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Mosaic Group Privacy Policy
Effective: December 20, 2019

We at Mosaic have created this Privacy Policy to explain how we collect, use, disclose and otherwise process personal information in connection with operating our business. This Privacy Policy describes the practices concerning the information collected by Mosaic Group Holdings, LLC (“Mosaic, LLC”) and IAC Search and Media Europe Limited (“SAM EU” and together with Mosaic, LLC, “Mosaic”, “we”, “us” and “our”) through the use of our website on which this Privacy Policy is posted.

This Privacy Policy applies to your use of the Mosaic website (the “Site”) only and does NOT apply to other websites, products or applications operated by Mosaic or its operating businesses, such as Apalon, Daily Burn, iTranslate, Teltech and other Mosaic affiliates. Each product or service has its own privacy policy, and we refer you to such privacy policy for more details on how your information is collected and processed with respect to those products and services.

1. WHO WE ARE 2. WHAT WE DO 3. HOW WE COLLECT INFORMATION 4. HOW WE USE THE INFORMATION WE COLLECT 5. WITH WHOM WE SHARE YOUR INFORMATION 6. HOW LONG WE KEEP YOUR INFORMATION 7. WHERE WE STORE YOUR INFORMATION 8. THIRD-PARTY WEBSITES 9. INFORMATION FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA) 10. INFORMATION FOR RESIDENTS OF CALIFORNIA: YOUR CALIFORNIA PRIVACY RIGHTS 11. NOTICE TO NEVADA USERS 12. HOW WE PROTECT YOUR INFORMATION 13. INFORMATION RELATING TO CHILDREN 14. UPDATES TO OUR PRIVACY POLICY 15. HOW TO CONTACT US

1. WHO WE ARE

If you reside in the European Economic Area (“EEA”) then the company that is responsible for your personal information is our Irish affiliate, SAM EU. If you reside outside of the EEA then the company that is responsible for your personal information is Mosaic LLC.

2. WHAT WE DO

This site is intended to provide you with a range of content about our corporate affiliates and the products and services provided by them. It is intended for informational purposes only.

3. HOW WE COLLECT INFORMATION

We may collect information from you in a variety of different ways. Some of this information may identify you and some is anonymous information, such as your page views, link clicks, and login times. Your information may be kept in an identifiable format, or in a de-identified aggregate format which means that you cannot reasonably be identified from it. We provide further detail on the type of info we collect, and how we collect it, below: The information that we collect, whether from you directly or automatically, may be considered personal information in certain jurisdictions or personal data under the European General Data Protection Regulation (the “GDPR”). Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in the relevant jurisdiction.

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Categories of personal information we may collect:

A. Identifiers

Examples: Unique personal identifier, online identifier, IP address, email address or other similar identifiers.

B. Personal Records

Examples: Name, email address and username (only if you contact our support team).

Some personal information included in this category may overlap with other categories.

C. Internet or other similar network activity

Examples: Information on a consumer's interaction with a website or advertisement.

See Automatically Captured Information below for further details.

D. Geolocation data

Examples: Physical location (inferred from your IP Address).

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A. Information You Provide To Us. We may collect and store any information you provide when using the Site or that you provide in some other manner. This information may include information such as:

  • Your name and email address.

  • You may choose to send us communications through the email addresses or webforms listed on the Site. We may use emails that you send to us for any business purpose, including communicating with you, and we may disclose such correspondence with our trusted third party service providers who may only use it to provide services to us. You may request to receive newsletters such as Investor Relations emails. You may unsubscribe at any time by following the instructions at the bottom of the any such email or sending an email to us here. We will not sell your email address to third parties.

  • You may choose to apply for a position at Mosaic or one of our operating businesses. If you do, we may share your job application with any of our operating businesses that might have a relevant position for you. We (and our operating businesses) will only use your job application for employment-related purposes. You online job application will be collected and processed by a third party, currently Greenhouse Software, Inc. (“Greenhouse”). For more information on Greenhouse’s privacy practices, please review its privacy policy here.

B. Automatically Captured Information. We may automatically collect information from your computer and/or device when you use the Site. This allows us to assess how you have used the Site, the device you have used it on and helps us to analyze how we can optimize the Site for you in the future. This information may include information about your hardware and software such as your IP address, your browser type and language and other browser- related information and a time-stamp. C. Cookies and other tracking technologies. We are not currently deploying cookies, pixels, web beacons or other online tracking technologies on our Site. If we introduce cookies and other tracking technologies on our Site you will be provided with a notice and a cookie policy. D. Do not track signals. The Site’s systems are not configured to respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party Web sites or online services.

To process your information as described above, we rely on the following legal bases:

  • Provide you with the Site: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service, we use your information to provide you with a more customized and personal experience.

  • Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users behavior on our services to continuously improve our offerings, ensure it is bug free, and we process information for administrative, fraud detection and other legal purposes.

  • Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by either contacting us at the address provided at the end of this Privacy Policy.

4. HOW WE USE THE INFORMATION WE COLLECT We may use information that we collect about you to:

  • Deliver the Site to you;

  • Respond to your queries with the best possible answers;

  • Provide you with customer support;

  • Perform research and analysis about your use of, or interest in, the Site;

  • Communicate with you by e-mail, postal mail, display media and/or mobile devices;

  • Enforce our terms and conditions;

  • Manage our business and protect the quality of the Site, which includes maintenance of the Site systems;

  • Investigate complaints, abuse or other allegations; and

  • Perform functions as otherwise described to you at the time of collection.

5. WITH WHOM WE SHARE YOUR INFORMATION Authorized service providers: We may share your information with our authorized service providers that perform certain services on our behalf. These services may include:

  • providing customer service, technical and operational support, and email services;

  • marketing assistance, performing business and sales analysis,

  • supporting our Site functionality and other features offered through our Site, as well as when we have notified you, or you have requested, that we do so.

These service providers may have access to information, which is needed to perform their functions and allow us to provide you with the Site. Other Situations. We may disclose your information (i) in good faith compliance with a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency, (ii) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; (iii) to protect and defend the rights, property or safety of our company, our users, our employees, or others; (iv) to comply with applicable law or cooperate with law enforcement; (v) to enforce our Terms of Use or other agreements or policies; and (vi) in connection with a substantial corporate transaction, such as the sale of our business (or a majority of the assets of either), a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. In addition, we may share aggregated information we collect, under any of the above circumstances, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. 6. HOW LONG WE KEEP YOUR INFORMATION We only keep your personal information as long as it is necessary for the purposes set out in this Privacy Policy including for legitimate business purposes and as permitted by applicable law. We will only use your information to the extent necessary to comply with our legal obligations, resolve any legal issues, enforce our agreements, and as otherwise described in this policy. 7. WHERE WE STORE YOUR INFORMATION Information we collect, or permit third parties to collect may be transferred to, stored and processed outside your country of residence in any country or territory where one or more of our affiliated group companies, third party service providers or advertising companies or advertising networks are located or maintain facilities, including but not limited to the United States and Ireland. When your information is moved from your home country to another country, we ensure that such a transfer is done legally. For users based in the EEA, we may rely on the Model Clauses a standard document created by the European Commission to facilitate data transfers while ensuring that safeguards are put in place for personal information. We do not participate in the EU-US Privacy Shield but we may rely on it to transfer personal information to some of our service providers based in the USA, provided they are certified to receive such personal information pursuant to the Privacy Shield. By using the Site you consent to the transfer of your personal information as described in this Privacy Policy. 8. THIRD-PARTY WEBSITES There may be places in the Site where you may click on a link to access other websites that do not operate under this Privacy Policy, including Greenhouse. These third-party websites may independently solicit and collect information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy policy of all third-party websites you visit.

9. INFORMATION FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA) As a resident of the EEA, you may have some or all of the following rights in relation to how we use your personal information:

  • Access: you may request access to your personal information and receive copies of it; Correction: you may have inaccurate/incomplete personal information corrected and updated;

  • Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it;

  • Deletion: in certain circumstances, you can request a right "to be forgotten" (this is a right to have your information deleted or our use of your data restricted). We will honor such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it;

  • Portability: in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your personal information to transfer to another provider); and

  • Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.

If you are a resident of the EEA and you wish to access, change or delete personal information we hold about you, you may contact us here. If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide you with our Services or some of the features and functionality of our Services. In addition, you may contact us here to request that we not disclose your personal information to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as data processors). Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For example, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.

For your protection, we may require proof of identity and verification before we can answer the above requests.

10. INFORMATION FOR RESIDENTS OF CALIFORNIA: YOUR CALIFORNIA PRIVACY RIGHTS If you are a California resident, the California Consumer Privacy Act (“CCPA”) may provide you with rights that are in addition to those set forth elsewhere in this Privacy Policy rights regarding our use of your personal information. The CCPA Notice applies to “Consumers” as defined by the law. This section describes your CCPA rights as a California Consumer and explains how to exercise those rights. Access to Information and Data Portability Rights You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:

  • The categories of personal information we have collected about you.

  • The categories of sources from which we collected your personal information.

  • The business or commercial purposes for our collecting or selling your personal information.

  • The categories of third parties to whom we have shared your personal information.

  • The specific pieces of personal information we have collected about you.

  • A list of the categories of personal information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.

  • A list of the categories of personal information sold about you in the prior 12 months, or that no sale occurred. If we sold your personal information, we will explain: o The categories of your personal information we have sold. o The categories of third parties to which we sold personal information, by categories of personal information sold for each third party.

You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.

Data Deletion Rights Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.

Exercising Your Rights To make a request for access, portability or deletion according to your rights under CCPA, click here or mail your request for the attention of the Privacy / Legal Department to Mosaic, LLC., 330 West 34th St., 5th Floor, New York, NY 10001. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. 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 that the personal information relates to you. Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). The Verifiable Consumer Request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response. We will make commercially reasonable efforts to identify Consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. We do not “sell” personal information that we collect from you, in accordance with the definition of “sell” in the CCPA, and will treat personal information we collect from you as subject to a do not sell request. There is not yet a consensus as to whether third party cookies and tracking devices associated with our websites and mobile apps may constitute a “sale” of your personal information as defined by the CCPA. We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your personal information as permitted by the CCPA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly. California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. As discussed above, if we share Personal Information with third parties for their marketing purposes you will be able to elect for us not to do so by submitting your request here (please include your name, mailing address, and email address). To find out more about our “do not track” practices under Cal. Bus. & Prof. Code § 22575, see the “Do Not Track Signals” section of this Privacy Policy.

11. NOTICE TO NEVADA USERS

Under Nevada law, Nevada residents may opt out of the “sale” of certain “covered information” (as defined under Nevada law) collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by Nevada law, and we do not have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please contact us. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our practices change. 12. HOW WE PROTECT YOUR INFORMATION The security and confidentiality of you information is very important to us, thus we take certain security measures (including physical, electronic and procedural measures) to help safeguard your information from unauthorized access and disclosure. Please know that, despite our best efforts, no security measures are perfect or impenetrable. You are solely responsible for maintaining the confidentiality of any password you may use to access the Site. You agree not to transfer your user name or password, or lend or otherwise transfer your use of or access to the Site, to any third party. You are fully responsible for all activity that occurs in connection with your user name or password. You agree to immediately notify us of any unauthorized use of your user name or password or any other breach of security related to your account or the Site, and to ensure that you log off/exit from your account (if applicable) at the end of each session. We are not liable for any loss or damage arising from your failure to comply with any of the foregoing obligations. 13. INFORMATION RELATING TO CHILDREN We do not knowingly collect information from children under the age of 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws). If you are not over 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT ACCESS OR USE THE SITE. If you believe that we may have personal information from or about a child under the age of 16 years old, please contact us here. Note that we'll attempt to delete the account of any child under the age of 16 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account. 14. UPDATES TO OUR PRIVACY POLICY We reserve the right to update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will update the date of this Privacy Policy. Continued use of the Services after such date constitutes acceptance of such updates. When required by applicable law, we may inform you by additional means, such as through a notification on the website or in our mobile applications if we make material changes to how your personal information is collected, accessed or otherwise used as a result of your use of the Services or if your rights under this Privacy Policy are materially impacted by changes to our privacy practices. We recommend that you check this page from time to time to inform yourself of any changes in this Privacy Policy.

15. HOW TO CONTACT US You may contact us with questions, comments, or concerns about our services and this Privacy Policy or our privacy practices, or to request access to or correction of your information by submitting your requests or inquiries as detailed below: For our European users, our Data Protection Officer is responsible for ensuring your rights are respected and to review and oversee how we collect and use your personal information. They can be reached here. If you are a resident of California, please contact us here. Our support team can be contacted at contact@mosaic.co. OR Mosaic, LLC 330 West 34th Street, 5th Floor New York, NY 10001 Attention: Privacy Officer/Legal Dept.

Without prejudice to any other rights you may have, if you are located in the EEA, you also have the right to file a complaint against IAC SAM EU (the controller of your information) with the Irish Data Protection Commissioner ("DPC"), which is IAC SAM EU’s Lead Supervisory Authority. The DPC’s contact details are:

Office of the Data Protection Commissioner Canal House, Station Road Portarlington, Co. Laois, R32 AP23, Ireland Phone: +353 (0761) 104 800 LoCall: 1890 25 22 31 Fax: +353 57 868 4757 Email: info@dataprotection.ie If you live in the EEA, you may also file a complaint with your local data protection regulator. If you require this Privacy Policy in another language, please contact the appropriate customer support email in the How to Contact Us section of this Privacy Policy.

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