PRIVACY POLICY

1. PURPOSE

This Privacy Policy (“Policy”) is incorporated by reference into the Onovo Terms and Conditions (the “Terms”). The term “Onovo ,” “we,” and “us” includes Onovo. and our affiliates and subsidiaries, including without limitation Onovo. The Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can optout of a use or correct or change such information. All other terms not defined in Section 14 or otherwise herein will have the meanings set forth in the Terms.

2. SCOPE

This Policy applies to Personal Information that is Processed by Onovo  in the course of our business, including on Onovo  websites (each a “Site”), mobile applications, and other online, offline or in-store offerings (together with any and all future online and offline offerings operated by or on behalf of Onovo , the “Services”). “Personal Information” is any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular identified or identifiable natural person or device.

All individuals whose responsibilities include the Processing of Personal Information on behalf of Onovo  are expected to protect that data by adherence to this Policy. This Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

3. TRANSPARENCY/NOTICE–TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Onovo  and the requirements of applicable law. Some of the ways that Onovo may collect Personal Information include:

You may provide Personal Information directly to Onovo  throughinteracting with the Services, participating in surveys, during events, and requesting products, Services, or information. As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below. We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

3.1 TYPES OF PERSONAL INFORMATION WE COLLECT

Onovo  collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and Employees (collectively “Individuals”). Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Onovo , requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

Purchases. When you purchase products or services from Onovo, you must provide us with Personal Information, such as your name, email address, address that are associated with your debit/credit card. Please note that we do not store credit/debit card numbers.

Communications with Us. We may also collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our products and Services, register for a newsletter or loyalty program that we may offer from time to time, contact customer service or otherwise communicate with us.

Surveys. From time to time, we may contact you to participate in online surveys or in-person interviews and focus groups. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys or interviews is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein. Posting on the Site. We collect information you post through the Site. For example, when you interact with other users or the Site by posting a review or other materials, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth here in.

Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile advertising identifiers, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences. To the extent devices transmit location data through GPS, Bluetooth, or WiFi signals, we may also collect this data. Promotion and Giveaways. Occasionally we will partner with Third Parties on social media and online channels to sponsor giveaways and promotions. Terms and conditions will accompany each give Onovo  and promotion, and it is the responsibility of all entrants to read the terms and conditions and privacy policies carefully. If you choose to share your information in order to participate in a give Onovo  or promotion, your entry information may be shared with such Third Parties. Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations, which may supplement information provided by you. This supplemental information can allow us to verify information that you have provided to Onovo  and enhances our ability to provide you with information about our business, products, and Services. For example, if you access Third-Party services, such as Facebook or Twitter, to login to the Services or to share information about your experience with Onovo , we may collect information from these Third-Party services.

3.2 HOW ONOVO  USES YOUR PERSONAL

INFORMATION

We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including: To Provide Products, Services, or Information Requested: Onovo may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to: Generally manage Individual information and accounts; Respond to questions, comments, and other requests; Support the tracking and recovery of your Onovo  and/or other products; Provide access to certain areas, functionalities, and features of Onovo  Services; Allow you to register for events. Administrative Purposes: Onovo  may use Personal Information about you for its administrative purposes, including to: Measure interest in Onovo  Services; Develop new products and Services; Ensure internal quality control; Verify Individual identity; Communicate about Individual accounts and activities on Onovo  Services and systems, and, in Onovo  discretion, changes to any Onovo  policy; Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance; Process payment for products or services purchased; Process applications and transactions; Comply with regulatory requirements, including collecting and using information relating to adverse effects you have experienced when using our products; Prevent potentially prohibited or illegal activities; Enforce our Terms of Use. Marketing Onovo Products and Services: Onovo  may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Onovo  may provide you with these materials via online social platforms, websites, phone, text/SMS, postal mail, facsimile, or email, as permitted by applicable law. Such uses include: To tailor content, advertisements, and offers; To notify you about offers, products, and services that may be of interest to you; To provide Services to you and our sponsors; For other purposes disclosed at the time that Individuals provide Personal Information; or Otherwise with your consent. You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below. Research and Development: Onovo  may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Onovo  may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes. Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, referral offers, newsletters, mailings, or phone calls from us with information on Onovo  or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below. Mobile Devices. From time to time, Onovo  may provide Services that are specifically designed to be compatible and used on mobile devices. Onovo  will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings and the operating system of your device. Mobile versions of Onovo  Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with user accounts. In addition, Onovo  may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Onovo  to enable Individuals to access user accounts and to enable Onovo  to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Onovo  may use personal or non-identifiable information transmitted to Onovo  to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Policy or in other notices Onovo  provides. Anonymous and Aggregated Information. Onovo  may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Onovo  Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Onovo  may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Onovo  and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you. Information Submitted Via Services. You agree that Onovo  is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/ or marketing goods or Services. Onovo will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law. Sharing Content with Friends or Colleagues. Onovo  Services may offer various tools and functionality. For example, Onovo  may provide functionality on its Services that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Onovo  or any other Third Parties for any other purpose. Other Uses. Onovo  may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

3.3 COOKIES, PIXEL TAGS/WEB BEACONS, AND ANALYTICS

INFORMATION

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices to automatically collect information through the Services. Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly. Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting and other providers to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. Google Analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/ policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. Our uses of such Technologies fall into the following general categories: Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions; Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools; Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites; and Advertising or Targeting Related. We may use first-party or thirdparty cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement. If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.4 THIRD-PARTY SITES AND SOCIAL MEDIA PLATFORMS

The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Onovo does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk. The Site and our other Services may also contains links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes.

4. ONWARD TRANSFER – ONOVO MAY DISCLOSE YOUR PERSONAL INFORMATION; SHARING OF PERSONAL INFORMATION

4.1 PERSONAL INFORMATION WE SHARE

We may share your information as described in this Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission. We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Onovo  has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements. Business Partners. Onovo  may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested Onovo may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Onovo name. Onovo requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Onovo provided them. Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information. Marketing. Interest-Based Advertising and Third Party Marketing. Through our Services, Onovo may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Onovo  related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 6 below. Disclosures to Protect Us or Others (e.g., As Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Onovo  policies or contracts; (v) to collect amounts owed to Away; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities. Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. Should such an event occur, Onovo  will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Policy in effect at the time such Personal Information was collected. In the preceding twelve (12) months, we have not sold any Personal Information.

4.2 DATA TRANSFERS

All Personal Information collected via or by Onovo  may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Onovo, you consent to the storage of your Personal Information in these locations.