Privacy Policy | Pool Office Manager

When you send us an application or other form
When you conduct a transaction with us, our affiliates, or others
When we collect information about in you in support of a transaction, such as credit card information
In some places on this web site you have the opportunity to send us personal information about yourself, to elect to receive particular information, to purchase access to one of our products or services, or to participate in an activity.
Must comply with Google API Services User Data Policy

ARE COOKIES OR OTHER TECHNOLOGIES USED TO COLLECT PERSONAL INFORMATION?

Yes, we may use cookies and related technologies, such as web beacons, to collect information on our web site. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you register with us, a cookie helps Pool Office Manager to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Pool Office Manager website, the information you previously provided can be retrieved, so you can easily use the features that you customized. A web beacon is a small graphic image that allows the party that set the web beacon to monitor and collect certain information about the viewer of the web page, web-based document or e-mail message, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. Web beacons can be very small and invisible to the user, but, in general, any electronic image viewed as part of a web page or e-mail, including HTML based content, can act as a web beacon. We may use web beacons to count visitors to the web pages on the web site or to monitor how our users navigate the web site, and we may include web beacons in e-mail messages in order to count how many messages sent were actually opened, acted upon or forwarded.

Third party vendors also may use cookies on our web site. For instance, we may contract with third parties who will use cookies on our web site to track and analyze anonymous usage and volume statistical information from our visitors and members. Such information is shared externally only on an anonymous, aggregated basis. These third parties use persistent cookies to help us to improve the visitor experience, to manage our site content, and to track visitor behaviour. We may also contract with a third party to send e-mail to our registered [users/members].

To help measure and improve the effectiveness of our e-mail communications, the third party sets cookies. All data collected by this third party on behalf of Pool Office Manager is used solely by or on behalf of Pool Office Manager and is shared externally only on an anonymous, aggregated basis. From time to time we may allow third parties to post advertisements on our web site, and those third-party advertisements may include a cookie or web beacon served by the third party. This Privacy Policy does not cover the use of information collected from you by third party ad servers. We do not control cookies in such third party ads, and you should check the privacy policies of those advertisers and/or ad services to learn about their use of cookies and other technology before linking to an ad. We will not share your personal information with these companies, but these companies may use information about your visits to this and other web sites in order to provide advertisements on this site and other sites about goods and services that may be of interest to you, and they may share your personal information that you provide to them with others.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Whiate Incorporated websites you visit.

HOW DOES Pool Office Manager USE PERSONAL INFORMATION?

Pool Office Manager may keep and use personal information we collect from or about you to provide you with access to this web site or other products or services, to respond to your requests, to bill you for products/services you purchased, and to provide ongoing service and support, to contact you with information that might be of interest to you, including information about products and services of ours and of others, or ask for your opinion about our products or the products of others, for record keeping and analytical purposes and to research, develop and improve programs, products, services and content.

Personal information collected online may be combined with information you provide to us through other sources We may also remove your personal identifiers (your name, email address, social security number, etc). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and we may treat it like other non-personal information. Finally, we may use your personal information to protect our rights or property, or to protect someone’s health, safety or welfare, and to comply with a law or regulation, court order or other legal process.

DOES Pool Office Manager SHARE PERSONAL INFORMATION WITH OTHERS?

We will not share your personal information collected from this web site with an unrelated third party without your permission, except as otherwise provided in this Privacy Policy. In the ordinary course of business, we may share some personal information with companies that we hire to perform services or functions on our behalf. In all cases in which we share your personal information with a third party for the purpose of providing a service to us, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition. For some sorts of transactions, in addition to our direct collection of information, our third party service vendors (such as credit card companies, clearinghouses and banks) who may provide such services as credit, insurance, and escrow services may collect personal information directly from you to assist you with your transaction. We do not control how these third parties use such information, but we do ask them to disclose how they use your personal information before they collect it. If you submit a review for a third party (person or business) using our Facebook Fan Review Application, during the submission process we ask your permission to gather your basic information (such as name and email address) which we then share with the third party for whom you are submitting the review. We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation.

We may cooperate with law enforcement authorities in investigating and prosecuting web site visitors who violate our rules or engage in behavior, which is harmful to other visitors (or illegal). We may disclose your personal information to third parties if we feel that the disclosure is necessary to protect our rights or property, protect someone’s health, safety or welfare, or to comply with a law or regulation, court order or other legal process. As discussed in the section on cookies and other technologies, from time to time we may allow a third party to serve advertisements on this web site.

If you share information with the advertiser, including by clicking on their ads, this Privacy Policy does not control the advertisers use of your personal information, and you should check the privacy policies of those advertisers and/or ad services to learn about their use of cookies and other technology before linking to an ad.

HOW IS PERSONAL INFORMATION USED FOR COMMUNICATIONS?

We may contact you periodically by e-mail, mail or telephone to provide information regarding programs, products, services and content that may be of interest to you. In addition, some of the features on this web site allow you to communicate with us using an online form. If your communication requests a response from us, we may send you a response via e-mail. The e-mail response or confirmation may include your personal information. We cannot guarantee that our e-mails to you will be secure from unauthorized interception.

HOW IS PERSONAL INFORMATION SECURED?

We have implemented generally accepted standards of technology and operational security in order to protect personally-identifiable information from loss, misuse, alteration, or destruction. Only authorized personnel and third party vendors have access to your personal information, and these employees and vendors are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.

LINKS

This site contains links to other sites that provide information that we consider to be interesting. Pool Office Manager is not responsible for the privacy practices or the content of such web sites.

PUBLIC DISCUSSIONS

This site may provide public discussions on various business valuation topics. Please note that any information you post in these discussions will become public, so please do not post sensitive information in the public discussions. Whenever you publicly disclose information online, that information could be collected and used by others. We are not responsible for any action or policies of any third parties who collect information that users disclose in any such forums on the web site. Pool Office Manager does not agree or disagree with anything posted on the discussion board. Also remember that you must comply with our other published policies regarding postings on our public forums.

HOW CAN A USER ACCESS, CHANGE, AND/OR DELETE PERSONAL INFORMATION?

You may access, correct, update, and/or delete any personally-identifiable information that you submit to the web site. You may also unsubscribe from mailing lists or any registrations on the web site. To do so, please either follow instructions on the page of the web site on which you have provided such information or subscribed or registered or contact us at info@poolofficemanager.com

CHILDREN’S PRIVACY

Pool Office Manager will not intentionally collect any personal information (such as a child’s name or email address) from children under the age of 13. If you think that we have collected personal information from a child under the age of 13, please contact us.

CHANGES

Pool Office Manager reserves the right to modify this statement at any time. Any changes to this Privacy Policy will be listed in this section, and if such changes are material, a notice will be included on the homepage of the web site for a period of time. If you have any questions about privacy at any websites operated by Pool Office Manager or about our website practices, please contact us at: info@poolofficemanager.com

Privacy Policy Pool ServiceManager: Phantom Technology LLC dba Pool Office Manager (“POM”/“we”/“us”/“our”) owns and operates the website located at https://poolofficemanager.com/ (“Website”), and any subdomains https://***.poolservicemanager.com, used in connection with or related to the same, and the POM mobile application (the “App”), as well as and the e-commerce site located at https://***.poolservicemanager.com/. POM is committed to protecting your privacy. This Privacy Policy describes how we collect, store, use and distribute information about our users through the Website, App and Service (as defined in our Terms of Service). Our Service is provided to business customers who have registered for an account with us (“Account Owners”) and any information collected via the Website, App and Service from or about Account Owners’ employees and contractors will be made available to the applicable Account Owner and will be used by such Account Owner according to their privacy policy. A Note About Children. You must be at least 18 years old to use the Website and App. We do not intentionally gather Personal Information (defined in Collection of Information below) from visitors who are under the age of 13. If a child under 13 submits Personal Information to POM and we learn that the Personal Information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Information from a child under 13, please contact us at help@poolofficemanager.com. A Note to Users Outside of the United States and Canada. If you are a non U.S. or non-Canadian user of the Website, by visiting the Website and providing us with data, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Privacy Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States and Canada, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your data, you consent to such transfer. If you are in the EEA please see the GDPR Privacy Notice. Lawful processing: We process your personal information only to the extent necessary for the performance of our obligations to you, which is in providing the Services to you under our Terms of Service listed above. We set out below the type of Personal Information that we collect and how we use it. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. We will not actively collect Personal Information for the purpose of sale or marketing in a way that specifically identifies the individual. In other words, we don’t sell customer lists. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Website, App and/or the Services. Collection of Information: Unless you have otherwise given us appropriate consent, we collect, use and disclose only such information as is required to enable us to manage your account, to provide the Service, to maintain our customer/visitor lists, to respond to your inquiries or provide feedback, for identification and authentication purposes and for service improvement. We will also have access to Personal Information if you are a customer of one of our commercial customers, typically a home service business. We will maintain the confidentiality of any contact information you provide to us on signing up for our Service or contacting us with questions or for further information and we will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties. Two types of information may be collected through the Website, App and our Service: Personal Information and Non-Personal Information. This Privacy Policy does not extend to the collection, use or disclosure of the following information which is currently not limited by applicable privacy laws: (a) information that is publicly available, such as names, addresses, telephone numbers and electronic address when listed in a directory or made available through directory assistance; or (b) Non-Personal Information (as defined further below). “Personal Information” is personally identifiable information, such as your name, address, e-mail address, credit card information, birth date and gender. At the time of collection, we will clearly identify the information being collected and the purposes for which it will be used. It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information, in some instances you may not be able to register to use the Website, App or Service or be able to access and them at all. In other instances, your choice not to provide certain other Personal Information may mean that you will not be able to use certain features of the Website, App or Service. We may collect Personal Information in respect of the Website, App or Service through registration processes; communications with you; information downloads; service use; purchases; user support; and surveys. “Non-Personal Information” is information of an anonymous nature, such as the domain used to access the Website, App or Services, and the type and version of browser or operating system being used by visitors to access the Website, App or Service. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical location of our users), number of visitors, what pages users access or visit, and average time spent on the Website, App or Service is not on its own considered Personal Information.. Although the use of certain Non-Personal Information collected, used or disclosed through the Internet as described herein is not restricted (and to the extent that such is the case, the obligations under this Privacy Policy do not apply to such information), we provide information in this Privacy Policy about the collection of such information for the sake of transparency with respect to the operation of the Website, App and Service. Such Non-Personal Information is collected or derived by us in the course of operating this Website, App and our Services. For example, our servers may automatically collect Non-Personal Information that is provided through your browser or stored in a cookie. Connecting Through Third Party Sites. Users may login or register to use the Service through certain third party sites (“SNSs”). If you are already logged into the App or Service and a SNS or a Third-Party Account, when you connect to the SNS or Third-Party Account, you may be prompted to merge your profiles. By proceeding, you are allowing the App and/or Service to access your information and you are agreeing to the SNSs’ or Third-Party Account’s Terms of Use in your use of the App or Service. Conversely, if you are not currently registered as a user of the App or Service, and you click on “Sign in” the SNS or Third-Party Account that we support, you will first be asked to enter your SNS or Third-Party Account credentials and then be given the option to register for the App or Service. In this case, we may receive information from the SNS or Third-Party Account to make it easier for you to create an account on the Website and show our relevant content from your SNS friends. Once you register on the Website and connect with the SNS or Third-Party Account you will be able to automatically post recent activity back to the SNS or Third-Party Account. Any information that we collect from your SNS account or Third-Party Account may depend on the privacy settings you have with that SNS or Third-Party Account, so please consult the SNSs’ or Third-Party Account’s privacy and data practices. Collection and Use of Information: We collect the following information for the following purposes: • Registration Data. When you register to use the Service, we ask for information such as your full legal name, company name (if applicable), email address, billing address and credit card information. This information will be used to administer your account, for billing, verification and authentication purposes and to contact you in relation to the same. • Content You Make Available. You have the ability to take/upload photos, notes and other content to the Website and/or App such as a photo and description of a job that you have completed. The content that you make available will be accessible to the Account Owner. • Location Data Generally. Once you download the App, the App will request access to your device location. If you grant the App access to your device location, we will be able to track the physical location of your device using GPS and WiFi signals. We use this information to provide the Service. You can remove the App’s access to your device location at any time by changing your privacy settings on your device, and you may also permit the App to only track your location at specific times by changing your privacy settings within the App. Not enabling access to your device location may limit the features and functionality of the Service that you can use. Location data will be available to the Account Owner. • Location Data: Security Tracking. Location data is automatically tracked for fraud prevention purposes (eg. to potentially identify unauthorized access to your account) and unusual patterns or location data that is flagged by the Security Services may be notified to the Account Owner/applicable administrators. In the event of high- risk activity flagged by the Security Services, your account may be temporarily disabled to protect against fraudulent activity through your account. We will notify you if we take this action and will provide information on how to verify your account and unblock access to the same. • Time Tracking. You may use the time tracking functionality in the App to track how long it takes you to complete a work task. Such information will be made available to the Account Owner. • E-commerce transactions. If you make a purchase through our e-commerce store located at https://***.poolservicemanager.com/, POM will collect your name, credit card billing information and shipping information. This information is used to process your transaction and delivery products purchased. • Metadata: We collect and use various metadata derived from your use of the Service. For example, if you take a photo using the App, we also collect the time that such photo was taken. Such metadata will also be made available to the Account Owner. • Transactional Notifications: We provide notifications for certain activities relating to your use of our Service despite your indicated e-mail preferences, for example we may send you notices of any updates to our Terms of Service or Privacy Policy. • Marketing Communications: If you opt-in to receive marketing communications from us, we will keep you up to date on our products and services. You may withdraw your consent to receiving marketing communications from us at any time by following the opt-out instructions in each communication. • Statistics: We also collect statistics about use of the Service which we use for analytics including predictive analytics. Aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to other members or third parties. POM may disclose industry trends related our customers, which are derived from use of the Service, that do not include any Personal Information. • Third Party Services: In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Website or use our Services. This includes third party analytics services, including but not limited to Google Analytics (“Analytics Services”), that we engage to help analyze how users use the Website, as well as third parties that deliver content or offers and third party fraud detection and prevention services (“Security Services”) that we engage to help predict and prevent fraudulent activities on the Website and Services. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Website and Services and the use of information from Security Services will be used in accordance with the terms of the Account Security and Fraud Prevention Terms. The information generated by the Cookies or other technologies about use, access to and the location of such use and access by you and others with access to your POM account and to our Website and Services (the “Analytics Information”) is transmitted to the Analytics Services and Security Services. The Analytics Services use Analytics Information to compile reports on user activity and the Security Services use Analytics Information within digital products and tools including an AI-driven real time machine learning software platform which analyses and aggregates data to identify risk patterns and predict fraudulent activities. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Website and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at help@poolofficemanager.com. • System Logs & Cookies: Cookies are used by us to track content usage and traffic on the Website and App. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server. Cookies help us compile aggregate statistics about usage of this Website and App, such as how many users visit the Website, how long users spend viewing the Website, and what pages are viewed most often. This information is used to improve the content of the Website and App. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the Website, App or Services. Your IP address is reported by your web browser whenever you visit a page on the Website. This information is recorded together with your registration information on our databases. How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Site. • Third-Party Links: The Website and App may contain links to other third-party websites that are not owned or controlled by us. Such third-party websites are governed by the terms and conditions and privacy policies of such third-party providers and we are not involved in any interaction or transaction between you and such third-parties. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites. • Third Party Partner Integrations: Optional third party add-ons may be offered by our integration partners from time to time. Data shared with third party integration partners is subject to the privacy policies and terms of service of such third parties. • POM Payments. If you register for the POM Payments service, we may collect additional information from you, including certain account information. We will also collect certain payment and other personal information from your customers, and it is your responsibility to ensure you have a privacy policy in place that permits POM to collect such information. Because our payment service is provided by a third-party service provider, Stripe, by signing up for POM Payments, you are also agreeing to the terms of the Stripe Privacy Policy (see further www.stripe.com/ca/privacy). Any personal information that you provide to Stripe about you or your customers will be treated in accordance with the terms of the Stripe privacy policy. If we plan to use your Personal Information in future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See further the section of this Privacy Policy entitled ‘Amendment of this Policy’. Disclosures & Transfers: We have put in place contractual and other organizational safeguards with our agents (see further below) to ensure a proper level of protection of your Personal Information (see further Security below). In addition to those measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy (see further Important Exceptions below). As at the date of this Privacy Policy, we share Personal Information about you in respect of the Website, App or Service only with our service providers and partners which include website hosting, cloud service providers, security service providers, analytics providers, email marketing providers and payment processors. Our service providers may host data worldwide and accordingly your Personal Information may be available to governments worldwide under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information. Stripe is the sub-processors that we use, and an additional application fee may be applied to all transactions to support the continued integration of POM and Stripe . Our business needs may change from time to time and so we will periodically update this page to provide notice of additions and removals to our list of sub-processors. Where we engage sub-processors, we will endeavour to impose data protection terms that provide at least the same level of protection for Personal Information as those in our Privacy Policy, to the extent applicable to the nature of the services provided by such sub-processors. From time to time we may employ third parties to help us improve the Website, App and/or the Service. These third parties may have limited access to databases of user information solely for the purpose of helping us to improve the Website, App and/or the Service and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose. Our App and Service may enable you to post content to SNSs or other Third-Party Accounts. If you choose to do this, we will provide information to such SNSs or Third-Party Accounts in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third-party provider of such SNSs or Third-Party Accounts. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs or Third-Party Accounts; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs or Third-Party Accounts Important Exceptions: We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Website or App members, other users of the Service, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information. Security: The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you. When you provide credit card or other payment information to pay for POM subscriptions, your credit card and financial information is processed by Recurly, a third-party subscription management provider. POM does not store and does not have access to detailed credit card details. If you use POM Payments, as further described in our Terms of Service, your payment information and payments will be processed by Stripe and such information and processing will be subject to Stripe’s own legal agreements which you should read carefully. You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information or your password for the Service to third parties. Retention: We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. All retained personal information will remain subject to the terms of this Privacy Policy. If you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints. Amendment of this Policy: We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will send you an email or in-App notification. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective 30 days from their posting on the Website or App. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Website, App or Service signifies your acceptance of any changes. You should consult this Privacy Policy regularly for any changes. If you decide at any time that you no longer wish to have your Third-Party Account linked to your account, please contact us at help@poolofficemanager.com. Access & Accuracy. You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner. We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service. Contact Us: You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your information or would otherwise like to exercise any of your rights in respect of your personal information (whether as set out above or otherwise), if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us at: help@poolofficemanager.com CA Privacy Policy This Privacy Notice for California Residents (“CA Privacy Notice”) who use our Website, App or Service (each as defined and described in the Privacy Policy). Phantom Technology LLC dba Pool Office Manager (“POM”, “we”, “us”, or “our”) has adopted this CA Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this CA Privacy Notice. With respect to users who are California residents, this notice is incorporated and made a part of our Privacy Policy, and the terms of this CA Privacy Notice shall control with respect to California residents in the event of any inconsistency between our Privacy Policy and this CA Privacy Notice. Where we use capitalized terms in this CA Privacy Notice that are not expressly defined, those terms have the meaning provided in the Privacy Policy. I. Information We Collect Our Website, App and Service (collectively and together with all related services and activities, our “Services”) collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect through our Website, App and Service, and have collected during the last twelve (12) months, the following categories of personal information: Category A. Identifiers Description/Examples A real name, Internet Protocol address, email address, or other similar identifiers. Collected? YES Category B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Description/Examples A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Collected? YES Category C. Protected classification characteristics under California or federal law. Description/Examples A name, signature, Social Security number, physical characteristics or description, Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Some personal information included in this category may overlap with other categories. Collected? NO Category D. Commercial information. Description/Examples Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Collected? YES Category E. Biometric information. Description/Examples Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected? NO Category F. Internet or other similar network activity. Description/Examples Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Collected? YES Category G. Geolocation data. Description/Examples Physical location or movements. Collected? YES Category H. Sensory data. Description/Examples Audio, electronic, visual, thermal, olfactory, or similar information. Collected? YES Category I. Professional or employment-related information. Description/Examples Current or past job history or performance evaluations. Collected? YES Category J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Description/Examples Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected? NO Category K. Inferences drawn from other personal information. Description/Examples Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected? YES For purposes of this CA Privacy Notice, personal information does not include: • Publicly available information from government records • De-identified or aggregated consumer information not capable of being associated with or be linked, directly or indirectly, to a particular consumer or household • Information that is excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), or personal information covered by certain privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) and the Driver’s Privacy Protection Act of 1994. In general, we obtain the categories of personal information listed above from the following categories of sources: • Directly from our users or their agents. For example, from forms our users complete on our websites or information they provide in connection with an account with us, through our communications with our users or through any other interaction we have with our users. This includes personal information relating to (1) purchasers of the goods and services offered by our users and (2) information related to the user’s workers and agents that such users input via the Services. • Indirectly from our users and their agents. For example, from observing user actions on our website, or when someone authorizes a third party (including SNSs (as defined in the Privacy Policy)) to provide us the information on their behalf. • Indirectly from our service providers. For example, third party service providers we use to help us provide aspects of the Services (such as payment processing) may receive personal information related to our users that we receive access to. The ways that we collect the foregoing information are set forth in greater detail in our Privacy Policy. Although this Section I and the corresponding portions of our Privacy Policy are designed, as described in our Privacy Policy and Terms of Service to disclose and describe our receipt and use of personal information of which we are aware, we do receive information from users of our Services, including User Content (as defined in the Terms of Service), in circumstances where we do not control or monitor what is contained in the information received. Accordingly, it is possible that we may receive unsolicited personal information falling in one of the categories described above under circumstances other than those described above. We endeavor to treat all personal information we receive consistent with the terms of our Privacy Policy, but cannot guarantee such treatment with respect to personal information, if any, that we may unknowingly receive as described in this paragraph. II. Use of Personal Information We may use the categories of personal information we collect as set forth above for the following purposes: Category A. Identifiers. Purposes • To provide our Services to our users. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. • To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, to communicate with our users and perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies. • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity • Undertaking activities to verify or maintain the quality or safety of, and to upgrade and enhance, our products and services. • Auditing related to a current interaction with consumers using the Services • Advertising, marketing and selling the Services • Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction Category B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Purposes • To provide our Services to our users. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. • To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, to communicate with our users and perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies. • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity • Undertaking activities to verify or maintain the quality or safety of, and to upgrade and enhance, our products and services. • Auditing related to a current interaction with consumers using the Services • Advertising, marketing and selling the Services • Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction Category D. Commercial information Purposes • To provide our Services to customers and other users, including facilitating purchases and payments via the Services. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. • Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction Category F. Internet or other similar network activity. Purposes • To provide our Services to customers and other users. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. • Detecting security incidents and protecting against malicious, deceptive, fraudulent or illegal activity • Undertaking activities to verify or maintain the quality or safety of, and to upgrade and enhance, our products and services. • Auditing related to a current interaction with a consumer using the Services • Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction Category H. Sensory data. Purposes • To provide our Services to customers and other users. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. • Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction Category I. Professional or employment-related information. Purposes • To provide our Services to customers and other users. This includes sharing personal information with certain third-party vendors we contract with to provide aspects of the services as described further under the heading “Sharing Personal Information” below. • Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction Category K. Inferences drawn from other personal information. Purposes • To perform account-related services, provide customer service, process and fulfil orders and transactions, verify customer information, process payments, and to perform other customer services functions such as notifying you about aspects of our products and services and changes to our website or policies. • Undertaking activities to verify or maintain the qualify or safety of, and to upgrade and enhance, our products and services. • Short-term, transient use where the personal information (i) is not disclosed to another third party, and (ii) is not used to build a profile about a Consumer or alter their individual experience outside the current interaction In addition, we may use information in any of the categories described above: • As described to you and consented to by you when collecting your personal information or as otherwise set forth in the CCPA. • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations or to otherwise comply with legal obligations applicable to us. These uses of data, including personal information are described in greater detail in our Privacy Policy. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes from what is described in this CA Privacy Notice without providing you notice. III. Sharing Personal Information We may disclose your personal information to a third party for a business purpose as set forth in this Notice. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information in the following categories for the business purposes identified above: Category A. Identifiers. Disclosed To • Our applicable service providers • Third parties such as SNSs (as defined in the Privacy Policy) where the provider of the personal information has either provided it to such third party or consented to it being provided • Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us Category B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Disclosed To • Our applicable service providers • Third parties such as SNSs (as defined in the Privacy Policy) where the provider of the personal information has either provided it to such third party or consented to it being provided • Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us Category D. Commercial information Disclosed To • Our applicable service providers • Third parties such as SNSs (as defined in the Privacy Policy) where the provider of the personal information has either provided it to such third party or consented to it being provided • Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us Category F. Internet or other similar network activity. Disclosed To • Our applicable service providers Category G. Geolocation Data. Disclosed To • Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us Category H. Sensory data. Disclosed To • Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us Category I. Professional or employment-related information. Disclosed To • Commercial Customers (as defined in the Privacy Policy) who are the Account Owner for the applicable account with us IV. Your Rights and Choices The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. A. Access to Specific Information and Data Portability Rights You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: • The categories of personal information we have collected about you. • The categories of sources for the personal information we collected about you. • Our business or commercial purpose for collecting or selling that personal information. • The categories of third parties with whom we share that personal information. • The specific pieces of personal information we collected about you (also called a data portability request). • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: o sales, identifying the personal information categories that each category of recipient purchased; and o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. To make a request to have your personal information disclosed you can make a request for the information using the contact information set out in Section C below. B. Deletion Request Rights You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. • Debug products to identify and repair errors that impair existing intended functionality. • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. • 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 interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. • Comply with a legal obligation. • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. C. Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us as follows: (1) calling us at 614-710-0074 (2) writing to us at Phantom Technology LLC 4177 Lyman Drive Hilliard, OH 43026 (3) emailing us at: help@poolofficemanager.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you wish to register a person to operate on your behalf, you must inform us by contacting our customer services team and validating your identity so that the identity of the authorized person may be recorded. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: • Provide enough information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. • Describe your request with enough detail that allows us to properly understand, evaluate, and respond to it. • We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. D. Response Timing and Format We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within forty-five (45) days of receipt of your request. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. E. Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: • Deny you goods or services. • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. • Provide you a different level or quality of goods or services. • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. F. California Shine the Light Law California’s “Shine the Light” law (Civil Code Section § 1798.83) may permit users of our Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, and to prevent future disclosures for direct marketing purposes of your Personal Information. To make such a request, please contact us using the contact information provided below. V. Changes to this Notice We reserve the right to amend this CA Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our website and update this notice’s effective date. If as a business we intend to use your personal information for a purpose that was not previously disclosed in the privacy policy or in the notice at collection, we shall directly notify your of this new use and obtain explicit consent from the consumer to use it for this new purpose. VI. Contact Information If you have any questions or comments about this notice, the ways in which we collect and use your information described in the CA Privacy Notice and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us as follows: • Send us a message via email to help@poolofficemanager.com • Call our customer service team at 614-710-0074

Limited Use Policy