain pages, page interaction information (such as
scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We may
also collect technical information to help us identify your device for fraud prevention anddiagnostic purposes.
We automatically collect certain information when you visit, use or navigate the platform. This
information does not reveal your specific identity (like your name or contact information) but may
include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about who and when you use our and other technical information. This
information is primarily needed to maintain the security and operation of our platform, and for
our internal analytics and reporting purposes.
Right to Delete
You may submit a verifiable request to close your account and we will delete Personal
Information about you that we have collected.
Personnel
If you are a FIBRUM worker or applicant, we collect information you voluntarily provide to us.
We use the information collected for Human Resources purposes in order to administer benefits
to workers and screen applicants.
You may contact us in order to (1) update or correct your information, (2) change yourpreferences with respect to communications and other information you receive from us, (3)receive a record of the information we have relating to you, (4) delete your information. Suchupdates, corrections, changes and deletions will have no effect on other information that wemaintain, or information that we have provided to third parties in accordance with this Privacy
Policy prior to such update, correction, change or deletion.

Sale of Business
We reserve the right to transfer information to a third party in the event of a sale, merger orother transfer of all or substantially all of the assets of FIBRUM or any of its Corporate Affiliates(as defined herein), or that portion of FIBRUM or any of its Corporate Affiliates to which theService relates, or in the event that we discontinue our business or file a petition or have filed
against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third
party agrees to adhere to the terms of this Privacy Policy.

Affiliates
We may disclose information (including personal information) about you to our Corporate
Affiliates. For purposes of this Privacy Policy, "Corporate Affiliate" means any person or entity
which directly or indirectly controls, is controlled by or is under common control with FIBRUM,
whether by ownership or otherwise. Any information relating to you that we provide to ourCorporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms ofthis Privacy Policy.

Governing Law
This Privacy Policy is governed by the laws of CYPRUS without regard to its conflict of laws
provision. You consent to the exclusive jurisdiction of the courts in connection with any action or
dispute arising between the parties under or in connection with this Privacy Policy except for
those individuals who may have rights to make claims under Privacy Shield, or the Swiss-US
framework.
The laws of CYPRUS, excluding its conflicts of law rules, shall govern this Agreement and youruse of the app. Your use of the app may also be subject to other local, state, national, orinternational laws.
By using FIBRUM products or contacting us directly, you signify your acceptance of this Privacy
Policy. If you do not agree to this Privacy Policy, you should not engage with our website, or use
our services. Continued use of the website, direct engagement with us, or following the postingof changes to this Privacy Policy that do not significantly affect the use or disclosure of yourpersonal information will mean that you accept those changes.

Your Consent

We've updated our Privacy Policy to provide you with complete transparency into what is being
set when you visit our site and how it's being used. By using our app, registering an account, ormaking a purchase, you hereby consent to our Privacy Policy and agree to its terms.

Links to Other Websites
This Privacy Policy applies only to the Services. The Services may contain links to otherwebsites not operated or controlled by FIBRUM. We are not responsible for the content,
accuracy or opinions expressed in such websites, and such websites are not investigated,monitored or checked for accuracy or completeness by us. Please remember that when you use
a link to go from the Services to another website, our Privacy Policy is no longer in effect. Yourbrowsing and interaction on any other website, including those that have a link on our platform,
is subject to that website’s own rules and policies. Such third parties may use their own cookies
or other methods to collect information about you.

CookiesFIBRUM uses "Cookies" to identify the areas of our website that you have visited. A Cookie is asmall piece of data stored on your computer or mobile device by your web browser. We use
Cookies to enhance the performance and functionality of our app but are non-essential to theiruse. However, without these cookies, certain functionality like videos may become unavailable
or you would be required to enter your login details every time you visit the app as we would not
be able to remember that you had logged in previously. Most web browsers can be set todisable the use of Cookies. However, if you disable Cookies, you may not be able to accessfunctionality on our website correctly or at all. We never place Personally Identifiable Informationin Cookies.

Blocking and disabling cookies and similar technologies
Wherever you're located you may also set your browser to block cookies and similar
technologies, but this action may block our essential cookies and prevent our website fromfunctioning properly, and you may not be able to fully utilize all of its features and services. You
should also be aware that you may also lose some saved information (e.g. saved login details,
site preferences) if you block cookies on your browser. Different browsers make different
controls available to you. Disabling a cookie or category of cookie does not delete the cookie
from your browser, you will need to do this yourself from within your browser, you should visit
your browser's help menu for more information.

Payment Details

In respect to any credit card or other payment processing details you have provided us, wecommit that this confidential information will be stored in the most secure manner possible.

Kids' Privacy
We do not address anyone under the age of 13. We do not knowingly collect personallyidentifiable information from anyone under the age of 13. If You are a parent or guardian andYou are aware that Your child has provided Us with Personal Data, please contact Us. If We
become aware that We have collected Personal Data from anyone under the age of 13 without
verification of parental consent, We take steps to remove that information from Our servers.

Changes To Our Privacy Policy
We may change our Service and policies, and we may need to make changes to this Privacy
Policy so that they accurately reflect our Service and policies. Unless otherwise required by law,
we will notify you (for example, through our Service) before we make changes to this PrivacyPolicy and give you an opportunity to review them before they go into effect. Then, if you
continue to use the Service, you will be bound by the updated Privacy Policy. If you do not wantto agree to this or any updated Privacy Policy, you can delete your account.

Third-Party Services
We may display, include or make available third-party content (including data, information,applications and other products services) or provide links to third-party websites or services("Third- Party Services").
You acknowledge and agree that FIBRUM shall not be responsible for any Third-Party Services,
including their accuracy, completeness, timeliness, validity, copyright compliance, legality,decency, quality or any other aspect thereof. FIBRUM does not assume and shall not have any
liability or responsibility to you or any other person or entity for any Third-Party Services.
Third-Party Services and links thereto are provided solely as a convenience to you and youaccess and use them entirely at your own risk and subject to such third parties' terms andconditions.

Tracking Technologies-Local Storage
Local Storage sometimes known as DOM storage, provides web apps with methods andprotocols for storing client-side data. Web storage supports persistent data storage, similar tocookies but with a greatly enhanced capacity and no information stored in the HTTP requestheader.

Information about General Data Protection Regulation (GDPR)
We may be collecting and using information from you if you are from the European Economic
Area (EEA), and in this section of our Privacy Policy we are going to explain exactly how andwhy is this data collected, and how we maintain this data under protection from being replicatedor used in the wrong way.

What is GDPR?
GDPR is an EU-wide privacy and data protection law that regulates how EU residents' data isprotected by companies and enhances the control the EU residents have, over their personaldata.
The GDPR is relevant to any globally operating company and not just the EU-based businesses
and EU residents. Our customers’ data is important irrespective of where they are located,which is why we have implemented GDPR controls as our baseline standard for all ouroperations worldwide.

What is personal data?
Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of
information that could be used on its own, or in combination with other pieces of information, toidentify a person. Personal data extends beyond a person’s name or email address. Someexamples include financial information, political opinions, genetic data, biometric data, IPaddresses, physical address, sexual orientation, and ethnicity.

The Data Protection Principles include requirements such as:-Personal data collected must be processed in a fair, legal, and transparent way and should
only be used in a way that a person would reasonably expect.
-Personal data should only be collected to fulfill a specific purpose and it should only be used
for that purpose. Organizations must specify why they need the personal data when they collectit.
-Personal data should be held no longer than necessary to fulfill its purpose.
-People covered by the GDPR have the right to access their own personal data. They can alsorequest a copy of their data, and that their data be updated, deleted, restricted, or moved toanother organization.

Why is GDPR important?
GDPR adds some new requirements regarding how companies should protect individuals'
personal data that they collect and process. It also raises the stakes for compliance byincreasing enforcement and imposing greater fines for breach. Beyond these facts it's simply theright thing to do. At FIBRUM we strongly believe that your data privacy is very important and wealready have solid security and privacy practices in place that go beyond the requirements ofthis new regulation.

Individual Data Subject's Rights - Data Access, Portability and Deletion
We are committed to helping our customers meet the data subject rights requirements of GDPR.
FIBRUM processes or stores all personal data in fully vetted, DPA compliant vendors. We do
store all conversation and personal data for up to 6 years unless your account is deleted. In
which case, we dispose of all data in accordance with our Terms of Service and Privacy Policy,
but we will not hold it longer than 60 days.
We are aware that if you are working with EU customers, you need to be able to provide themwith the ability to access, update, retrieve and remove personal data. We got you! We've been
set up as self service from the start and have always given you access to your data and yourcustomers data. Our customer support team is here for you to answer any questions you might
have about working with the API.

California Residents
The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal
Information we collect and how we use it, the categories of sources from whom we collect
Personal Information, and the third parties with whom we share it, which we have explainedabove.
We are also required to communicate information about rights California residents have under
California law. You may exercise the following rights:-Right to Know and Access. You may submit a verifiable request for information regarding the:(1) categories of Personal Information we collect, use, or share; (2) purposes for which
categories of Personal Information are collected or used by us; (3) categories of sources fromwhich we collect Personal Information; and (4) specific pieces of Personal Information we havecollected about you.
-Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
-Right to Delete. You may submit a verifiable request to close your account and we will delete
Personal Information about you that we have collected.
-Request that a business that sells a consumer's personal data, not sell the consumer'spersonal data.
If you make a request, we have one month to respond to you. If you would like to exercise anyof these rights, please contact us.
We do not sell the Personal Information of our users.
For more information about these rights, please contact us.

Contact Us
Don't hesitate to contact us if you have any questions.
-Via Email: info@fibrum.com