PRIVACY POLICY

WELCOME TO SENECA ESG

Thank you for visiting Seneca ESG! We are a business intelligence platform (collectively the “Site”) delivering solutions for corporate sustainability assessment, reporting, and integration with financial services (“Services”). This Privacy Policy describes how Seneca ESG collects, uses and discloses information, and what choices you have with respect to the information. This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Seneca ESG platform, or any other third-party products, services or businesses.

INFORMATION WE COLLECT

We are committed to respecting your privacy and recognize your need for appropriate protection and management of any personally identifiable information you share with us. When you interact with us through the Services, we collect certain information from you when you voluntarily provide such information (for example, when you register for access to our Services). Such ‘Personal Information’ we collect may include, but is not limited to, a first and last name, country of citizenship, phone number, physical address, email address, work experience, IP address, company name and position, or other contact information that we may request to comply with regulatory requirements. We may use your email address account to send updates, newsletter or news regarding our services.

HOW WE DISCLOSE AND SHARE INFORMATION

Seneca ESG is not in the business of selling your information. We consider your information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your information with certain third parties, as set forth below:

• Customer’s Instructions: Seneca ESG will share and disclose customer information in accordance with a customer’s instructions, including any applicable terms in any customer agreements and customer’s use of Services, and in compliance with applicable law and legal process.

• Third Party Technologies: We may use third party analytic and automation tools (such as Google Analytics and MailChimp) which may employ web cookies to collect certain information concerning your use of our Services. As discussed above, you may disable web cookies by changing your browser setting. You may see our Service advertised in other applications or websites who may collect information for optimizing their needs. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by our Privacy Policy. Using a tool created by the Network Advertising Initiative, you can opt out of several third-party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the following link: http://optout.networkadvertising.org/.

• Corporate Affiliates: Seneca ESG may share your information with its corporate affiliates, parents and/or subsidiaries.

• During a Change to Seneca’s Business: If Seneca ESG engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Seneca’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), a portion of or all of your information may be shared or transferred, subject to standard confidentiality arrangements.

• Aggregated Information: In an ongoing effort to better understand and serve the users of our Services, we may conduct internal research on our customer demographics, interests and behavior based on the information collected. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes. For example, we may share aggregated or de-identified information with prospects or partners for business or research purposes, such as telling a prospective Seneca customer the average amount of users within a certain geographical location.

• To Comply with Laws: If we receive a request for information, we may disclose your Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.

• To enforce our rights, prevent fraud, and for safety: To protect and defend the rights, property or safety of Seneca ESG or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

• Web Cookies: A ‘Web Cookie’ is a string of information that a website stores on a user’s computer that the user’s browser provides to the website each time the user uses the site. We may employ cookies and similar technologies to keep track the pages that users visit during visits to our web and mobile sites, both to help us improve users’ experiences and to help us understand how our Service is being used. Users who do not wish to have web cookies placed on their computers should set their browsers to refuse web cookies before accessing our web and mobile sites, with the understanding that certain features of the site may not function properly without the aid of web cookies. Users who refuse web cookies assume all responsibility of any resulting loss of functionality.

• With Consent: Seneca ESG may share your Information with third parties when we have consent to do so.

OUR LEGAL BASIS FOR HANDLING YOUR PERSONAL DATA

Seneca ESG is a controller of customer data and we use the information you provide in a manner that is consistent with this Privacy Policy. Seneca ESG uses your information in furtherance of our legitimate interest in operating our Services. Specifically, we may use your information to:

• To provide, update, maintain and protect our Services and business: This includes use of your Information to support delivery of the Services under an express or implied customer agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an authorized user’s request.

• To communicate with you by responding to your requests, comments and questions: If you contact us, we may use your information to respond.

• To develop and provide tools and additional features: Seneca ESG continually strives to improve its Services to be as useful as possible for authorized users. For example, we may improve our Service functionality by using your information to help determine and rank the relevance of content, channels or expertise to an authorized user, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, or to customize a Services experience or create new productivity features and products.

• To send emails and other communications: We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Seneca ESG. These are marketing messages so you can control whether you receive them (aka “opt-out” of). If at any time you wish not to receive any future marketing communications or you wish to have your personal information deleted from or mailing lists, please contact us at info@senecaesg.com

• To maintain internal servers: Seneca ESG operates severs located in various global regions, and in some instances, when a user clicks links on the website, they may be redirected from one internal Seneca server to another and/or certain data may be transferred from one internal server to another internal server for the purpose of allowing the user to in order to access the information they seek.

• For billing, account management and other administrative matters: Seneca ESG may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.

• As required by applicable law, legal process or regulation

• To investigate and help prevent security issues and abuse

AGE LIMITATION

To the extent prohibited by applicable law, Seneca ESG does not knowingly collect personal information from children under the age of 13. If you learn that anyone younger than 13 has unlawfully provided us with personal data, please contact us at info@senecaesg.com and we will take steps to delete such information.

DATA RETENTION

We generally retain personal data for so long as it may be relevant to the purposes identified herein. To dispose of personal data, we may anonymize it, delete it, or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

YOUR DATA RIGHTS AND CHOICES

Individuals located in certain countries have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you have the right to request access to your personal information, as well as to seek to update, delete, restrict the use of, or correct this information. You can usually do this using the settings and tools provided in your Services account. You may also click the “unsubscribe” link in any of our marketing materials. If you cannot use the settings and tools or have any issues or questions, please contact our customer support at info@senecaesg.com for additional access and assistance.

CHANGES TO THIS PRIVACY POLICY

Seneca ESG may change this Privacy Policy from time to time as laws, regulations and industry standards evolve, or we may make changes as our business and operations develop. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, SenecaESG will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, we encourage you to contact us at info@senecaesg.com to speak to our Data Protection Officer, and (in the case no solution can be reached) you should deactivate your Services account.

CONTACTING US

Please also feel free to contact us at any time if you have questions about this Privacy Policy or the information practices of the Services. You may reach us at info@senecaesg.com.