Privacy Statement Effective as of May 10, 2017

Palm Labs LLC (DBA “Digital Compass” or the “Company”) is committed to protecting the privacy of your information. This Privacy Statement describes Digital Compass’ information practices

Nothing is more important to Digital Compass than preserving the integrity of our products and services. All direct contact information and professional inquiries are used only to process your request.

Please take a moment to review our current Privacy Policy. As always, if you have any questions or concerns, please contact us directly at: [email protected]

1. Web Sites Covered

Digital Compass Privacy Policy applies to https://www.digitalcompass.com and http://www.dcdial.net.

Digital Compass’ Web sites may contain links to other Web sites. Digital Compass is not responsible for the information practices or the content of such other Web sites. The Company encourages you to review the privacy statements of other Web sites to understand their information practices.

2. Personal Information Collected

Digital Compass offers a variety of services that are collectively referred to as the “Service.” Digital Compass collects information from individuals who visit the Company’s Web sites (“Visitors”) and individuals who register to use the Service (“Customers”).

When expressing an interest in obtaining additional information about the Service or registering to use the Service, Digital Compass requires you to provide the Company with contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Service, Digital Compass requires you to provide the Company with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Service (“Billing Information”). Digital Compass may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information are referred to collectively as “Data About Digital Compass Customers.”

As you navigate the Company’s Web sites, Digital Compass may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked).

3. Use of Information Collected

The Company uses Data About Digital Compass Customers to perform the services requested. For example, if you fill out a “Contact Me” Web form, the Company will use the information provided to contact you about your interest in the Service.

The Company may also use Data About Digital Compass Customers for marketing purposes. and to send you information regarding the Company and its partners, such as information about promotions or events.

Digital Compass uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information in combination with Data About Digital Compass Customers to provide personalized information about the Company.

4. Web Site Navigational Information

Digital Compass uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”) . This section describes the types of Web Site Navigational Information the Company may collect and how the Company may use this information.

Cookies

Digital Compass uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web sites, Digital Compass’ servers send a cookie to your computer. Standing alone cookies do not personally identify you, they merely recognize your Web browser. Unless you choose to identify yourself to Digital Compass, either by responding to a promotional offer, opening an account, or filling out a Contact or Inquiry Form, you remain anonymous.

There are two types of cookies: session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer.

If you have chosen to identify yourself to Digital Compass, the Company uses session cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the Service, a session cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These session cookies allow the Company to uniquely identify you when you are logged into the Service and to process your online transactions and requests. Session cookies are required to use the Service and the Company does not recognize do-not-track requests with respect to Session cookies.

Digital Compass uses persistent cookies that only the Company can read and use to identify browsers that have previously visited the Company’s Web sites. When you purchase the Service or provide the Company with personal information, however, a unique identifier is assigned you. This unique identifier is associated with a persistent cookie that the Company places on your Web browser and this cookie does not respond to do-not-track requests. The Company is especially careful about the security and confidentiality of the information stored in persistent cookies. For example, the Company does not store account numbers or passwords in persistent cookies.

Digital Compass may use information from session and persistent cookies in combination with data about Digital Compass Customers to provide you with information about the Company and the Service.

Third Party Cookies

From time-to-time, Digital Compass engages third-parties to track and analyze non-personally identifiable usage and volume statistical information from individuals who visit the Company’s Web sites. Digital Compass may also use other third-party cookies to track the performance of Company advertisements. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after the Company receives it. This Privacy Statement does not cover the use of third party cookies, as Digital Compass does not control the cookies potentially used by third parties.

Web Beacons

Digital Compass uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Website tied to the Web beacon, and a description of a Web site tied to the Web beacon. For example, Digital Compass may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. Digital Compass uses Web beacons to operate and improve the Company’s Web sites and email communications. Digital Compass may use information from Web beacons in combination with Data About Digital Compass Customers to provide you with information about the Company and the Service.

IP Addresses

When you visit Digital Compass Website, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personally identifiable information. For example, Digital Compass uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites.

Digital Compass also collects IP addresses from Customers whey they log into the Service as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features

5. Public Forums, Refer a Friend, and Customer Testimonials

Digital Compass may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personally identifiable information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Digital Compass is not responsible for the personally identifiable information you choose to submit in these forums.

Digital Compass may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personally identifiable information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Digital Compass is not responsible for the personally identifiable information you choose to submit in these forums.

Digital Compass posts a list of Customers and testimonials on the Company’s Web sites that contain information such as Customer names and titles. Digital Compass obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

6. Sharing of Information Collected

Digital Compass may share Data About Digital Compass Customers with the Company’s agents so that these agents can contact Customers and Visitors who have provided contact information on our behalf. Digital Compass may also share Data About Digital Compass Customers with the Company’s agents to ensure the quality of information provided. Digital Compass does not share, sell, rent, or trade personally identifiable information with third parties for their promotional purposes.

Digital Compass uses a third-party intermediary to manage credit card processing. This intermediary is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.

Digital Compass reserves the right to disclose personally identifiable information of the Company’s Customers or Visitors if required by law or if the Company reasonably believes that disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

7. Communications Preferences

Digital Compass offers Customers and Visitors who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may send a request specifying your communications preferences to [email protected] Customers cannot opt out of receiving transactional emails related to their account with Digital Compass or the Service.

8. Correcting and Updating Your Information?

Customers may update or change their registration information by editing their user or organization record. To update a user profile, please login to https://www.dcdial.net and navigate to “Users” under the Administration tab. To discontinue your account and to have information you maintained in the Service returned to you, please email [email protected] Requests to access, change, or delete your information will be handled within 30 days.

9. Customer Data

Digital Compass Customers use the Service to host data and information (“Customer Data”). Digital Compass will not review, share, distribute, or reference any such Customer Data except as may be required by law. Individual records of Customer Data may be viewed or accessed only for the purpose of resolving a problem, support issues, or suspected violation of the Digital Compass Terms of Service, or as may be required by law. Customers are responsible for maintaining the security and confidentiality of their Digital Compass usernames and passwords.

10. Security

Digital Compass uses robust security measures to protect Customer Data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Customer Data. When the Service is accessed, our Secure Socket Layer (“SSL”) technology protects Customer Data using both server authentication and data encryption. These technologies help ensure that Customer Data is safe, secure, and only available to the Customer to whom the information belongs and those to whom the Customer has granted access. Digital Compass also implements an advanced security method based on dynamic data and encoded session identifications, and the Company hosts its Web sites in a secure server environment that uses firewalls and other advanced technology to prevent interference or access from outside intruders. Digital Compass also offers enhanced security features within the Service that permit Customers to configure security settings to the level they deem necessary.

Because the Company uses the Service to maintain Data About Digital Compass Customers, this information is secured in the same manner as described above for Customer Data.

11. Changes to this Privacy Statement

Digital Compass reserves the right to change this Privacy Statement. Digital Compass will provide notification of the material changes to this Privacy Statement through the Company’s Web sites at least thirty (30) business days prior to the change taking effect.

12. Contacting Us

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to Digital Compass Privacy by emailing [email protected]. or calling us directly at (888) 878-1011.