Privacy Policy

This Privacy Policy describes the policies and procedures of AlfaTech (“AlfaTech”, “we” or “us”) on the collection,
use and disclosure of personal information from those who use or access our website, located at
https://www.atce.com/ and related mobile sites that expressly adopt and display or link to this Privacy Policy
(collectively, the “Site”), as well as our branded pages on social media sites (our “Social Media Pages”), and any
emails, text messages or other electronic messages between you and us (collectively, the “Services”).

NOTE: This Privacy Policy does not apply to information collected by the websites, mobile sites, mobile applications
or social media sites of any third parties, including any of our affiliates, even if such websites are linked to or
accessible from our Services. These third parties have separate and independent privacy policies which we recommend
you read carefully.  It also does not address Personal Information that has been de-identified and aggregated.

Consent

When you visit the Site or otherwise use the Services, you are consenting to the terms of this Privacy Policy. If
you do not agree with our policies or practices, your choice is not to use the Services.

This Privacy Policy answers the following questions:

  • What information do we collect about you?
  • How do we use the Personal Information we collect about you?
  • Do we share your information with third parties?
  • What Other Information about you do we collect?
  • How do we collect, use and disclose Other Information about you?
  • What choices do you have over how we use and disclose your Personal
    Information?
  • How do we secure your Personal Information on the Services?
  • How can you access, update, correct or delete your Personal
    Information?
  • Does this Privacy Policy cover the privacy, information, or other
    practices of any third parties?
  • What is the retention period for the Personal Information collected?
  • Who may use the Services?
  • Will this Privacy Policy change?
  • How can you contact us?

1. What information do we collect about you?

“Personal Information” is information that identifies you as an individual or relates to an identifiable
individual. We and our service providers may collect and combine Personal Information about you from a variety
of sources, including through the Services. For example, we collect Personal Information when you sign up for
newsletters, marketing emails and other commercial electronic messages (e.g., on upcoming promotions, new
products, etc.), correspond with us, or access our Services or Social Media Pages. Personal Information does not
include information derived from Personal Information that has been de-identified and aggregated.

We generally collect the following types of Personal Information:

  • Your Name
  • Company Mailing address
  • Project site address
  • Role and/or title at your company
  • Email address
  • Telephone number
  • Mobile phone number
  • Postal/zip code, state/province, and country
  • Username and password (related to your account)
  • Information related to customer satisfaction surveys, customer requests
    or queries

2. How do we use the Personal Information we collect about you?

The Personal Information we collect from you helps us provide our Services, personalize your experience with us
and our communications to you, and improve your experience with our Services. You may choose not to provide us
with certain requested information, but then you might not be able to take advantage of some of our Service
features or we may not be able to provide you with the Services.

We and our service providers use the Personal Information collected above for purposes including:

  • Presenting the Services and its contents to you.
  • Responding to your inquiries and fulfilling your requests for example
    when you contact us via one of our online contact forms.
  • Sending administrative information to you, such as changes to our terms,
    conditions and policies, including this Privacy Policy.
  • Allowing you to send messages to another person if you choose to do
    so.
  • Fulfilling any other purpose for which you provide Personal
    Information.
  • In any other way we may describe when you provide the Personal
    Information.
  • For any other purpose with your consent.
  • We will engage in these activities to manage our contractual
    relationship with you, and/or to take steps at your request prior to entering into a contract, and/or to
    comply with a legal obligation.
  • Providing you with our newsletter and/or other marketing materials and
    facilitating social sharing.
  • To send you advertising and marketing related emails with information
    about our Services and other news about our company. If you do not want to receive additional marketing
    emails, click the “unsubscribe” link included in each of these emails.
  • To facilitate social sharing functionality that you choose to use.

Analyzing of Personal Information for business reporting and providing personalized services.

  • To better understand you, so that we can personalize your experiences
    when using our Services and provide you with information and/or offers tailored to your interests.
  • To better understand your preferences so that we can deliver content via
    our Services that we believe will be relevant and interesting to you.

Otherwise accomplishing our business purposes.

  • For data analysis, for example, to improve the efficiency of our
    Services.
  • For audits, to verify that our internal processes function as intended
    and are compliant with legal, regulatory or contractual requirements.
  • For fraud and security monitoring purposes, for example, to detect and
    prevent cyberattacks or attempts to commit identity theft.
  • For improving and developing our products and Services.
  • For enhancing, improving, or modifying our current Services.
  • For identifying usage trends, for example, understanding which parts of
    our Services are of most interest to users.
  • For determining the effectiveness of our promotional campaigns, so that
    we can adapt our campaigns to the needs and interests of our users.
  • For operating and expanding our business activities, for example,
    understanding which parts of our Services are of most interest to our users so we can focus our energies
    on meeting our users’ interests.
  • For carrying out our obligations and enforcing our rights arising from
    any contracts entered into between you and us, including for billing and collection.

3. Do we share your information with third parties?

We do not sell, rent, or trade your Personal Information to unrelated third parties. Our affiliates and
third-party service providers obtain personal information in order to perform tasks on our behalf such as the
following:

  • Providing and improving our communications with you
  • Responding to requests to our investor relations
  • Improving our Services, including through analytics
  • As required to cooperate with a subpoena, search warrant or other
    legally valid inquiry, court order or other legal process, or as required or permitted by law to protect
    the rights, property, security or safety of the Services, our users or others, including where necessary
    for the establishment, exercise or defense of legal claims (including to enforce or apply the AlfaTech
    Terms of Use, or other agreements or contracts, including for billing and collection purposes) to
    fulfill the purpose for which you provide it for any other purpose disclosed by us when you provide the
    information with your consent.

AWe may share your Personal Information if we were ever merged with or acquired by another company, or if we
acquire another business entity or are involved in a corporate reorganization or other change of control, or if
we sell our assets or the assets of our affiliate or subsidiary, or are involved in a restructuring,
reorganization, dissolution or other sale or transfer of assets, whether as a going concern or as part of a
bankruptcy, liquidation or similar proceeding.

We may share certain information that is not Personal Information (including certain Other Information) with
third parties, including as follows: aggregate data about our sales, customers, traffic patterns, and other
related Services information with third parties, as described in “How do we use the Personal Information we
collect about you?”.

4. What Other Information about you do we collect?

As you navigate through and interact with the Services, we may use automatic data collection technologies to
collect certain Other Information about your equipment, browsing actions and usage patterns. Some Other
Information may be Personal Information.

“Other Information” includes: browser type and version, operating system, IP address, GPS coordinates or other
location information, Internet service provider used to access our Services, links used to arrive at our
Services and the IP address from which you arrived, web pages requested and viewed, time spent on our Services,
technical information about the device used (such as screen size, cookie support by the device and how images
may appear), the App usage data, other information collected through cookies, pixel tags, and other
technologies.

Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may
be identified and logged automatically in our server log files whenever a user accesses the Services, along with
the time of the visit and the page(s) that were visited.

Collecting IP addresses is standard practice and is done automatically by many websites, applications and other
services.

5. How do we collect, use and disclose Other Information about you?

We and our service providers collect Other Information in a variety of ways, including:

Through your browser or device: Certain information is collected by most browsers or automatically
through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), IP
address, screen resolution, operating system name and version, device manufacturer and model, language, Internet
browser type you are using.

We use this information to deliver a better service and to ensure that the Services function properly, including
by estimating our audience size and usage patterns, diagnose server problems and store information about your
preferences so that we can customize the Services to your individual interests and recognize you when you return
to the Services.

Physical Location Information: Our Services and emails use your IP address to determine the postal code
where you are located when you open the email. This allows us to tailor content to you. The specificity of the
location can vary depending on the device used to open our emails. Your email program may allow you to prevent
the pixel tags or images in the emails you receive from us from downloading, which will also prevent our service
provider from accessing your location information. You can also unsubscribe from receiving our emails, by
sending an email to marketing@atce.com

Cookies, pixel tags, web beacons and other similar technologies: We and our third-party service
providers use cookies, which are small text files that contain a unique identification to your device and are
typically stored directly on your device by your web browser. These are used for such purposes as: security, to
facilitate navigation, to display information more effectively, and to personalize your experience, to tailor
email marketing to you based on your use of the Services, determine return visitors, keep track of items in your
cart, and serve tailored advertisements on other sites.

Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and
display them while you are on the Services and on other sites. We may also use cookies or other similar
technologies in online advertising to track responses to our advertisements and measure the effectiveness of our
advertising.

We may also use pixel tags (also known as web beacons, web bugs, and clear GIFs) in providing the Services. A
pixel tag is a nearly invisible pixel-sized graphic image on a webpage or in an email message. We use these
technologies to, among other things, track the actions of users of the Services (including email recipients),
measure the success of our marketing campaigns, measure which parts of the Services are most visited or used,
and compile statistics about usage of the Services and response rates.

We also gather statistical information about use of the Services in order to continually improve their design and
functionality, to improve and better transact business, to understand how Services are used, measure which parts
of the Services are most visited or used, monitoring the number of visitors to the Services, and assist us with
resolving questions regarding the Services.

Our systems may not recognize “Do Not Track” headers from some or all browsers. If you do not want information
collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the
choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish
to refer to http://www.allaboutcookies.org/manage-cookies/. If, however, you do not accept cookies, you may
experience some inconvenience in your use of the Services. You also may not receive advertising or other offers
from us that are relevant to your interests and needs.

Third-party analytics: We use third-party analytics providers, such as Google® Analytics, which uses
cookies and similar technologies to measure traffic and usage trends, and to help us better understand your use
of and interaction with our Services. This service may also collect information regarding the use of other
websites, apps and online resources. For more information on how Google uses data when you use our Services,
click here, and opt out of Google’s practices by downloading the Google Analytics opt-out browser add-on,
available here. https://tools.google.com/dlpage/gaoptout

To the extent we are required to treat Other Information as Personal Information under applicable law, then we
may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in “What
choices do you have over how we use and disclose your Personal Information?”.

6. What choices do you have over how we use and disclose your Personal Information?

We give you choices about the information we collect and how we communicate with you and use and disclose your
information

Email: You may opt-out of our marketing emails by following the instructions listed in the email that
you received. However, even if you opt-out you may still receive non-marketing emails, such as order
confirmations, changes to service or customer service communications.

Postal Marketing: If you no longer want to receive marketing materials from us via regular postal mail,
please contact us at marketing@atce.com and tell us that you want to be removed from the our postal mailing
list, including the postal address you wish to have removed.

Cookies: You may set your web browser to notify you when you visit a website that uses cookies or to
not accept certain cookies. However, if you decide not to accept cookies from our Services, you may not be able
to take advantage of all of the features of our Services.

We will try to comply with your request(s) as soon as reasonably practicable

How do we secure your information on the Services?

We designed our applications to accept traffic only from Web browsers that permit communication through Secure
Socket Layer (SSL) technology, which encrypts your information while it is being transmitted to us. While we
implement the above security measures on the Site, we do not guarantee or warrant that such techniques will
prevent unauthorized access to information about you that we store, and you should be aware that 100% security
is therefore not always possible. We also have implemented other reasonable technical, administrative and
physical measures designed to protect the Personal Information in our custody or control from unauthorized
access, use, modification and disclosure.

8. How can you access, update, correct or delete your Personal Information?

If you would like to delete Personal Information previously provided to us, you can do this by emailing us at
marketing@atce.com Please note that we may need to retain certain information for record keeping purposes and/or
to complete any transactions that you began prior to requesting a change or deletion (e.g., you may not be able
to change or delete the Personal Information provided until after the completion of a services contract).

9. Does this Privacy Policy cover the privacy, information, or other practices of any third parties?

This Privacy Policy does not cover the privacy, information, or other practices of any third parties, including
any third party operating any website or service to which the Services link, including any third-party websites
or services on which we maintain our Social Media Pages. These third parties have separate and independent
privacy policies which we recommend you read carefully. The inclusion of a link on the Services does not imply
endorsement of the linked site or service by us or by our affiliates. In addition, we are not responsible for
the information collection, use, disclosure or security policies or practices of other organizations, such as
Facebook, Twitter, Google, or any other app developer, app provider, social media platform provider, operating
system provider, wireless service provider or device manufacturer, including with respect to any Personal
Information you disclose to other organizations through or in connection with our Social Media Pages.

10. What is the retention period for the Personal Information collected?

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was
obtained and consistent with applicable law. The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide
    the Services to you (for example, for as long as you have an account with us or keep using the
    Services);
  • Whether there is a legal obligation to which we are subject (for
    example, certain laws require us to keep records of our engagement for a certain period of time before
    we can delete them); or
  • Whether retention is advisable in light of our legal position (such as
    in regard to applicable statutes of limitations, litigation or regulatory investigations).
  • Please note that where you unsubscribe from our marketing
    communications, we will keep a record of your e-mail address to ensure we do not send you marketing
    e-mails in the future.

11. Who may use the Services?

The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect
Personal Information from individuals under eighteen (18).

Our Services is based in the United States, and, regardless of where you use our Services, the information
collected as part of that use will be transferred to and maintained on servers located in the United States.
Please note that any information we obtain about you will be stored in accordance with United States privacy
laws, regulations and standards, which may not be equivalent to the laws in your country of residence. By using
our Services, you consent to this collection, transfer, storage and processing of information to and in the
United States.

12. Will this Privacy Policy change?

We may make changes to this Privacy Policy at any time, so please review it periodically. We will update the
effective date of the Privacy Policy at the time a change is made. Your use of the Services following these
changes means that you accept the revised Privacy Policy.

If we make changes in the way we collect or use information, we will notify you by an email, relevant application
messaging, or a reminder to review new policy while logged in to our website.

13. California Consumer Privacy Rights

California has adopted the California Consumer Privacy Act (“CCPA”), which took effect at the beginning of 2020. 
We comply with the requirements of the CCPA to the extent they apply to us.

If you are a California resident and we qualify as a “business” under the terms of that law, you will have the
following rights:

  • You have the right to request that we disclose the categories and the
    specific items of Personal Information about you that we collect, use, disclose, and/or sell and that
    Data about you that we have collected, used, disclosed, and/or sold during the 12 months prior to your
    request.
  • You also have the right to have the Personal Information we collect
    about you deleted.  We use a two-step process to verify your identity and to have the information
    deleted. Your rights to have Data deleted are subject to several exceptions, specifically the Personal
    Information that is necessary for us to:
    • provide you a good or service;

    • perform a contract between us and you;
    • protect your security and prosecute those responsible for breaching it;
    • fix our system in the case of a bug;

    • protect the free speech rights of you or other users;

    • comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
    • engage in public or peer-reviewed scientific, historical, or statistical research in the public
      interests that adheres to all other applicable ethics and privacy laws;
    • comply with a legal obligation; or
    • make other internal and lawful uses of the information that are compatible with the context in which
      you provided it.
  • To make any request under the CCPA please send an email for Data Request to marketing@atce.com. Please
    provide your name, e-mail address, telephone number, and any other information to reasonably verify your
    identity. We will respond to your request within 10 business days after receipt of your request, and
    will then take action to verify your identity and fulfill your request, as required by the CCPA.
  • We will provide you with a CSV copy of your stored data within 45 days of your request, assuming we are
    able to verify your identity in that period and so long as you provide a correct email address for
    successful correspondence.
  • You have the right not to receive discriminatory treatment by us for the exercise of any privacy rights
    conferred by the CCPA, which means that we will not take any action to hurt or punish you for exercising
    your rights under the CCPA.
  • You may designate an authorized agent to make a request under the CCPA on your behalf by writing us
    at marketing@atce.com.  Upon receipt of your request, we will provide you with the information you will
    need to designate that agent.

Note that we are not allowed by law to at any time disclose your Social Security number, driver’s license number,
or other government-issued identification number, financial account number, any health insurance or medical
identification number, or any account password or security questions or answers.

We have listed the specific and general categories of information we have collected, disclosed, or sold in the
last 12 months in the sections above.  Those sections also list the specific and general categories of Personal
Information we have disclosed to third parties for our business purposes.

We do not sell your Personal Information.

We do not sell the personal information of minors under 16 years of age.

For more information, please direct your questions to us at marketing@atce.com

How can you contact us?

If you have questions or concerns with respect to our Privacy Policy, please contact the Privacy Policy Manager
by sending an email to: marketing@atce.com and include your question.

EFFECTIVE DATE OF PRIVACY POLICY:
January 1, 2021