Privacy Policy

Overview

Cadana, Inc., also represented in business as Cadana, (“Cadana,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains who we are, how we collect, use and share Personal information about you and how you can exercise your privacy rights. This Privacy Policy describes (unless a different privacy notice is displayed) our privacy practices regarding the personal information we collect from individuals in the usual course of business, including when you:

• Visit any of our websites (such as https://cadanapay.com/); visit our social media pages; receive communications from us; or register for, attend and/or otherwise take part in any of our events, tutorials, webinars or contests (collectively “Visitors”); and

- Register to or otherwise use any of the Cadana Services as an employer, or employee of one of our Customers (collectively “Users”), when we act as a controller of your Personal Information.

"You" may, depending on the context, be a Visitor or a User of one or more of the Cadana Services.

For purposes of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual (e.g., name, address, email address, national ID, tax ID or phone number)

About Us

We are Cadana, a company headquartered in New York, New York, USA. We make payroll software to save time for employers and provide faster employee payments by allowing employees to get paid on-demand. Our mission is to unlock financial wellness for all workers. In achieving our mission we provide a hosted platform and tools including the Cadana payment web solution and mobile applications (the “Cadana Services”), that streamlines payroll from employers and reduces financial stress for employees.

Cadana As A Service Provider

Cadana Customers are organizations who use the Cadana Services to manage and provide payment benefits to their employees. Cadana processes Personal Information in these services only according to our Customer's and their User's instructions (as defined in our Customer agreements). If you have questions about Personal Information you have entered into the Cadana Services used by one of our Customers, or want to exercise any of your rights regarding your Personal Information, our Customer contract requires that we redirect your inquiry back to that Customer. This Privacy Policy does not apply to the Personal Information we process as a service provider or processor on behalf of our Customers.

Cadana is not responsible for the privacy or security practices of our Customers, which may differ from those set out in this Privacy Policy. Please review the relevant Customer's privacy policy to understand more about their data processing activities.

Privacy Principles

Cadana follows these principles in order to protect your privacy:

- We only use your Personal Information for the purposes we specify in this Privacy Policy, unless you are notified otherwise;

- Other than as specified in this Privacy Policy, we do not share your Personal Information with third parties and are not in the business of selling your Personal Information.

What Information Do We Collect?

The information we collect depends on the ways you interact with Cadana and the choices you make (including your privacy settings), the products and features you use, your location and applicable law.

A. Information We Collect

(i) Information You Provide to Us

Visitors

When a Visitor to our website contacts us and/or registers for information, content or an event sponsored by Cadana, we will collect certain personal information so that we may fulfill the Visitor's request or keep in touch with them in connection with our sales and marketing activities (always in accordance with a Visitor's marketing preferences). The Personal Information we collect and we may have collected since our existence include:

• Identifiers, such as your name and business e-mail address;
• Professional or employment-related information, such as company name, job level, functional role and title;
• Inferences, such as your contact preferences; and
• Any other information you provide to us when completing any "free text" boxes in our forms or when you interact with us in the context of troubleshooting and support.

If you register to attend a Cadana-sponsored event, we may also require certain additional Personal Information including:

• Emergency contact (in some instances); and
• Dietary preferences (in some instances).

‍Users

‍If you are a User, you (or your team administrator) may provide certain Personal Information to us through the Cadana Services - for example, when you register for a Cadana account to access and use the Cadana Services, when you consult with customer support or send us an email or communicate with us in any way (for example, to make a support request).

The Personal Information we collect may include:

• Business information (such as your name, job title, the person you report to, phone number, email address and country);
• Personal information that you provide to us or that is collected on behalf of our customer as it relates to your employment (such as gender, t-shirt size, or dietary preferences);
• Marketing information (such as your contact preferences);
• Account log-in credentials (such as your email or username and password when you sign up for an account with us and the unique User/ team ID assigned to you in our systems);
• Troubleshooting and support data (which is data you provide or we otherwise access in connection with support queries we receive from you. This may include, for example, contact or authentication data, the content of your chats and other communications with Cadana, and the product or service you are using related to your help inquiry); and
• Billing information (including your credit card numbers and associated identifiers, billing address and background information, but only where you pay for the Cadana Services).

If you ever communicate directly with us, we will maintain a record of those communications and responses.

‍(ii) Information We Collect Automatically

Visitors

As is true of most websites, when you visit our sites or interact with our emails, we gather certain technical information from your browser or device automatically and store it in log files. In some (but not all) countries, including countries in the European Economic Area ("EEA"), UK and Switzerland, this information is considered Personal Information under data protection laws. To the extent that this automatically-collected data includes, or is linked to, Personal Information, we will treat the data in accordance with this Privacy Policy.

This information we collect includes:

• Identifiers, such as your internet protocol (IP) addresses and browser type; and
• Internet or other electronic network activity, such as your internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information to analyze trends, to improve and personalize our marketing activities and websites, to administer our websites and guarantee their security and continued proper functioning, to track Visitors' movements around the website and to gather non-identifiable, demographic information about our user base as a whole. We may link this automatically-collected data to Personal Information provided by Visitors, or to other publicly available information hosted on the internet, so that we can better gauge our Visitors' needs and provide specific information to best serve them.

‍Users

‍When you use or interact with the Cadana Services, we automatically collect or receive certain information through our Services (for example in log files) and through other technologies (such as cookies) about your device and usage of the Cadana Services. In some (but not all) countries, including countries in the European Economic Area ("EEA"), UK and Switzerland, this information is considered 'personal data' under data protection laws.

The information we collect includes:

• Log and usage data, which is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use the Cadana Services and which we record in log files. This log data may include the Internet Protocol (IP) address, device information, browser type and settings and information about your activity in the Services (such as the date/ time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you use)), device event information (such as system activity, error reports and hardware settings).
• Device data, such as information about your computer, phone, tablet or other device you use to access the Cadana Services. This device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information. If you are using our mobile app, we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID and information about the features of our mobile app you accessed.
• Location data, such as information about your device's location, which can be either precise or imprecise. How much of this information we collect depends on the type and settings of the device you use to access the Cadana Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Cadana Services.

This information is used to:

• maintain the security of the Cadana Services;
• provide necessary functionality;
• improve performance of the Cadana Services;
• assess and improve your experience of the Cadana Services;
• review compliance with applicable usage terms;
• identify future opportunities for development of the Cadana Services;
• assess capacity requirements;
• identify customer opportunities and for the security of Cadana generally (in addition to the security of the Cadana Services); and
• analyze overall trends, to help us provide and improve the Cadana Services, and to improve their security and proper functioning.

(iii) Information We Collect from Third Parties

‍In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information may include your: mailing address, job title, functional role, business email, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, social media URLs and custom profile. We process this data for the purposes of: updating our records; targeted advertising; event promotion; optimizing our sites and the Cadana Services; for our sales and marketing activities, including to send marketing emails.

Cookies and Similar Tracking Technologies

Cadana uses a technology called "cookies" to store session information. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive.

We use both session ID cookies and persistent cookies. A "session ID cookie" expires when you close your browser. We use session ID cookies to track your login status. This cookie is only ever transmitted over HTTPS. A "persistent cookie" remains on your hard drive for an extended period of time. We use persistent cookies to determine from where you were referred to our website, as well as the last user ID that you used to log in. Cadana may set and access Cadana cookies on your computer; cookies are required to use the Cadana Services. You can remove persistent cookies by following directions provided in your Internet browser's "help"directory.

Google Analytics: We use cookies served by Google Analytics to collect limited data directly fromService Users browsers to enable us to better understand your use of the Services, including making use of the demographics and interests reports services of Google Analytics. Further information on how Google collects and uses this data can be found at www.google.com/policies/privacy/partners/. You can opt-out of all Google supported analytics within the Services by visiting https://tools.google.com/dpage/gaoptout.

We also partner with third-party ad networks to manage our advertising on other sites and with third-party analytics companies to assist us with analyzing the use of our own website. These third-party companies use cookies, web beacons, pixel tags, and related technologies to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests and to provide measurement and analytic services.

“DO NOT TRACK” SETTING Currently, various browsers offer a “do not track” or “DNT” option which sends a signal to websites' visited by a user about the user's browser DNT preference setting. Cadana does not currently respond to browsers' DNT signals with respect to the website, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Cadana takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

How Do We Use Your Personal Information?

Cadana processes personal information for the following business and commercial purposes, and if you are a resident in the EEA or UK, on the legal basis identified below:

• Providing our websites and Cadana Services: In reliance on our legitimate interest, we process your personal information to operate and administer our websites, and to provide, operate, and maintain the Cadana Services;
• Communicating with you about the Cadana Services: We may send you service, technical and other administrative or technical email, messages and other types of notifications(such as distribution and product updates and product patches and fixes) in reliance on our legitimate interests in administering the Cadana Services and providing certain features. These communications are considered part of the Cadana Services and in most cases you cannot opt-out of them. If an opt-out is available, you will find that option within the communication itself;
• Providing necessary functionality: We process your personal information in reliance on our legitimate interest to provide you with the necessary functionality required during your use of our websites and Cadana Services.
• Transactional considerations: We process your personal information to complete transactions, and send you related information, including purchase confirmations and invoices, to perform our contract with you and to the extent necessary in reliance on our legitimate interest;
• Handling contact and support requests: If you fill out a “Contact Us” web form or request support as a User, or if you contact us by other means including via a phone call, we process your PersonalInformation to perform our contract with you and/or (if we have not entered into a contract with you) to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
• Administering Events: We process your personal information to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, billing, registration and to connect you with other event attendees, to perform of our contract with you, or to the extent necessary for our legitimate interests in fulfilling your requests to attend any such events;
• ‍Developing and improving our websites and services: We process your Personal Information to analyze trends and to track your usage of and interactions with our websites. marketing activities and Cadana Services to the extent it is necessary for our legitimate interest in developing, improving and troubleshooting our websites, marketing activities and the Cadana Services and providing you with more relevant content and service offerings, or where necessary, in reliance on your consent;
• Sending marketing communications: We will process your Personal Information for marketing purposes in accordance with your preferences, such as to communicate with you via email, SMS or telephone about services, features, surveys, newsletters, promotions or events we think may be of interest to you and/or to provide other news or information about Cadana and/or our select partners, in each case in reliance on our legitimate interest in conducting direct marketing or where necessary with your consent.
• Displaying personalized advertisements and content: We process your Personal Information to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in supporting our marketing activities or advertising the Cadana Services or, where necessary, to the extent you have provided your prior consent
• Promoting the security of our websites and services: To the extent necessary for our legitimate interests in promoting the safety and security of our websites and services, we use your PersonalInformation to investigate and prevent fraudulent transactions, unauthorized access to the websites, Cadana Services, and other illegal activities;
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products and features, enhancing, improving or modifying our products and services, identifying usage trends and expanding our business activities in reliance on our legitimate interests; and
• Complying with legal obligations: We process your Personal Information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, the Cadana Services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
• Reviewing compliance with applicable usage terms: We process your Personal Information to review compliance with our contract with you or your organization (where applicable) to the extent that it is in our legitimate interest to ensure adherence to the relevant terms; and
• Other purposes: We will process your Personal Information for other purposes about which we notify you in advance, or for which we receive your consent.

What Information Do We Share or Disclose to Others?

Cadana will not share Personal Information, or otherwise make your Personal Information available to any other parties except as provided in this Privacy Policy. Parties with whom we may share your Personal Information, pursuant to any applicable agreements, include:

• Event Co-Sponsors: If you sign up for an event or content that is co-hosted by Cadana and one of its partners or co-sponsors, your Personal Information may be shared with that partner or co-sponsor. Please see our partner or co-sponsors' privacy policies for further information about how they use Personal Information.
• Legal or regulatory bodies and agencies: Cadana will share your information, including Personal Information, in order to respond to investigations, court orders, legal processes, or to investigate prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, violations of Cadana Terms of Service, or as otherwise required by law. If Cadana is required by law or an order of a court of competent jurisdiction to disclose your information, Cadana will promptly notify you of this requirement, if permitted by the court or applicable law, so that you may seek a protective order or other appropriate relief.
• Service providers: In order to provide our websites, the Cadana Services to you and undertake our marketing and business activities, it may be necessary for us to disclose your information to contracted third parties and service provider partners who perform certain functions on our behalf. Examples include payment providers (to authorize, record, settle and clear payment card transactions); cloud hosting providers (to provide data storage and processing services); communications providers (to process new queries and to manage our emails); and analytics companies to perform analysis. These third-party service providers or vendors may use data we provide to them only as instructed by Cadana.
• Business transfers: If Cadana is involved in a merger, acquisition, or sale of all or apportion of its assets, Personal Information may be transferred to the acquiring person or entity, in which case you will be notified via email and/or a prominent notice on our website of any such change in ownership or uses of Personal Information, as well as any choices you may have regarding Personal Information.
• ‍Advertising partners: We may partner with third party advertising networks, exchanges and social media platforms to display advertising on our websites or to manage and service advertising on other sites and we may share Personal Information with them for this purpose.

How We Protect Your Personal Information

All of your Personal Information remains private and confidential. The security of your Personal Information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

Cadana maintains a comprehensive written information security program that complies with applicable law and generally accepted industry standards. Our program includes appropriate administrative, technical and physical safeguards, procedures and practices to protect Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, the Cadana web application owned and operated by Cadana, or the Cadana Services, please contact us using the contact information below.

Cadana and its representatives will never request your account credentials. You should never share your Cadana account information, including your username and password, with anyone else. We recommend that you use a unique password for your Cadana account that is not associated with other websites. You should check your Cadana account regularly to ensure that your Personal Information has not been tampered with or altered. Any suspicious activity regarding your account, including automated messages or calls from parties you cannot identify, should be reported to your site administrator and Cadana using the contact information below.

Social Media Features

Our websites may use social media features, such as the Facebook “like” button, the “Tweet”button and other sharing widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. SocialMedia Features are either hosted by the respective social media network or hosted directly on our website. To the extent the Social Media Features are hosted by the respective social media networks and you click through to these from our website, the latter may receive information showing that you have visited our website. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile. Your interactions with Social MediaFeatures are governed by the privacy policies of the companies providing the relevant Social

Your Privacy Rights

When acting as a controller, and depending on your location, your jurisdiction, and subject to applicable law, you may have the rights below with regard to the Personal Information we control about you. We will respond to your requests within the appropriate timeline under applicable law.

The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you. You can do so at any time by contacting us using the contact details provided under the "How to Contact Us" heading below.

The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. As mentioned above, you can do so at any time by contacting us using the contact details provided under the"How to Contact Us " heading below.

The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.

You can also ask us to correct or update your Personal Information; object to the processing of your personal information; ask us to restrict processing of your Personal Information or request the portability of your PersonalInformation. Again, you can exercise these rights by contacting us using the contact details provided under the "How to Contact Us " heading below

You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you, or you can contact us using the contact information below.

Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent

You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

If your Personal Information has been submitted to us by or on behalf of our Customer (your employer) and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Customer directly. For more information on how your employer uses your Personal Information, please see your employer's privacy policy.

CCPA Personal Information Notices

As mentioned above, Cadana may provide third parties with certain personal information to provide or improve our products and services, for example to deliver products or services at your request. In such cases, we require those third parties to handle the information in accordance with applicable laws and regulations. Cadana does not sell personal information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018), nor does Cadana share personal information with third parties for their direct marketing purposes (pursuant to California Civil Code Sec.1798.83).

How to Contact Us

You can exercise your rights yourself or depending on your country or state, you may be able to designate an authorized agent to exercise these rights on your behalf. Please note that to protect your personal information, we will verify your identity by a method appropriate to the type of request you are making.For example, this could include sending an e-mail to an account on record, or asking you to identify a recent transaction or communication. We may also request that your authorized agent sign a declaration under the penalty of perjury attesting to their designation as your authorized agent, and that they have written permission from you to make requests on your behalf. We may also need to verify your authorized agent's identity to protect your personal information.

Please use the contact details below, if you would like to:

• Access this policy in an alternative format;
• Exercise your rights;
• Contact Cadana Data Protection Officer;
• Learn more about your rights or our privacy practices;
• Designate an authorized agent to make a request on your behalf; or
• For questions related to this Privacy Policy, or about any of your rights.

E-Mail: support@cadanapay.com

Retention of Person Information

We will retain your Personal Information for as long as is necessary to fulfill the services that you have requested, comply with any laws or regulations, resolve disputes, and enforce our agreements. Cadana may retain your data longer for a legitimate business interest Cadana business benefit is not outweighed by your personal rights and freedoms. Data entered into the Cadana Services and processed on behalf of our Customers as a service provider or processor is retained in accordance with any applicable agreement between Lattice and its Customer.

Information About Minors

Our website and services are not targeted at children under sixteen (16) years of age. As such, Cadana does not process or disclose Personal Information of minors under sixteen years of age. If you believe we have collected personal information about a child under sixteen, please contact us using the How to Contact Us Section above.

Updates to This Privacy Policy

Cadana may update this Privacy Policy from time to time and will notify account holders of significant changes in the way we treat any Personal Information, by sending a notice to the primary email address specified in your Lattice account. We may also place a prominent notice on our website. We encourage you to periodically review this page for the latest information on our privacy practices

International Data Transfers

Your personal information may be transferred to, and processed in the United States and in any other country where Cadana or its affiliates, subsidiaries or third party service providers maintain facilities or personnel. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). We follow applicable data protection laws when transferring personal data.If you are resident in or a visitor from the EEA, United Kingdom or Switzerland, we will protect your Personal Information when it is transferred outside of such locations by processing it in a territory which the European Commission has determined provides an adequate level of protection for Personal Information; or otherwise implementing appropriate safeguards to protect your Personal Information, including through the use of Standard Contractual Clauses or another lawful transfer mechanism approved by the European Commission.

Have more questions? We're here to help, so please contact us.

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