Way2B1 Privacy Policy

Posted: February 2016

Thanks for using Way2B1! Here we describe how we collect, use and handle your information when you use our websites, software and services ("Services").

What & Why

We collect and use the following information to provide, improve and protect our Services:

Account. We collect, and associate with your account, information like your name, email address, phone number, payment info, and physical address. Some of our services let you access your accounts and your information with other service providers.

Services. When you use our Services, we store, process and transmit your files (including, but not limited to, your photos, emails, legal documents, insurance policies, financial information, real estate information, collectibles information, yacht, vehicle and aircraft information, HR information) and information related to them (for example, location tags in photos, who uploaded the document, when it was last accessed and by whom). If you give us access to your contacts and calendar events we'll store those contacts and events on our servers for you to use. This will make it easy for you to do things like share your information, send emails, and invite others to use the Services and interact with your vendors who maintain information on the site for you.

Usage. We collect information from and about the devices you use to access the Services. This includes things like IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services. We use this aggregated information in the administration of our website to improve its usability and to evaluate the success of particular features of the Service. We use non­identifying and aggregated information to help optimize our website based on the needs of our users. No personal or personally identifiable information about any individual user is collected.

Cookies and other technologies. We use technologies like cookies and pixel tags to provide, improve, protect and promote our Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services, and improving them based on that information. You can set your browser to not accept cookies, but this may limit your

ability to use the Services. These anonymous data are aggregated for analysis to ensure proper functioning of our site, in terms of navigation and usability, as well as to evaluate the effectiveness of our marketing efforts. We also use cookies to track your activity on our site as a unique person. We use session ID cookies to make it easier for you to navigate our site. Session ID cookies expire when you close your browser. We use a persistent cookie that remains on your hard drive for an extended period of time, so that we can recognize you when you return to our website. You can remove persistent cookies by following directions provided in your Internet browser's "help" file; however, because we use cookies for our sign­in functionality, if you choose to disable cookies you will not be able to log on to the Way2B1 website. All of this information is stored in an encrypted fashion for security reasons, and no personal information about you is stored.

With whom

We may share information as discussed below, but we won't sell it to advertisers or other third­parties.

Others working for Way2B1. Way2B1 uses certain trusted third parties to help us provide, improve and protect our Services. These third parties will access your information only to perform tasks on our behalf and in compliance with this Privacy Policy.

Other users within your organization. Our Services display information like your name and email address to other users in places like your user profile and sharing notifications. Your organization consists of any user granted access by you to the Service. Certain features let you make additional information available to other users. All sharing and notifications are configurable and in your control.

Other applications. You can also give third parties access to your information and account. Please remember that their use of your information will be governed by their privacy policies and terms.

Way2B1 Administrators. Your Way2B1 administrators may have the ability to access and control your Way2B1 account. Please refer to your employer's internal policies if you have questions about this. If you are not a Way2B1 administrator but interact with a Way2B1 administrator (by, for example, joining a shared folder or accessing information shared by that user), members of that organization may be able to view the name, email address and IP address that were associated with your account at the time of that interaction. Our policy is to only access your data when required to provide user support and improve quality of service.

Law & Order. We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of Way2B1 or our users; or (d) protect Way2B1's property rights. We will notify you of such requests, unless prohibited by law.

Stewardship of your data is critical to us and a responsibility we take seriously. It is our policy to strive for the right balance between protecting our clients and complying with legal requests. We'll abide by the following Government Request Principles when receiving, scrutinizing and responding to government requests for our users' data:

Fight blanket requests,

Protect all users, and

Provide trusted services.

How

Security. We have internal team members and external consultants and service providers dedicated to keeping your information secure and testing for vulnerabilities. We also continue to work on features to keep your information safe in addition to things like two­factor authentication, and alerts when new devices and apps are linked to your account.

Retention. We'll retain information you store on our Services for as long as we need it to provide you the Services. If you delete your account, we'll also delete this information. Note: (1) there might be some latency in deleting this information from our servers and backup storage; and (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

Where

World Wide. To provide you with the Services, we may store, process and transmit information in locations around the world ­ including those outside your country. Information may also be stored locally on the devices you use to access the Services.

Changes

If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

We may revise this Privacy Policy from time to time, and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.

Contact

Have questions or concerns about Way2B1, our Services and privacy? Contact us at feedback@way2b1.com.