PRIVACY & COOKIE POLICY

LAST REVISED:

February 25, 2023

This privacy policy (this “Privacy Policy”) applies to https://www.stridenow.io (the “Site”), which is owned and operated by Compiify, Inc.(“we,” “our,” or “us”) and our compensation management software (the “Software”). We recognize and respect your privacy. This Privacy Policy explains how we collect, use and disclose personally identifying information (“Personal Information”) gathered through the Siteand the Software. This Privacy Policy is subject to and incorporates by reference the Site’s “Terms of Use”(located here:https://www.stridenow.io/terms).

We reserve the right to change this Privacy Policy from time to time without notice to you. You should check here periodically to review the current Privacy Policy, which is effective as of the revision date listed below. Your use of the Site and submission of Personal Information to us constitutes acceptance and understanding of this Privacy Policy.

Types of Personal Information Collected Through the Site

We may collect the following types of Personal Information through the Siteand/or the Software:

• Your contact information (such as name, address, email address and phone number);

• Personal Information contained in legal agreements (such as invoicesand orders);

• Personal Information transferred to us by you (or by your organization about you) through the Siteand/or the Software such as your employee information, compensation information and other identifiers specific to you such as your gender and ethnicity;

• Information posted by you to the Site (such as comments, suggestions, feedback, opinions, or media); and

• Any other Personal Information you submit through the Siteand/or the Softwareor to us in the form of an email.

Types of Uses of Information & Personal Information

We collect, store and use the information as well as Personal Information you provide to us in various ways always in accordance with this Privacy Policy and as follows:

• To provide our products and services to you, to improve the Site, the Software,and offerings or services provided by us and to better understand how users access and use the Site, the Software,and offerings provided by us;

• To process product orders received through the Site, the Software,or other ways you communicate them to us (e.g., email, phone);

• To evaluate business opportunities;

• To effectuate or enforce a transaction or agreement;

• To adjust offerings or services provided by us to you;

• To provide you with information about our products and services that we believe you may find of interest, including to send you mailing lists, and marketing and promotional e-mails;

• To authenticate visitors to the Site;

• To be able to respond to requests or inquiries, and for similar, customer-service-related purposes; and

• We automatically collect through the Site information that is often not personally identifying, such as the website from which visitors came to the Site, Site visitors’ IP address, browser type and other information relating to the device through which they access the Site. We may combine this information with the Personal Information we have collected from you.

For clarity, we do not make any warranty, express, implied or otherwise, that we will be able to prevent loss, misuse, unauthorized access to, or alteration of personally identifiable information you provide to us. You make any disclosure of personally identifiable information to us at your own risk.

Types of Sharing of or Disclosures of Personal Information

We may share or disclose Personal Information to third parties for the following purposes:

• To third parties in aggregated, or non-personally identifying, forms of information about Site and/or Software users for marketing, advertising, research or other reasonable business purposes;

• To provide you with information relating to products or services that we believe you may find of interest;

• In response to a subpoena or other legal process by a governmental entity or thirdparty, or if otherwise required by law;

• To protect or enforce our rights including with respect to our assets and properties;

• In the event of the sale or dissolution (bankruptcy) of assets, in whole or in part, of our business or any of its affiliates;

• To third parties involved in the process of fulfilling orders, providing, or performing functions on our behalf (e.g., such as third-party service providers, contractors, payment processors, banks, and collection agencies); and

• To provide our products or services to you and as requested.

Cookies, Beacons and Analytics

When you interact with the Site, we strive to make your experience easy and meaningful. Our Site uses technology, or those of third-party service providers, such as cookies, web beacons (clear GIFs, web bugs) and similar technologies to track user activity and collect site data. We may combine this data with the Personal Information we have collected from you.

Cookies

We (including our chosen third-party service providers) use cookies to track visitor activity on the Site. A cookie is a text file that a website transfers to your computer’s hard drive for record-keeping purposes. Our cookies assign a random, unique number to each visitor’s computer. They do not contain information that would personally identify the visitor, although we can associate a cookie with any identifying information that is or has been provided to us while visiting the Site. We use cookies that remain on your computer for a specified period of time or until they are deleted (persistent cookies). We may also use cookies that exist only temporarily during an online session (session cookies) –these cookies allow us to identify you temporarily as you move through the Site. Most browsers allow users to refuse cookies but doing somay impede the functionality of some portions of our Site.

Web Beacons

Web beacons are tiny graphics with a unique identifier, similar in function to cookies, that are used to track the online movements of Web users. In contrast to cookies, which are stored on your computer’s hard drive, Web beacons are embedded invisibly on webpages and may not be disabled or controlled through your browser.

Third Parties

As noted, we may also engage third parties to track and analyze Site activity on our behalf. To do so, these third parties may place cookies or web beacons to track user activity on our Site. We use the data collected by such third parties to administer and improve the quality of the Site, analyze usage of the Site, and provide a more enhanced user experience on the Site, such as personalizing and delivering relevant offers and content based on user activity on the Site. We do not provide these third parties with your Personal Information.

Email Policy

We may use your email address to communicate with you about orders you have placed, inquiries you have made about our products and services, or information you have shared with us through the Site or email. We may send you emails from time to timeabout information that we believe may be of interest to you. We may also send you news and offers about our products and services, or those of our chosen partners.

If, at any time, you would like to stop receiving these promotional e-mails, you may follow the opt-out instructions contained in any such e-mail. Please note that it may take a few business days for us to process opt-out requests. If you opt-out of receiving emails or promotions, we still may send you e-mails to you in accordance with this Privacy Policy, as requested by you, or in reference to other customer service purposes.

California Privacy Laws

The “California Consumer Privacy Act of 2018” became effective January 1, 2020, andwas amended by the “California Privacy Rights Act of 2020” or the “CPRA”), effective January 1, 2023(together, “CA Privacy Laws”). The CA Privacy LawsgrantCalifornia consumers new rights related to their Personal Information. The CA Privacy LawsaffordCalifornia consumers new rights to transparency about data collection including rights to control access and use of their Personal Information, including, but not limited to, theright to correct personal information and opt out of data sharing. To the extent applicable to us, we comply with CA Privacy Laws. We do not sell your Personal Information. We do share some of your information with our trusted service providers, to market our services and operate the Site. We do not allow these third parties to use your information for their own purposes.Personal Information we collect is retained by us for a period of 12 months. If you wish to opt out of data sharing, correct Personal Information, or exercise any other rights you have under the CA Privacy Laws, please contact us at the email specified below in this Privacy Policy.

Under California’s “Shine the Light” law, California residents who provide Personal Information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared,if any, with other businesses for their own direct marketing uses.If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared that information for the immediately prior calendar year (e.g., requests made in 2023 will receive information regarding 2022 sharing activities).To obtain this information, please contact us at the email specified below in this Privacy Policywith “Shine the Light Request” on the subject line and in the body of your message.We will provide the requested information to you at your email address in response.Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Pursuant to California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Compliant Assistance Unit of the Division of ConsumerServices for the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of Personal Information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control.The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.We do not specifically market to children under the age of 13 years old.

To protect children’s Personal Information, we do not knowingly collect any Personal Information from persons under the age of eighteen (18) that can be used to specifically identify them, and the Company does not permit persons under the age of eighteen (18) to use the Siteor the Software.If we become aware that a child under the age of thirteen (13) has provided us with Personal Information, we will immediately take steps to delete the Personal Information submitted and terminate the account.

International Users & GDPR

We have implemented safeguards to ensure an adequate level of data protection where your Personal Information is transferred outside of the EEA, such as by means of our customer data processing addendum by means of which we implement the standard contractual clauses for the transfer of Personal Information as approved by the European Commission (Article 46 GDPR).

How to Contact Us

While we strive for error free performance, we cannot always catch an unintended privacy issue. As a result, we encourage your questions and comments about any privacy concerns. Please direct them to us by an email to the following: support@stridehr.io.