SHENHAV LLC WEBSITE PRIVACY POLICY

1. Introduction

Shenhav LLC (“Shenhav” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy. This privacy policy describes the types of information we may collect from you or that you may provide when you visit or access our websites or platforms (the “Platform”) and our practices for collecting, using, maintaining, protecting and disclosing that information.

Our Platform provides information, content and resources to local, state and federal political candidates across the United States (the “Services”). We provide some Services directly to you, and we also create connections by which you can obtain other services from third-party providers (“Third-Party Services”). By using this Platform, you acknowledge and agree that Shenhav does not control how these providers of Third-Party Services collect, use or disclose your information, including through cookies or other tracking technologies on their pages. For more information on a third-party provider’s privacy practices, please review that entity’s privacy policy and its Terms of Service.

This privacy policy applies to information we collect either (i) on the Platform, (ii) through email, text or other electronic messages between you and this Platform, or (iii) through mobile and desktop applications you download from this Platform, which provide dedicated non- browser-based interaction between you and this Platform. This policy does not apply to information collected by (i) us offline or through any other means, including any publicly- available information, or (ii) any third party, including our affiliates, including through any application or content (including advertising) that may link to or be accessible from or through the Platform.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should choose not to use our Platform or the services we provide. By accessing or using this Platform, you agree to this privacy policy. If we are notified or otherwise come to learn that you are violating or have violated either our Content Standards or our Terms of Service, we have the right to take appropriate legal action, including the disclosure of your Personal Information to law enforcement authorities. We retain the right to immediately terminate or suspend your access to all or part of the Platform for any or no reason.

This Platform is intended for use by individuals who are eighteen (18) years of age or older and are located in the United States.

2. Changes to our Privacy Policy

We reserve the right to revise, replace and update this privacy policy from time to time in our sole discretion. All changes are effective immediately upon our posting them to the Platform. The date the privacy policy was last revised is identified at the top of the page. Your continued use of or access to this Platform following the posting of a revised privacy policy means that you accept and agree to the changes. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Platform home page. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you, and for periodically visiting this page to check for updates, so you are aware of any such changes, as they are binding on you.

3. Children Under the Age of 18

Our Platform is not intended for children under 18 years of age. No one under age 18 may provide any personal information on our Platform. We do not knowingly collect personal information from children under 18. If you are under 18 years of age, do not use or provide any information on this Platform or through any of its features. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at tech@shenhav.com.

4. Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Platform, including information:

• by which you may be personally identified, such as your name, address of residence, billing address, email address, or telephone number (“Personal Information”);
• that is about you but individually does not identify you; and/or
• about your internet connection, the equipment you use to access our Platform, and usage details (such as times and dates of visits to the Platform).

We collect this information either (1) directly from you when you provide it to us, and/or (2) automatically as you navigate through the Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies and/or other tracking technologies.

Personal Information does not include publicly available information from government records that we may obtain from other sources.

5. Information You Provide to Us

The information we collect on or through our Platform may include (i) information that you provide by filling in forms on our Platform (including information provided at the time of registration or subscription) or uploading information to our Platform, (ii) records and copies of your correspondence (including email addresses), if you contact us, (iii) the contents of your non-public messages made via the Platform to other subscribers (“Direct Messages”), (iv) details of transactions you carry out through our Platform (including financial information connected with the purchase of a subscription, products or services), (v) information you provide when making a purchase on our Platform, (vi) documents that prove your identity for purposes of obtaining Gold Verified account status, and/or (vii) any other types of information you may provide to Shenhav.

Documentation that you provide to verify your identity for purposes of obtaining a Gold Verified account shall not be used or saved for any other purpose by Shenhav or Stripe Identity.

Your Direct Messages are transmitted to others at your own risk. Although we may limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Platform to whom you may choose to send Direct Messages. Therefore, we cannot and do not guarantee that your Direct Messages will not be viewed by unauthorized persons. We will not save the content of your Direct Messages indefinitely; this information will be deleted from the Platform after one hundred twenty (120) days.

6. Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (i) details of your visit(s) to our Platform, including location and other communication data and the resources that you access and use on the Platform, and (ii) information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include Personal Information. This information helps us to improve our Platform and the services we provide, including by enabling us to (i) estimate audience size and usage patterns, (ii) store information about your preferences, allowing us to customize our Platform according to your individual interests, (iii) speed up user searches, and (iv) recognize you when you return to our Platform. We will not share this collected data with other parties.

The technologies we use for this automatic data collection includes cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.

7. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Platform are served by third-parties, including networks and servers, content providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Platform. The information they collect may be associated with your Personal Information when necessary to provide you with services through the Platform. Any Personal Information collected in this manner will not be used other than as needed to provide services to you.

8. How We Use Your Information

We use information that we collect about you or that you provide to us, including Personal Information, in the following ways:

• To improve our Platform and present its contents to you.
• To provide you with information, products, or services that you request or purchase from us (e.g., order fulfillment, billing, and delivery).
• To fulfill any other purpose for which you provide it, including the processing of payment for your purchase.
• To provide you with email alerts or other notices concerning our products or services, or events or news, that may be of interest to you.
• To link you with a third-party so that you may purchase Third-Party Services.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Platform or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Platform.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

WE WILL NEVER SELL ANY OF YOUR PERSONAL INFORMATION WITHOUT YOUR CONSENT.

9. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal information that we collect or you provide as described in this privacy policy:

• To contractors, service providers and other third parties we use to support our business.
• To fulfill the purpose for which you provide it (e.g., for connecting with a Third-Party Services provider or customer support).
• To successors of all or part of our business; e.g., if Shenhav merges with, is acquired by or acquires, or sells part of its business to another business entity.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Service, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Shenhav, the users of our Platform, or others.

10. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. In order to exert certain control over your information, you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

11. Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information. California’s “Shine the Light” law (Civil Code Section §1798.83) permits users of our Platform that are California residents to request certain information regarding our collection of their Personal Information, including their right to access such information. In addition, residents of California and certain other states may have the following rights: (i) the right to request that we delete Personal Information about you that we have collected from you; (ii) the right to request that we correct inaccurate Personal Information that we maintain about you; and/or (iii) the right to non-discrimination in the event that you exercise your privacy rights under applicable law. To make such a request, please send an email to tech@shenhav.com or write us at: 2 Research Place, Suite 310, Rockville, MD 20850.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”) requires that we disclose the criteria we use to determine how long we will retain each category of Personal Information we collect, or the criteria we use to determine the relevant retention period. We consider the following factors when considering how long we will retain such information: our need to use such information to continue to provide the services to which you have subscribed, our need to use such information to fulfill our legal and contractual obligations, and our need to use the information to fulfill the purposes for which such information was collected.

12. Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to use is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Platform. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

You should report any security violations that you become aware of to us at this email address: tech@shenhav.com.

13. Contact Information

This Platform is operated by Shenhav 2 Research Place, Suite 310, Rockville, MD 20850. To ask questions or provide feedback about this privacy policy and our privacy practices, contact us at: tech@shenhav.com.