CUBBY ENTERPRISES, INC. PRIVACY POLICY

Last Updated _______, 2022

This Privacy Policy applies to Personal Data (defined below) processed by Cubby Enterprises, Inc. (“Cubby,” “we,” “us,” or “our”) in the course of providing software solutions to self-storage companies (our “Customers”) to manage and rent their storage units, as collected from [our website (the “Site”), our platform, which may be accessible from our Customers’ websites (our “Platform”), and our related online service offerings (collectively with the “Site” and the “Platform”, the “Services”)].This Privacy Policy explains what Personal Data we collect, how we use and share that data, and your choices concerning our data practices. It also explains how we engage with our payment processor to provide the Services to you.If you submit Personal Data to our Platform through one of our Customers’ websites (a “Customer Site”), the processing of your Personal Data is also subject to the Customer’s data practices. Please review the Customer’s privacy policy on the Customer Site. Before using the Services or submitting any Personal Data to us, please review this Privacy Policy carefully and contact us at privacy@cubbystorage.com if you have any questions. By using the Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not access or use the Services. PERSONAL DATA WE COLLECTWe collect information that alone or in combination with other information in our possession personally identifies you (“Personal Data”) as follows:Personal Data You Provide: We collect Personal Data when you visit the Site or Platform, register to use the Services, in connection with your use of the Services, and in other instances where you may provide it to us. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it will generally include [your name, email address, mobile phone number, physical mailing and billing address, government identification, vehicle titles, and any documentation required by our Customer in order for you to rent a unit.] We will also collect certain payment information in connection with the Services, including as necessary to ensure payments can be processed by our third-party payment processors, such as Payrix Solutions, LLC. (“Payrix”). Accordingly, in addition to this Privacy Policy and our Terms of Service, information related to your purchases is also processed according to Payrix’s Privacy Policy. Personal Data We Receive Automatically From Your Use of the Services: When you visit, use and interact with the Services, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Services, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Google Chrome, Microsoft Edge, etc.), and geographical location information. In particular, the following information may be created and automatically logged in our systems: Log data: Information that your browser automatically sends whenever you visit the Service (“Log Data”). Log Data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Service. Cookies: Please see the “Cookies” section below to learn more about how we use cookies.Device information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings. Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.Cookies: We use cookies to operate and administer our Service, gather usage data on our Service and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.Analytics: We may use certain third-party analytics providers, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Service and enhance your experience when you use the Service. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.Online Tracking and Do Not Track Signals: We and our third-party service providers, including Google, Facebook, and Instagram, may use cookies, pixels or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Service and use that information to send targeted advertisements. Our Service currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so. Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers: Microsoft EdgeMozilla FirefoxGoogle ChromeApple SafariPlease note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Service and you may not be able to benefit from the full functionality of the Service.Advertising networks may collect Personal Data through the use of cookies. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.If you access the Service on your mobile device, you may not be able to control tracking technologies through the settings. HOW WE USE PERSONAL DATAWe may use Personal Data for the following purposes:To provide and facilitate your engagement with the Services, including to support, process and fulfill your rental of our Customer’s units;To facilitate our Customers’ ability to manage their units, including tracking which units are available, who their tenants are, and what prospective tenants have inquired about units;To respond to your inquiries, comments, feedback or questions;To send administrative information to you, for example, information regarding the Services, and changes to our terms, conditions, and policies;To secure documentation including identification and vehicle title records required in lien lawTo administer a promotion, contest, sweepstakes, survey or other Services feature;To analyze how you interact with our Services;To maintain and improve the content and functionality of the Services;To develop new products and services;To prevent fraud, criminal activity, or misuses of our Services, and to ensure the security of our IT systems, architecture and networks; andTo comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.Aggregated or Anonymized Information. We may collect or generate aggregated and/or anonymized Personal Data and use the aggregated and/or anonymized information to analyze the effectiveness of our Services, to improve and add features to our Services, and for any other lawful purpose. In addition, we may share aggregated and/or anonymized information with our business partners and other third parties. We may collect or generate aggregated and/or anonymized information through the Services, through cookies, and through other means described in this Privacy Policy.[Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us at [insert email address]. If you unsubscribe from our marketing lists you will no longer receive marketing communications, but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.]SHARING AND DISCLOSURE OF PERSONAL DATAIn certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, ecommerce services, order fulfillment services, email communication software and email newsletter services, advertising and marketing services, financial services providers and payment processors (including Payrix), customer relationship management and customer support services, and web analytics services (for more details on the third parties that place cookies through the Service, please see the “Cookies” section above). Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data, and to limit their use and other processing of your Personal Data to the performance of their services for us.Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.Affiliates: We may share Personal Data with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Cubby. Our affiliates may use the Personal Data we share in a manner consistent with this Privacy Policy.DATA RETENTIONWe keep Personal Data for as long as you use the Services or as reasonably necessary or advisable to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, protect against fraud, enforce our agreements, and comply with applicable laws. UPDATE YOUR INFORMATIONPlease contact us at [email address] if you need to change or correct your Personal Data. CHILDRENOur Service is not directed to children who are under the age of 18. Cubby does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to us through the Service please contact us at [email address]. and we will endeavor to delete that information from our databases.LINKS TO OTHER WEBSITES AND THIRD PARTY FUNCTIONALITYThe Services may contain links to other websites or applications, or other functionality not operated or controlled by Cubby, including [insert] (“Third-Party Services”). You will generally have discretion and control over the Third-Party Services with whom you elect to interact and share your Personal Data, except as otherwise provided in this Privacy Policy. These Third-Party Services include certain payment processors or other API finance solutions, such as Payrix. The information that you share with Third-Party Services will be governed by the specific privacy policies and terms of service of the Third-Party Services and not by this Privacy Policy. By providing these links or functionality we do not imply that we endorse or have reviewed these services. Please contact the Third-Party Services directly for information on their privacy practices and policies. SECURITYYou use the Services at your own risk. We implement commercially reasonable technical, administrative, and organizational measures designed to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services or e-mail. Please keep this in mind when disclosing any Personal Data to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or third-party websites.YOUR CHOICESIn certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Service, you may be unable to use those features. You can also contact us at [email address] to ask us to update or correct your Personal Data.INTERNATIONAL DATA TRANSFERSAll information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States and other countries. If you are accessing our Site from the European Economic Area (“EEA”) or other regions with laws governing data collection and use, please note that your Personal Data will be transferred to and stored in the United States as necessary for the purposes described in this Privacy Policy, and Personal Data may be transmitted to our service providers supporting our business operations (described above). The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located.CHANGES TO THE PRIVACY POLICYThe Services, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Services or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.CONTACT USIf you have any questions about our Privacy Policy or information practices, please feel free to contact us at [email address].