Privacy Statement

This Privacy Policy (“Policy”) explains the data protection practices of E-ntrepreneur DMCC

(“e-ntrepreneur” or “the Company”) when you visit or use the website, to which this policy is linked, and which is owned and operated by the Company. For the purposes of data protection laws,

E-trepreneur is a data controller (“Controller”). This Policy is incorporated into the Sites’ Terms and Conditions.

When you use our websites (including e-ntrepreneur.net) or related services (collectively “Site or Sites”), you trust us with your personal and non-personal information. This Policy applies to the personal and non-personal information you share with us through your activity on the Site and it describes:

• What information we collect and how we collect it;
• How we use information we collect;
• How we share information we collect;
• How we store and secure information;
• How we transfer information we collect internationally; and
• How to access and control your information

Each time you use the Site or provide us with information, you represent that you are accepting the practices described in this Policy at that time and consent to our collection, use, disclosure and transfer of your information. Please review this Policy each time you use the Site as we may revise certain sections of this Policy, and any changes will be effective immediately upon being published unless we inform you otherwise, subject to clause 10 below.

You are not required to provide personal information that we request, but, if you choose not to do so, in many cases we will not be able to provide you with our services or respond to any inquiries you may have.

Type of Information we collect:

The type of information we collect may be “personal” or “non-personal”. “Personal” information means any information relating to an identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We do not consider personal information to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise. We collect personal information from you and any devices (including mobile devices) you use when you: use our services, register for an account with us, provide us information on a web form, update or add information to your account, or when you otherwise correspond with us. We may also collect personal information from other sources, as described below.

INFORMATION WE COLLECT WHEN YOU USE OUR SITE MAY INCLUDE:

a) Basic subscriber information: for individuals includes given name (first name) and family name (last name), Social Security Number (for US citizens), Permanent Account Number (for Indian citizens), driver’s license, date of birth, email address; and for companies it includes company name and company EIN number

b) Information to process transactions: name, mailing address (with details such as city, state, country, zip), phone number, email address and contact preferences

c) Payment information: such as choice of payment method and basis, payment processor, associated transaction reference numbers/ IDs.

INFORMATION THAT IS AUTOMATICALLY TRANSMITTED:

d) Transaction information: details related to your use of our Site, including information about purchases you make, your subscriptions and other related transaction details

e) Usage and preference information: information about how you and Site visitors interact with our Site, preferences expressed, and settings chosen

f) Server Log Information: server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, device information, type of browser, use of cookies, tracking pixels and similar analytics technologies and the third-party site or service you were using before interacting with our Site

g) Your geolocation

Different ways in which we collect information:

We collect information about you when you provide it to us through your interaction with our Site, our employees, service partners and/ or use our other services. The primary sources of your information are:

INFORMATION YOU GIVE US WHEN YOU USE OUR SITE:

a) Sign-ups/ account registrations: when you register on the Site or sign in to an existing account, create or modify your profile, set preferences or navigate through our website

b) Website visits: when you visit our website(s)

c) Support channel: Information you provide through our customer support channel

d) Referral Program: when you choose to use our referral service to send out VIP Rewards Membership vouchers to potential customers or when you share referral links for introducing new Business Associates (“BAs”)

INFORMATION THAT IS COLLECTED AUTOMATICALLY:

e) Through location identifying technologies

f) Transaction information: when you participate in our shopping or any promotional activities, we may monitor and analyze trends, usage and activities

g) Cookie Technologies: through cookies we collect and store a user’s Site preferences, information for allowing Site log-ins and potential data to be used for advertising purposes h) Through tracking pixels and website tags that create and maintain unique identifiers

The Controller of the information will determine the purpose and means of any personal information that we collect and primarily rely on the following legitimate bases for processing such information:

a) Consent: applies when you have given consent to the processing of your personal information for one or more specific purposes. For instance, the Consent to Electronic Record where the Company requires that you consent to entering into an Independent BA Agreement (in an electronic form) with the Company before the agreement is executed. The entire agreement between you and

E-ntrepreneur will be evidenced by an electronic record and hence you must consent to the use of electronic record.

You must also read the Terms and Conditions of the BA Agreement, E-ntrepreneur’s Policies and Procedures and the Marketing and Compensation Plan for E-ntrepreneur’s official website at www.e-ntrepreneur.com and electronically acknowledge that you have read the documents.

b) Performance of a contract: applies where the use of your personal information is necessary to perform the terms and conditions of a contract to which you are a party or any other policies which may be applicable to you as a user of our Site.

c) Legitimate interest: applies where we use your personal information for our legitimate interests such as to improve our Site and related services, security purposes, fraud prevention, and to share information with our affiliates for internal administration.

The specific purposes for which we use the information we collect about you are listed below:

TO PROVIDE SERVICES AND MANAGE YOUR ACCOUNT:

Simply put, we collect personal information to provide services on our Site. We use information about you to provide services to you including registration services, authentication services when you log in, provide customer support, management and processing of your transactions, to allocate and disburse commissions, and operate and maintain the Site. We also use your personal information to equip you with our website Terms and Conditions, Policies and Procedures, Marketing and Compensation Plan, Privacy Policy and any updates and changes thereto. Your personal information that we collect also helps us to prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities.

TO IMPROVE OUR SERVICES AND TO COMMUNICATE WITH YOU ABOUT THE SERVICES:

We use the personal information we collect to provide, maintain, and improve our services. We are always looking for ways to make our services smarter, faster, secure, integrated and useful to you. We use collective learnings about how you use our services, through your usage, activity patterns etc., primarily to identify areas for integration and improvement. Further, we use information pertaining to your BA status based on your rank and active subscriptions, your customer status and value of purchase in order to determine and allocate commissions. We also use your information to send out newsletters informing you about our new launches, additional tools etc. that may help you optimize your earnings.

We also use your contact information to send transactional communications via email and within the services, including your purchase confirmations, reminders about business package renewals, responding to your questions and requests through customer support, and sending you technical notices, updates, security alerts, and administrative messages.

USE OF INFORMATION COLLECTED FROM COOKIES:

We further use information collected from cookies and other technologies, like tracking pixels, website tags, to improve your user experience and the overall quality of the Site. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer.

One of the other primary purposes of the cookies is to give you a convenient and time-saving function. If for example you are adapting a webpage or you are navigating on a website, a cookie will help the website recall your specific data in connection with a subsequent visit. This facilitates the process by delivering the relevant contents and navigation is made easier. When you return to the website, the previously supplied information is retrieved making it easy for you to use the functions you adjusted on the website.

Web beacons (also known as clear gif technology or action codes), as explained in the ensuing paragraphs, may be used for delivering cookies on our Website. This technology constitutes a tool that we use for compiling collected statistics on the use of E-ntrepreneur's websites, for example how many visitors have clicked key elements (such as hyperlinks or graphical elements) on one of

Entrepreneur's web pages or blog pages or a newsletter. We can share the collected statistics from our website with partner companies.

The data stored in cookies allows you to avoid filling out forms at every site access. The cookies produced have a maximum expiration period of six months. Furthermore, you may use your browser program to manage or deactivate cookies produced on this page.

The use of cookies by our partners, affiliates, merchants, tracking utility company, service providers is not covered by our privacy policy. We do not have access or control over these cookies.

USE OF WEB BEACONS:

Webpages on our Site can also contain electronic screens known as web beacons - also called single-pixel GIFs - which make it possible for E-ntrepreneur to count the users who have visited the pages and to provide adjusted services. E-ntrepreneur can attach web beacons to advertisement emails or newsletters to decide whether the messages have been opened and whether the recipients have reacted.

Some of these web beacons may be placed by third-party service providers for purposes of measuring the efficiency of our advertisement campaigns or e-mail messages. These service providers can use web beacons for placing a continuing cookie on your computer. By doing this it is possible for the service provider to recognize your computer each time you visit certain pages or read specific email messages, and to collect anonymous information in connection with showing these pages. E-ntrepreneur does not permit web beacons to be used for collecting or obtaining access to your personal data.

FOR PROVISION OF CUSTOMER SUPPORT:

When you contact us, we keep a record of your communication to help solve any issues you might be facing be it technical in nature or for example regarding your commission payouts.

TO PROTECT OUR LEGITIMATE BUSINESS INTERESTS AND COMPLY WITH LEGAL AND REGULATORY PROVISIONS:

Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with purposes which are a part of the normal business course of operations.

We may also use your information where you have given us consent to do so for a specific purpose not described above. While you have the right to provide us with your consent for the use of your specific information, you also have the right to manage your choice at any time (see Section 7 for further details).

We may share the information we collect, including your personal information, with the Group Companies and third parties. This disclosure may be required for us to provide you access to our services, to comply with our legal obligations, to enforce our User Terms Agreement, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our services. We attempt to minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose. For example:

SHARING OF INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS:

We work with third-party service providers to provide hosting, maintenance, backup, storage, payment processing, analysis and other services for us, which may require them to access or use information about you. A service provider accesses information about you, to the extent required, to perform services on our behalf. They do so under instructions from us and in line with our prevalent policies and procedures designed to protect your information. We do not sell your information to these third-party service providers. The third-parties with which we share your information primarily include:

• Payment processors
• Providers of business analytics services
• Internet domain registrars/ web hosting partners
• Web performance and security partners

Our website may also include links to these third-party websites whose privacy practices may differ from those on our website. If you submit personal information to any linked websites, your information is governed by the privacy statements provided by the linked website. We encourage you to carefully read the privacy statement of any website you visit.

USE OF DATA BY GOOGLE:

Our websites also use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use primary services on our Site or receive responses to any inquiries you may have. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

SHARING OF INFORMATION WITH OUR BUSINESS PARTNERS:

We work closely with our businesses partners and share your information with them for business administration purposes and to provide business essential services (such as BA mapping with BA ID). Our business partners are also subject to similar privacy policies ensuring equal protection for your data.

SHARING OF INFORMATION WITH OUR GROUP COMPANIES:

We are part of a group of companies that share various operations and business processes. We may share your personal data with members of our group in order to fulfill our contractual obligations to you, or because it is in our legitimate interests to do so (for example, whilst you may order a product from us, the delivery of that product might be fulfilled by another member of our group). Our group companies have privacy policies in place ensuring equal protection for your data as per this policy.

LEGAL PURPOSES:

We may also disclose your personal information when we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; or comply with a subpoena, or similar legal process where it is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or to any other third party with your prior consent to do so.

BUSINESS RESTRUCTURING:

We may share or transfer your information (including your personal information) in connection with, or during negotiations of any restructuring process with another company for say acquisition of all or a portion of our business, merger, sale of company assets, or financing. You will be notified via email and/or a prominent notice on our corporate website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

The security of your personal information is important to us. We work hard to ensure protection against the unauthorized access, use, alteration or destruction of your personal or financial information. We protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We use a secure, encrypted connection (using a SSL protocol) on all pages where you access or transmit personal information. We do not store credit card information on our Site.

We follow generally accepted standards to protect the 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, is 100% secure, however. Therefore, we cannot guarantee its absolute security. Except as otherwise set forth under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. If you have any questions about security on our Website, you can contact us at [email protected].

We will store and retain your personal information for as long as necessary to provide you the services you have requested, as long as your user account is active in our systems, or as reasonably useful for commercial purposes or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. After that time, we may anonymize and aggregate the data and retain it for analytical purposes. We may also retain your information to comply with applicable law, to support financial audits, to resolve disputes, to maintain compliance efforts, and for other legitimate business reasons.

You have the following rights concerning our processing of your personal information:

THE RIGHT TO ACCESS

You have the right, at any time, to inquire about the personal information we store about you and to request deletion or suspension of your personal information. Please use our ticket system at https://support.dublinetwork.com/hc/en-us.

THE RIGHT TO HAVE YOUR INFORMATION RECTIFIED OR ERASED OR PLACE RESTRICTIONS ON PROCESSING YOUR INFORMATION

You may correct your account information at any time by logging into your online or in-app account. If we hold any information about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date. Most contact details (address, phone, etc.) can be changed in the "Profile" area of the back office. However, due to account security protocols in place, the following fields cannot be changed directly by a Business Associate: First Name, Middle Initial, Last Name, Date of Birth, SSN/EIN, Company Name, Company EIN, Country, Email Address, change of financial information such as choice of payment processor. Should you need to change any of the above information, please contact customer support at https://support.dublinetwork.com/ . Should you wish to cancel your account, you must do so online in your back-office area by logging in at www.e-ntrepreneur.com and use the link “Contact” to cancel. This will lead to automatic termination of your Business Associate agreement and you will lose all rights to all remuneration under the E-ntrepreneur Compensation Plan.

Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our Terms, we may seek to resolve the issue before deleting your information.

THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR INFORMATION

e.g., for direct marketing purposes or where the processing is based on our legitimate interests;

THE RIGHT TO DATA PORTABILITY

The right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);

THE RIGHT TO WITHDRAW CONSENT

Where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions. You may further withdraw your consent to the use of electronic records at any time. However, should you do so, your Business Associate Agreement will be automatically terminated, and you will lose all rights to any downline organization (including but not limited to any property rights you may have), and you will lose all rights to all remuneration under the E-ntrepreneur Compensation Plan. Should you wish to withdraw your consent to the exclusive use an electronic agreement (and thereby terminate your agreement with E-ntrepreneur), you must do so online in your back-office area by logging in at www.dublinetwork.com and use the link “Contact” to cancel;

THE RIGHT TO OPT-OUT

You may restrict our use of your personal information for any promotional communications or newsletters. You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about services you have requested, or our ongoing business relations.

THE RIGHT TO LODGE A COMPLAINT WITH THE SUPERVISORY AUTHORITY

responsible for data protection matters.

In order to provide services to you, we may need to transfer your personal information outside the EU (if you are based in EU) to countries that may not necessarily apply the same standards afforded under the European data protection legislation. However, we take steps to ensure that where your information is required to be transferred outside of the EU by us or our service providers and hosting providers, that appropriate measures and controls in place to protect that information in accordance with applicable data protection laws and regulations. By using our Sites, products or services or by interacting with us in the ways described in this Policy, you consent to the transfer of your information outside the EU in the circumstances set out in this Policy. If you do not want your information to be transferred outside the EU you should not use our website, applications or services, and should contact us at [email protected]

We do not knowingly collect personal information from users below 18 years of age. If you believe that such a user has provided personal information to us, please contact us at [email protected] so that we can identify and delete that user's personal information.

This Policy is current as of the effective date set forth above. We reserve the right to change this Policy from time to time consistent with applicable privacy laws and principles. If we make changes to this Policy we will notify you by revising the date at the top of this Policy and provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an email notification to obtain your consent).

If you have any questions about this Policy or an unresolved privacy or data use concern, please contact us at https://support.dublinetwork.com/hc/en-us/ or [email protected]