After, Inc. is committed to maintaining the privacy and security of personal information. This Privacy Policy Statement, together with our Terms of Service, contains information about our policy regarding the collection and use of data on our websites (“Sites”).

Effective Date: January 31, 2021

By using the Sites, you consent to the use of the information that you provide to us in accordance with this Privacy Policy. We do update this Privacy Policy from time to time so please review this Privacy Policy regularly. If we materially alter our Privacy Policy, we will notify you of such changes by posting a notice on our Site and/or contacting you at the e-mail address provided to us. Your continued use of the Sites will

be deemed your agreement that your information may be used in accordance with the new policy. If you do not agree with the changes, then you should stop using the Sites, and you should notify us that you do not want your information used in accordance with the changes.

By accessing and using the Sites, you agree that you have read and understood this Privacy Policy and that you accept and consent to the privacy practices and uses and disclosures of your information as described herein.

Please read this Privacy Policy carefully to fully understand:

1. What personal information is collected from you through the Sites.

2. How it is used and with whom it may be shared.

3. What choices are available to you regarding the use of your data.

4. The security procedures in place to protect your information.

Use of Cookies

For each visitor to our Sites, our web server automatically recognizes the visitor’s Internet domain, along with information about the visitor’s web browser. We may apply a “cookie” to the visitor’s computer, which he/she is free to accept or to decline. A cookie is a piece of data stored on a Site visitor’s hard drive. A cookie helps After, Inc. analyze visits to its Site and thereby improve the Site’s functionality and usability. Depending on the visitor’s web browser, a visitor may elect to block cookies from our Sites. After, Inc. employs no other identification tools on its website at this time, and we do not track visitors across time or across websites. We do not use flash cookies on our Sites.

Information We Collect

From Your Organization

From Individual Consumers

In operating our Sites on behalf of our customers, we may collect and process the following data about you:

• Details of your visits to our Sites and the resources that you access, including, but not limited to, traffic data, location data, web logs and other communication data, including your IP address, the date and time you accessed or left the Site(s), and which pages you viewed. Some parts of our Sites use cookies and other technologies to collect this information about your general internet usage. See section above “Use of Cookies” to learn more.
• If you are entering information related to a product warranty and/or registration, we may collect your name, address, telephone number, email address, details about the product and purchase information (e.g. purchase date, retailer).
• Our Site uses Google Analytics to collect certain information about our Site users such as session duration, pages per session, bounce rate, and source of the traffic.
• Information provided to us when you fill out forms on our Sites, including, but not limited to inquiries, survey information and/or site registrations.
• Information provided to us when you communicate with us for any reason.

If you have questions about how our customers (i.e. merchants, manufacturers, etc.) use your information, please review their privacy policy.

By submitting a telephone number to After, Inc. you agree that a representative of After, Inc. can contact you at the number you provide, potentially using automated technology (including texts/SMS messaging) or a prerecorded message. Your consent is not an obligation to receive any of our services.

Use of Your Information

Any information you submit through our Sites will primarily be used for After Inc.’s business purposes, including for example, to respond to your requests for information; make internal business decisions about the content we display on the Sites; to customize your visit to the Sites; to prevent, detect, and investigate security breaches; to contact you about offers from our company; to enable us to provide our services to you, and as otherwise disclosed at the point where such information

is collected. Personal information is safeguarded on secured systems and is used only for the purpose or purposes stated at the time of collection.

We may also use your information in order to:

• Provide third parties with statistical information about the visitors and/or users of our Site(s);
• To respond to law enforcement requests and as required by applicable law, court or governmental regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution 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 our Site users is among the assets transferred.
• To fulfill or meet the reason you provided the information. For example, if you share your name and email address in order to be contacted be a sales representative.
• To provide, support, personalize, and develop our Sites, products, and services.
• To create, maintain, customize, and secure your account with us.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Site experience and to deliver content and product and service offerings relevant to your interests.
• To help maintain the safety, security, and integrity of our Sites, products and services, databases and other technology assets, and business.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not use personal information we collected for materially different, unrelated, or incompatible purposes without providing you with notice and/or updating this Privacy Policy.

Unless you unsubscribe, we may contact you via e-mail in the future to tell you about specials, new products or services, or changes to this Privacy Policy.

The information provided by visitors to our Sites is not sold or traded to any outside party. We may share some of this information with our own vendor organizations for the marketing of our own services or to support After, Inc.’s operations. Only authorized After, Inc. employees, vendors, contractors or partners carrying out authorized business functions may access After, Inc. data. Vendors, contractors, or partners who have access to information in connection with providing services for After, Inc. are required to sign a written agreement to protect and secure our data. The agreement will require these third parties to keep the information confidential; they are not permitted to use this information for any purpose other than to carry out the services they are performing for After, Inc.

Security

After, Inc. is committed to protecting and securing your data and takes commercially suitable procedures to safeguard your personal information. Your data is stored on servers that are protected by firewalls and other appropriate security mechanisms.

No method of transmission over the Internet, nor method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security, and therefore, transmission of such data is entirely at your own risk.

Disclosing Your Information

Where applicable, we may disclose your personal information to any affiliated business entities or third parties necessary to provide our services to you, including, but not limited to, where applicable, our subsidiaries, our holding company and its other subsidiaries (if applicable), third parties involved in the administration and operation of our business and/or services, as well as to the entity for which a product and /or warranty is registered or market research is conducted.

We may also disclose your personal information to third parties:

• If required or permitted by law or court order;
• In the event of a sale, merger, liquidation, dissolution, reorganization or acquisition of After, Inc. or an After, Inc. business or business unit. However, the acquiring party would agree to be bound by the terms of the After, Inc. Privacy Policy before any information would be transferred.
• Where it relates to the administration and/or processing of your warranty or product registration;

As set forth above, where we disclose personal information for a purpose set forth herein, we enter a contract with the third party that describes the purpose and requires the third-party recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We do not sell your personal information to third parties.

Third Party Websites

By accessing third party websites through our Sites, you are consenting to the terms and privacy policies of those websites. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Users Only of Legal Age of Majority

Our Sites are designed and intended for those who have reached the age of majority (18 years of age). By using our Sites, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age.

No one under age 13 is authorized to submit or post any information, including personal information, on our Sites. Under no circumstances may anyone under age 13 use our Sites. Parents or legal guardians of children under 13 cannot agree to these terms on their behalf.

Other Privacy Policies

In addition to the general policy described on this page, additional provisions apply to certain visitors to our Sites.

For European Union Residents

Residents of countries covered under EU Privacy Shield agreements should review After, Inc.’s Privacy Shield Privacy Policy. It describes After, Inc.’s commitment to Privacy Shield principles, as well as information on how to contact After, Inc.

Collection and export of data for the provision of the Services is governed by the Data Processing Addendum.

For California Residents

If you reside in California and have provided personal information to us, you may request information about our disclosure of certain categories of personal information to third parties for their direct marketing purposes under California’s Shine the Light law. Such requests must be submitted to us using one of the contact methods below.

If you are a resident of California, effective January 1, 2020, you have the following rights under the California Consumer Privacy Act of 2018 (“CCPA”):

1. to know what categories of personal information about you we have collected and used, including how the personal information was collected;

2. to know what categories of personal information are being sold (if at all) or disclosed and if it is being sold or disclosed to third   parties and a list of categories of information that are sold;

3. to opt out of the sale of your personal information, if applicable;

4. to access your personal information, including the right to download or transfer personal information collected during the previous 12 months (click here for more information on “Access to Specific Information and Data Portability Rights”);

5. to request that your personal information be deleted (click here for more information on “Deletion Request Rights”); and

6. to equal service and equal price for goods or services even if you exercise your rights under the CCPA.

While California residents have the right to opt out of the sale of their personal information under CCPA, we do not sell personal information to any third parties, and therefore, we have not included a “Do Not Sell My Personal Information” link on our Site. If our practices change, we will update this Privacy Policy and take any other necessary action to comply with applicable law.

If you are a California resident and you want to exercise any of your rights as set forth above, please contact us at (800).374.4728. or privacy@afterinc.com. For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request,

describe the nature of your request, and provide your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response. For more information click here:

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

NOTE: If you are located in Canada, the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which After, Inc. or its parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

Accessibility Statement

We are committed to making sure that our Sites are accessible to everyone. To access this Privacy Policy in an alternative form, please call us at (800).374.4728.

Questions, Complaints or Concerns

If you have any queries, comments, complaints or requests regarding this Privacy Policy please do not hesitate to contact us at:

After, Inc.
Attention: CTO
1 Selleck St., 5th Fl.
Norwalk, CT 06855 USA

or e-mail us at privacy@afterinc.com.
We can also be reached by telephone at (800)374.4728.