PRIVACY POLICY

Last updated May 10, 2024

This privacy notice for Selleb, Inc. ("we," "us," or "our"), describes how and

why we might collect, store, use, and/or share ("process") your information

when you use our services ("Services"), such as when you:

Visit our website at http://www.selleb.com, or any website of ours

that links to this privacy notice

Download and use our mobile application (Selleb), or any other

application of ours that links to this privacy notice

Engage with us in other related ways, including any sales,

marketing, or events

Questions or concerns? Reading this privacy notice will help you

understand your privacy rights and choices. If you do not agree with our

policies and practices, please do not use our Services. If you still have any

questions or concerns, please contact us at support@selleb.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you

can find out more details about any of these topics by clicking the

link following each key point or by using our table of contents below

to find the section you are looking for.

What personal information do we process? When you visit, use, or

navigate our Services, we may process personal information depending on

how you interact with us and the Services, the choices you make, and the

products and features you use. Learn more about personal information you

disclose to us.

Do we process any sensitive personal information? We do not process

sensitive personal information.

Do we receive any information from third parties? We do not receive

any information from third parties.

How do we process your information? We process your information to

provide, improve, and administer our Services, communicate with you, for

security and fraud prevention, and to comply with law. We may also

process your information for other purposes with your consent. We process

your information only when we have a valid legal reason to do so. Learn

more about how we process your information.

In what situations and with which parties do we share personal

information? We may share information in specific situations and with

specific third parties. Learn more about when and with whom we share

your personal information.

How do we keep your information safe? We have organizational and

technical processes and procedures in place to protect your personal

information. However, no electronic transmission over the internet or

information storage technology can be guaranteed to be 100% secure, so

we cannot promise or guarantee that hackers, cybercriminals, or other

unauthorized third parties will not be able to defeat our security and

improperly collect, access, steal, or modify your information. Learn more

about how we keep your information safe.

What are your rights? Depending on where you are located

geographically, the applicable privacy law may mean you have certain

rights regarding your personal information. Learn more about your privacy

rights.

How do you exercise your rights? The easiest way to exercise your

rights is by submitting a data subject access request, or by contacting us.

We will consider and act upon any request in accordance with applicable

data protection laws.

Want to learn more about what we do with any information we

collect? Review the privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR

PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL

INFORMATION?

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

7. WHAT ARE YOUR PRIVACY RIGHTS?

8. CONTROLS FOR DO-NOT-TRACK FEATURES

9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY

RIGHTS?

10. DO WE MAKE UPDATES TO THIS NOTICE?

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE

COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you

register on the Services, express an interest in obtaining information about

us or our products and Services, when you participate in activities on the

Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we

collect depends on the context of your interactions with us and the

Services, the choices you make, and the products and features you use.

The personal information we collect may include the following:

names

phone numbers

email addresses

mailing addresses

usernames

passwords

contact preferences

contact or authentication data

Sensitive Information. We do not process sensitive information.

Application Data. If you use our application(s), we also may collect the

following information if you choose to provide us with access or permission:

Mobile Device Access. We may request access or permission to

certain features from your mobile device, including your mobile

device's contacts, reminders, and other features. If you wish to

change our access or permissions, you may do so in your device's

settings.

Push Notifications. We may request to send you push notifications

regarding your account or certain features of the application(s). If

you wish to opt out from receiving these types of communications,

you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation

of our application(s), for troubleshooting, and for our internal analytics and

reporting purposes.

All personal information that you provide to us must be true, complete, and

accurate, and you must notify us of any changes to such personal

information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer

our Services, communicate with you, for security and fraud prevention, and

to comply with law. We may also process your information for other

purposes with your consent.

We process your personal information for a variety of reasons,

depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise

manage user accounts. We may process your information so you

can create and log in to your account, as well as keep your account

in working order.

To request feedback. We may process your information when

necessary to request feedback and to contact you about your use of

our Services.

To protect our Services. We may process your information as part

of our efforts to keep our Services safe and secure, including fraud

monitoring and prevention.

To identify usage trends. We may process information about how

you use our Services to better understand how they are being used

so we can improve them.

To save or protect an individual's vital interest. We may process

your information when necessary to save or protect an individual’s

vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO

PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is

necessary and we have a valid legal reason (i.e., legal basis) to do so

under applicable law, like with your consent, to comply with laws, to provide

you with services to enter into or fulfill our contractual obligations, to protect

your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us

to explain the valid legal bases we rely on in order to process your personal

information. As such, we may rely on the following legal bases to process

your personal information:

Consent. We may process your information if you have given us

permission (i.e., consent) to use your personal information for a

specific purpose. You can withdraw your consent at any time. Learn

more about withdrawing your consent.

Legitimate Interests. We may process your information when we

believe it is reasonably necessary to achieve our legitimate business

interests and those interests do not outweigh your interests and

fundamental rights and freedoms. For example, we may process

your personal information for some of the purposes described in

order to:

Analyze how our Services are used so we can improve them

to engage and retain users

Diagnose problems and/or prevent fraudulent activities

Understand how our users use our products and services so

we can improve user experience

Legal Obligations. We may process your information where we

believe it is necessary for compliance with our legal obligations, such

as to cooperate with a law enforcement body or regulatory agency,

exercise or defend our legal rights, or disclose your information as

evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe

it is necessary to protect your vital interests or the vital interests of a

third party, such as situations involving potential threats to the safety

of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission

(i.e., express consent) to use your personal information for a specific

purpose, or in situations where your permission can be inferred (i.e.,

implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable

law to process your information without your consent, including, for

example:

If collection is clearly in the interests of an individual and consent

cannot be obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is

necessary to assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating

with next of kin

If we have reasonable grounds to believe an individual has been, is,

or may be victim of financial abuse

If it is reasonable to expect collection and use with consent would

compromise the availability or the accuracy of the information and

the collection is reasonable for purposes related to investigating a

breach of an agreement or a contravention of the laws of Canada or

a province

If disclosure is required to comply with a subpoena, warrant, court

order, or rules of the court relating to the production of records

If it was produced by an individual in the course of their employment,

business, or profession and the collection is consistent with the

purposes for which the information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the

regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR

PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this

section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in

connection with, or during negotiations of, any merger, sale of

company assets, financing, or acquisition of all or a portion of our

business to another company.

Business Partners. We may share your information with our

business partners to offer you certain products, services, or

promotions.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the

purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary

for the purposes set out in this privacy notice, unless a longer retention

period is required or permitted by law (such as tax, accounting, or other

legal requirements). No purpose in this notice will require us keeping your

personal information for longer than the period of time in which users

have an account with us.

When we have no ongoing legitimate business need to process your

personal information, we will either delete or anonymize such information,

or, if this is not possible (for example, because your personal information

has been stored in backup archives), then we will securely store your

personal information and isolate it from any further processing until deletion

is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of

organizational and technical security measures.

We have implemented appropriate and reasonable technical and

organizational security measures designed to protect the security of any

personal information we process. However, despite our safeguards and

efforts to secure your information, no electronic transmission over the

Internet or information storage technology can be guaranteed to be 100%

secure, so we cannot promise or guarantee that hackers, cybercriminals, or

other unauthorized third parties will not be able to defeat our security and

improperly collect, access, steal, or modify your information. Although we

will do our best to protect your personal information, transmission of

personal information to and from our Services is at your own risk. You

should only access the Services within a secure environment.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA),

United Kingdom (UK), Switzerland, and Canada, you have rights that allow

you greater access to and control over your personal information. You may

review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have

certain rights under applicable data protection laws. These may include the

right (i) to request access and obtain a copy of your personal information,

(ii) to request rectification or erasure; (iii) to restrict the processing of your

personal information; (iv) if applicable, to data portability; and (v) not to be

subject to automated decision-making. In certain circumstances, you may

also have the right to object to the processing of your personal information.

You can make such a request by contacting us by using the contact details

provided in the section "HOW CAN YOU CONTACT US ABOUT THIS

NOTICE?" below.

We will consider and act upon any request in accordance with applicable

data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully

processing your personal information, you also have the right to complain

to your Member State data protection authority or UK data protection

authority.

If you are located in Switzerland, you may contact the Federal Data

Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process

your personal information, which may be express and/or implied consent

depending on the applicable law, you have the right to withdraw your

consent at any time. You can withdraw your consent at any time by

contacting us by using the contact details provided in the section "HOW

CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your

preferences.

However, please note that this will not affect the lawfulness of the

processing before its withdrawal nor, when applicable law allows, will it

affect the processing of your personal information conducted in reliance on

lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can

unsubscribe from our marketing and promotional communications at any

time by clicking on the unsubscribe link in the emails that we send, or by

contacting us using the details provided in the section "HOW CAN YOU

CONTACT US ABOUT THIS NOTICE?" below. You will then be removed

from the marketing lists. However, we may still communicate with you —

for example, to send you service-related messages that are necessary for

the administration and use of your account, to respond to service requests,

or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your

account or terminate your account, you can:

Log in to your account settings and update your user account.

Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete

your account and information from our active databases. However, we may

retain some information in our files to prevent fraud, troubleshoot problems,

assist with any investigations, enforce our legal terms and/or comply with

applicable legal requirements.

If you have questions or comments about your privacy rights, you may

email us at support@selleb.com.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile

applications include a Do-Not-Track ("DNT") feature or setting you can

activate to signal your privacy preference not to have data about your

online browsing activities monitored and collected. At this stage no uniform

technology standard for recognizing and implementing DNT signals has

been finalized. As such, we do not currently respond to DNT browser

signals or any other mechanism that automatically communicates your

choice not to be tracked online. If a standard for online tracking is adopted

that we must follow in the future, we will inform you about that practice in a

revised version of this privacy notice.

9. DO UNITED STATES RESIDENTS HAVE SPECIFIC

PRIVACY RIGHTS?

In Short: If you are a resident of California, you are granted specific rights

regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the

past twelve (12) months:

Category Examples Collected

A. Identifiers

Contact details, such as real name,

alias, postal address, telephone or

mobile contact number, unique

personal identifier, online identifier,

Internet Protocol address, email

address, and account name

YES

B. Personal information

as defined in the

California Customer

Records statute

Name, contact information,

education, employment, employment

history, and financial information

YES

C. Protected

classification

characteristics under

state or federal law

Gender and date of birth NO

D. Commercial

information

Transaction information, purchase

history, financial details, and payment

information

YES

E. Biometric information Fingerprints and voiceprints NO

F. Internet or other

similar network activity

Browsing history, search history,

online behavior, interest data, and

interactions with our and other

websites, applications, systems, and

advertisements

NO

G. Geolocation data Device location NO

H. Audio, electronic,

visual, thermal,

olfactory, or similar

information

Images and audio, video or call

recordings created in connection with

our business activities

NO

I. Professional or

employment-related

information

Business contact details in order to

provide you our Services at a

business level or job title, work

history, and professional

qualifications if you apply for a job

with us

NO

J. Education Information Student records and directory

information

NO

K. Inferences drawn

from collected personal

information

Inferences drawn from any of the

collected personal information listed

above to create a profile or summary

about, for example, an individual’s

preferences and characteristics

YES

L. Sensitive personal

Information NO

We will use and retain the collected personal information as needed to

provide the Services or for:

Category A - As long as the user has an account with us

Category B - As long as the user has an account with us

Category D - As long as the user has an account with us

Category K - As long as the user has an account with us

We may also collect other personal information outside of these categories

through instances where you interact with us in person, online, or by phone

or mail in the context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your

inquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, "HOW

DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers

pursuant to a written contract between us and each service provider. Learn

more about how we disclose personal information to in the section, "WHEN

AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes,

such as for undertaking internal research for technological development

and demonstration. This is not considered to be "selling" of your personal

information.

We have not disclosed, sold, or shared any personal information to third

parties for a business or commercial purpose in the preceding twelve (12)

months. We will not sell or share personal information in the future

belonging to website visitors, users, and other consumers.

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light"

law permits our users who are California residents to request and obtain

from us, once a year and free of charge, information about categories of

personal information (if any) we disclosed to third parties for direct

marketing purposes and the names and addresses of all third parties with

which we shared personal information in the immediately preceding

calendar year. If you are a California resident and would like to make such

a request, please submit your request in writing to us using the contact

information provided below.

If you are under 18 years of age, reside in California, and have a registered

account with the Services, you have the right to request removal of

unwanted data that you publicly post on the Services. To request removal

of such data, please contact us using the contact information provided

below and include the email address associated with your account and a

statement that you reside in California. We will make sure the data is not

publicly displayed on the Services, but please be aware that the data may

not be completely or comprehensively removed from all our systems (e.g.,

backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California

Consumer Privacy Act (CCPA), you have the rights listed below.

The California Code of Regulations defines a "residents" as:

(1) every individual who is in the State of California for other than a

temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is

outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain

rights and obligations regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to

delete your personal information, we will respect your request and delete

your personal information, subject to certain exceptions provided by law,

such as (but not limited to) the exercise by another consumer of his or her

right to free speech, our compliance requirements resulting from a legal

obligation, or any processing that may be required to protect against illegal

activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell or share personal information to third parties;

the categories of personal information that we sold, shared, or

disclosed for a business purpose;

the categories of third parties to whom the personal information was

sold, shared, or disclosed for a business purpose;

the business or commercial purpose for collecting, selling, or sharing

personal information; and

the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete

consumer information that is de-identified in response to a consumer

request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy

Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to

determine you are the same person about whom we have the information

in our system. These verification efforts require us to ask you to provide

information so that we can match it with information you have previously

provided us. For instance, depending on the type of request you submit, we

may ask you to provide certain information so that we can match the

information you provide with the information we already have on file, or we

may contact you through a communication method (e.g., phone or email)

that you have previously provided to us. We may also use other verification

methods as the circumstances dictate.

We will only use personal information provided in your request to verify

your identity or authority to make the request. To the extent possible, we

will avoid requesting additional information from you for the purposes of

verification. However, if we cannot verify your identity from the information

already maintained by us, we may request that you provide additional

information for the purposes of verifying your identity and for security or

fraud-prevention purposes. We will delete such additionally provided

information as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or

no longer relevant, or ask to restrict the processing of the

information.

You can designate an authorized agent to make a request under the

CCPA on your behalf. We may deny a request from an authorized

agent that does not submit proof that they have been validly

authorized to act on your behalf in accordance with the CCPA.

You may request to opt out from future selling or sharing of your

personal information to third parties. Upon receiving an opt-out

request, we will act upon the request as soon as feasibly possible,

but no later than fifteen (15) days from the date of the request

submission.

We will honor your opt-out preferences if you enact the Global

Privacy Control (GPC) opt-out signal on your browser.

To exercise these rights, you can contact us by submitting a data subject

access request, by email at support@selleb.com, or by referring to the

contact details at the bottom of this document. If you have a complaint

about how we handle your data, we would like to hear from you.

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant

with relevant laws.

We may update this privacy notice from time to time. The updated version

will be indicated by an updated "Revised" date and the updated version will

be effective as soon as it is accessible. If we make material changes to this

privacy notice, we may notify you either by prominently posting a notice of

such changes or by directly sending you a notification. We encourage you

to review this privacy notice frequently to be informed of how we are

protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at

support@selleb.com

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to

request access to the personal information we collect from you, change

that information, or delete it. To request to review, update, or delete your

personal information.