Effective date: October 13, 2023

NatureNeutral, Inc. d.b.a. Klerra (“Klerra”, “we”, “us”, or “our”) respects your privacy and is committed to protecting it as set forth in this privacy policy (“Privacy Policy”). This Privacy Policy applies to personal data collected on our website located at https://www.klerra.com (the “Website”) and any other personal data we may process in connection with our products, services, or otherwise (collectively, together with the Website, the “Services”). This Privacy Policy describes our privacy practices in connection with our Services, including the personal data we collect, how we use personal data and our legal basis for such use, who we may disclose personal data to, and certain rights you may have regarding your personal data. By using the term “personal data” in this Privacy Policy, we mean any information that can be used to identify you.

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Changes to Our Privacy Policy

We may change this Privacy Policy at any time. The most recent version of the Privacy Policy is reflected by the effective date at the top of this Privacy Policy. All amendments to this Privacy Policy will be effective immediately upon providing notice thereof, which we may give by any means, including by posting a revised version of the Privacy Policy on the Website.

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Personal Data Collection

Klerra collects the following categories of personal data directly from you:

• Name;
• Username;
• Email address;
• Telephone number;
• Employment information (i.e., company name and title); and
• Any other personal data you may choose to provide to us.

We may also collect the above categories of personal data when you:

• Request a demo;
• Subscribe to marketing communications;
• Contact us via our Services (or otherwise); or
• Register for a new account or log into an existing account.

We may also collect the above categories of personal data when you:

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Cookies

When you visit our Services, Klerra and our third-party service providers may utilize cookies. A "cookie" is a text file that websites send to a visitor's device to uniquely identify the visitor's device or to store information or settings in the visitor's device. Through utilizing cookies, we may collect information about how you interact with the Services. This may include information such as the dates and time you visit the Services, referring and exit URLS, how you interact with the Services, your browser type, and the domain name of your internet service provider. We may also collect information about the devices you use to access the Services, including your device make and model, IP address, geolocation information, operating system, and other unique device identifiers.

If you choose not to accept certain cookies, you may not have access to certain features of the Services. Your browser may be configured to reject cookies or notify you when a cookie is set. Certain state laws require that we indicate whether we honor "Do Not Track" settings in your browser concerning online tracking. We adhere to the standards set out in this Privacy Policy and do not monitor or follow any "Do Not Track" browser requests.

In particular, Klerra uses Google Analytics, a web analysis service provided by Google, and Hubspot Analytics, a web analysis service provider by Hubspot, to better understand your use of the Services. Google Analytics and Hubspot Analytics use cookies to collect certain information such as how often you visit our Services, how you interact with our Services, and what other websites you used prior to coming to our Services.

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Purpose of Personal Data Processing and Legal Basis

Klerra uses the personal data we collect for the purposes set out in the table below. We have also set out our "legal basis" for each of these uses.

Personal Data Disclosure

Klerra may disclose all the categories of your personal data that we collect to the following categories of recipients:

• with our affiliates, which includes other businesses that are under common control with us or under our control;
• with our business partners and service providers to provide business services for the purposes set out above, which include our website provider and designer, customer relationship management platform, analytics provider, and scheduling partner;
• with professional advisors such as lawyers, auditors, bankers, and insurers, in the course of the professional services that they render to us;
• where required by law with law enforcement agencies, regulators, courts, other government authorities, or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party; or
• in the context of a transaction with potential transaction partners, service providers, advisors, and other third parties, such as in connection with a merger, asset sale, financing, liquidation, bankruptcy, or dissolution.

In addition, if you are an implementation partner, we may display your contact information (which may contain personal data) via our Services.

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Personal Data Transfer

Klerra is based in the United States, where we provide our Services from. Where we provide our Services to organizations based outside of the United States, we and our business partners and service providers take commercially reasonable efforts to put in place appropriate safeguards to personal data (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protection for any transferred personal data.

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Personal Data Rights

Depending on where you reside, you may have certain rights under applicable data privacy law. These may include the:

• Right to access or know: You may have the right to know what personal data we process about you.
• Right to delete or erase: You may have the right to delete your personal data in certain circumstances.
• Right to correct/rectify/update: You may have the right to correct personal data that we hold about you.
• Right to data portability: You may have the right to receive your personal data in a machine-readable or portable format.
• Right to restrict processing: Under some circumstances, you may request to restrict our use of your personal data.
• Right to withdraw consent: If your personal data is processed by us on the legal basis of consent, you may withdraw your consent. Withdrawing your consent will not affect the lawfulness of processing we conducted prior to such withdrawal, nor will it affect the processing of your personal data conducted in reliance of a legal basis other than consent.
• Right to lodge a complaint: If you have a complaint about how we use your personal data, we hope that you will contact us according to the below. However, you can always file a complaint with the data protection authority in your jurisdiction. For more information, please contact your local data protection authority (contact details for data protection authorities in the EEA are available at https://edpb.europa.eu/about-edpb/board/members_en. Contact details for the data protection authority in the UK is available at https://ico.org.uk/.

If you would like to exercise any of these rights, please send us an email at privacy@klerra.com. Please note that we may require additional information from you to verify your request or that you are authorized to act on the behalf of another, which may consist of identifiers or service history already known to or collected by us.

NatureNeutral, Inc. is the "controller" responsible for the personal data we process. We do not engage in automatic decision-making.

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Personal Data Safeguards

Klerra takes commercially reasonable measures to protect the personal data we collect from you from unauthorized or illegal access, modification, use, or destruction. We restrict access to such personal data to employees, contractors, and agents who need to know such information and only to third parties as described in the "Personal Data Disclosure" section of this Privacy Policy. Nevertheless, no security system or website is impenetrable. We cannot guarantee that your personal data will be secure.

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Personal Data Retention

Klerra will only keep your personal data for so long as we have a legitimate business purpose for retaining that personal data. When deciding how long to keep your personal data after our relationship has ended, we may retain some personal data for limited purposes, such as our legal compliance or to enforce or defend our legal rights.

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Children's Personal Data

Our Webpage is intended for a general audience and is not intended for use by children. We do not knowingly collect information about children or sell products to children. Consistent with the Children's Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13.

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Contact Us

If you have any questions regarding this Privacy Policy or our privacy practices or wish to exercise any of your rights described above, please contact us at privacy@klerra.com.

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