Privacy Policy

PRIVACY POLICY

The terms of this Privacy Policy were last updated and go into effect on September 16th, 2022.
This Privacy Policy applies only to http://www.plusoneinnovates.com and related pages (the “Site”) and email communications
controlled by Plus One, LLC, a subsidiary of Plus Relocation Services, LLC. This Privacy Policy describes how Plus One, LLC and its subsidiaries and affiliated companies (“Plus One” or collectively, “we”, “us” or “our”) collect, use and disclose personal information of visitors to our Site, users of our online services and others to whom we expressly provide that this Privacy Policy will apply (collectively, “you” or “your”). It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

This Privacy Policy applies only to individuals who visit our Site or interact with us through e-mail. Please read this Privacy Policy
carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using our site in any way, such as browsing or interacting with the Site, you acknowledge that you have read, understood and agree to be bound by the terms and conditions set forth in this Privacy Policy and the Terms and Conditions of Use. Your acknowledgement includes your consent and agreement to the manner of collection and use of information, including the use of personal information (described below). If you do not agree with this Privacy Policy and the Terms and Conditions of Use, you may not use this Site.

THE PERSONAL INFORMATION WE COLLECT
For the purposes of this Privacy Policy, personal information is any information about or that can be linked to an identifiable
individual or household. We collect and maintain different types of personal information that you and/or your employer provide to us on a voluntary basis.

This may include:

  • contact and identification information, such as your real name, alias, unique personal identifier, IP address, postal address,
    telephone number, e-mail address, signature or other similar identifiers, and employer information;
  • commercial information, including products or services purchased, obtained, or considered, or other purchasing or
    consuming histories;
  • internet or other electronic network activity information, including, but not limited to, information regarding your interaction
    the Site;
  • product and service related information concerning the products and services that we provide to you or programs that we
    offer, including proof of purchase or receipt;
  • business relationship information, including information related to your agreements, preferences, feed-back and
    information requested by or provided to you;
  • inferences drawn from any of the information identified in this section to create a profile about you reflecting your benefit
    selection and demographic information; and
  • any other information that identifies, relates to, describes, is capable of being associated with, or could reasonably be
    linked, directly or indirectly, with you or your household.

If you email us a question or request, we may use your email address to process your request and respond to your question, which may involve collecting any personal information that you choose to provide to us in your email.
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis, resource planning, financial advisory services and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial, resource planning, regulatory and other analysts and advisors.

THE PERSONAL INFORMATION WE COLLECT FROM THIRD PARTIES
As a general rule, we collect personal information directly from you or through your employer or its designated representative. We do not collect any personal information from third parties.

HOW WE COLLECT AND USE PERSONAL INFORMATION
We collect personal information from you to enable us to manage, maintain, and develop our business and operations, including:

  • to establish, maintain and manage our relationship with you so that we may provide you with products and services that
    have been requested;
  • to perform services on behalf of you or your employer, including maintaining or servicing accounts, providing customer
    service, processing or fulfilling orders and transactions, and processing payments;
  • to be able to review the products and services that we provide to you so that we may understand your requirements for
    our products and services and so that we may work to improve our products and services;
  • to administer or otherwise carry out our obligations in relation to any agreement you or your employer have with us;
  • to protect us against error, breach of contract, negligence, fraud, theft, illegal activity and damage to our goods and
    property;
  • to alert you to updated information and other new products and services from us, or third-parties, or to forward
    promotional materials to you, where you have consented to receive such information;
  • to complete a transaction or service requested by you or your employer;
  • to respond to inquiries or requests submitted by you or your employer;
  • to ensure the Site is relevant to your needs;
  • to detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those
    responsible for that activity;
  • to debug to identify and repair errors that impair existing intended functionality;
  • to undertake internal research for technological development;
  • to help us create and publish content most relevant to you;
  • to further any commercial purposes, including any purpose to advance your interests, such as by inducing you to buy, rent,
    lease, join, subscribe to, or provide products, goods, information, or services, or enabling or effecting, directly or indirectly,
    a commercial transaction;
  • to enable us to comply with applicable law or regulatory requirements; and
  • any other reasonable purpose to which you consent.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

DISCLOSURE
Your personal information may be used and disclosed:

  • as permitted or required by applicable law or regulatory requirements;
  • to meet national security or law enforcement requirements;
  • to comply with valid legal processes such as search warrants, subpoenas or court orders;
  • as part of our regular reporting activities;
  • to protect our rights and property;
  • where the personal information is publicly available;
  • during emergency situations or where necessary to protect the safety of a person or group of persons investigate fraud, or
    respond to a government request; or
  • for any additional purposes for which we have obtained your consent.

We may disclose your personal information without your knowledge or consent where we are permitted or required by applicable
law or regulatory requirements to do so.
We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you. Additionally, we may share your information with service providers in connection with the services you have selected as part of your employer’s relocation benefit program. These services include, but are not limited to, household moving supplies, destination services, fitness or health clubs and assorted retail gift cards for furniture, food, entertainment, décor, and various home and organizational services, etc. Certain of our subsidiaries, affiliates, service providers and other parties with whom we share information under this Privacy Policy may perform activities outside of the European Union, Switzerland or the United States. As a result, your personal information may be collected, used, processed, stored or disclosed in the European Union, Switzerland, United States, or other jurisdictions. In such cases, your information may be subject to the laws of those countries. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. We do not sell, transfer or disclose your personal information to any third party and we will not sell, transfer, or disclose your personal information to any third party other than for the limited purposes described in this Privacy Policy, or if we provide you with notice and a right to opt-out of such sale. We may share aggregated information that does not directly identify you. We may disclose or transfer your personal information to third parties in connection with a corporate re-organization, merger or amalgamation, or the sale of all or substantially all of our assets, provided that the personal information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring this information.

TRACKING TECHNOLOGIES
When you visit our Site, we may automatically collect website use information, such as information about your operating system,
browser type, domain name, your access times, the website that referred you to us, the Web pages or services you request, and the
date and time of those requests. We use this information only to monitor our Site’s performance and improve our Site’s content and structure. Plus One and its partners use cookies to analyze trends, administer the Site, and track users’ movements around the Site. You may be able to control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Site.

As described in this Privacy Notice, Plus One and/or its third parties on our digital propert(ies) may use cookies and similar tracking technologies to collect information and infer your interests for interest-based advertising purposes. If you would prefer to not receive personalized ads based on your browser or device usage, you may generally express your opt-out preference to no longer receive tailored advertisements. Please note that you will continue to see advertisements, but they will no longer be tailored to your interests.

To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit: 

-Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices

-European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu

-Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/) .

In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple’s IDFA or Android’s GAID), visit the device manufacturer’s current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http://www.networkadvertising.org/mobile-choices 

SOCIAL MEDIA WIDGETS
Our Site does not include social media features.

CALIFORNIA’S DO NOT TRACK NOTICE
We do not track our web visitors across third party website to provide targeted advertising and, therefore, our Site does not respond to Do Not Track (DNT) signals. We do not support Do Not Track browser settings and do not currently participate in any Do Not Track frameworks that would allow our Site to respond to signals or other mechanisms from you regarding the collection of your personal information.

CONSENT AND OPT-OUT
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on
the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified at the relevant time.

If we seek additional information from you, beyond the information provided by you or your employer, we will seek your consent at the time that we collect any such additional personal information. If we plan to use or disclose your personal information for a
purpose not previously identified (either in this Privacy Policy or separately), we will advise you of that purpose before such use or
disclosure.

Unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy. You may change or withdraw your consent to the collection of personal information at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to, or acquire products or services from you or your employer.

From time to time, we communicate via email with users who request information. For example, we may use your email address to confirm a request you have made, to send you information about changes to our products and services, and to send notices and
other disclosures as required by law. If you do not wish to receive email communications from us, you may change or withdraw your consent at any time by contacting our Privacy Officer in writing using the contact information provided below.

PRIVACY POLICY REGARDING CHILDREN
Our Site is not intended to collect personal information from children under the age of 13. We urge parents to regularly monitor and supervise their children’s on-line activities. Please contact us if you believe we have inadvertently collected personal information from a child under the age of 13, so that we can delete such information.

LINKS TO OTHER WEBSITES
Our Site may offer links to other websites that may be subject to less stringent privacy standards. If you visit one of these linked
websites, you are then subject to the privacy policies and other policies of such website and are no longer protected by our policies. We are not responsible for, or able to monitor or control, the policies and practices of other companies, including with respect to their collection, use or disclosure or your personal information. You should review the privacy policies of these websites before providing them with personal information.

SECURITY
No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the
security of any information you transmit to us, and you understand that any information that you transfer to us is done at your own risk.

Once we receive your transmission, we make reasonable efforts to maintain physical, technical and procedural safeguards that are
appropriate to the sensitivity of the personal information in question. We use firewalls to protect your information from
unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information
may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. In addition, although we obligate third parties who support our Site and their related offers or other programs to use any personal information only for the purpose of performing their work, we do not control such third parties’ websites or other security measures.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective
steps. By using this Site or providing personal information to us, you agree that we can communicate with you electronically
regarding security, privacy and administrative issues relating to your use of this Site. We may post a notice on our Site if a security
breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending
on where you live, you may have a legal right to receive notice of a security breach in writing.

UPDATING OR ACCESSING YOUR PERSONAL INFORMATION
Upon request, Plus One Service will provide you with information about whether we hold any of your personal information. If you
wish to obtain access to the personal information that we maintain about you, or to correct, amend, update or delete such
information, please contact our Privacy Officer in writing using the contact information provided below. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We will endeavor to respond within an appropriate timeframe and, in any event, within any timeframe required by law. If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or
regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed or erased in accordance with our record retention obligations and
practices. In the event we cannot provide you with access to your personal information, we will inform you of the reasons why,
subject to any legal or regulatory restrictions. In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

CALIFORNIA CONSUMER PRIVACY ACT
Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, California residents have the right to:

  • Request that a business delete any personal information about the consumer which the business has collected from the
    consumer.
  • Request that a business that collects personal information about the consumer disclose to the consumer, free of charge,
    the following:
    o The categories of personal information that it has collected about that consumer.
    o The categories of sources from which the personal information is collected.
    o The business or commercial purpose for collecting or selling personal information.
    o The categories of third parties with whom the business shares personal information.
    o The specific pieces of personal information it has collected about that consumer.
  • Request that a business that sells the consumer’s personal information, or that discloses it for a business purpose disclose,
    free of charge, to the consumer:
    o The categories of personal information that the business collected about the consumer.
    o The categories of personal information that the business sold about the consumer and the categories of third
    parties to whom the personal was sold, by category or categories of personal information for each third party to
    whom the personal information was sold.
    o The categories of personal information that the business disclosed about the consumer for a business purpose.
  • Direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal
    information.

You may submit a request under the California Consumer Privacy Act through the following methods:
• You may call us toll-free at 1-888-251-2825.
• You may e-mail us at notices@plusoneinnovates.com.

To submit a request, we are required to verify your identity. Please be prepared to provide us with your address, phone number,
email address and employee ID. We will match the personal information that you provide to us with personal information that we
already maintain about you in order to verify your identity. We may also need to contact you to confirm your request. You may also designate an authorized agent to make a right to know or deletion request on your behalf. To use an authorized agent, you as the California resident must provide the agent with written authorization, including the verification information above. In addition, the agent will be required to verify their own identity with us. We may deny a request from an agent that does not submit proof that they have been authorized by the you to act on your behalf.

We may not be able to honor each request that we receive, but if we are unable to do so, we will respond to let you know our
reasons. We will not discriminate against you if you choose to exercise any of your rights as described in this section.

EUROPEAN UNION
This section of our Privacy Policy contains information for persons located in the European Union (“EU”), a European Economic Area (“EAA”) member state, or Switzerland. Before Plus One collects any personal information from you, you are entitled under the EU General Data Protection Regulation (“GDPR”), to the information in this section of our Privacy Policy. Purposes and Legal Bases for Processing Personal Information Plus One collects your personal information to provide our products and services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. We will collect and process your personal information as necessary for the performance of a contract to which you are a party or because we have another legitimate interest in doing so relating to our business purposes arising from your relationship with us. We may also seek your prior consent or rely on some other lawful basis to process your personal information. Our legitimate interests include but are not limited to:
• Provide you with the products and services you request, view, engage with, or purchase;
• Communicate with you regarding your account or transactions with us; and
• Operate, understand, optimize, develop, or improve our sites, applications, products, services, and operations.

Rights of Users Located in the EU
If you use this website and are located in the EU, EAA, or Switzerland, you are entitled by law to access, correct, amend, or delete
personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not
absolute and certain exemptions may apply to specific requests that you may submit to us.

  • The right to access. You have the right to ask us for copies of your personal information. When making a request, please
    provide an accurate description of the personal information to which you want access. Where requests are repetitive or
    manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.
  • The right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right
    to ask us to complete information you think is incomplete.
  • The right to erasure. You have the right to ask us to erase your personal information in certain circumstances, including
    your personal information to be erased to comply with a legal obligation under EU or member state law.
  • The right to restrict processing. You have the right to ask us to restrict the processing of your personal information in
    certain circumstances, including: (i) when the accuracy of the personal information is brought into question, or (ii) when we
    no longer need the personal information for purposes of the processing, but require such personal information for the
    establishment, exercise, or defense of a legal claim.
  • The right to data portability. You have the right to ask that we transfer the personal information you gave us from one
    organization to another or give it to you.
  • The right to withdraw consent. If Plus One obtains your written consent to collect and process your personal information,
    you can subsequently withdraw such consent as to any further processing of information.
  • Automated decision-making. To the extent that Plus One engages in decision-making based solely on automated
    processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the
    right not to be subject to such decision-making.

To exercise these rights please contact us using the Contact Information below. For your protection, we may need to verify your
identity before responding to your request. If we refuse a request, we will provide you a reason as to why.

Right to Object to Processing
You have the right to object to the processing of your personal information that is based on legitimate interests. If you make such
an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment,
exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us using the
Contact Information below

Cross-Border Transfers of Personal Information
Personal information that you provide while in the EU, an EAA member state, or Switzerland will be transferred to the United States. The GDPR permits such transfer when necessary for the performance of a contract between you and Plus One, if Plus One obtains your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective of your privacy as those in your location. If we transfer personal information from the EU, we will provide an appropriate safeguard such as Privacy Shield.

Retention of Your Personal Information
We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

EU – U.S. PRIVACY SHIELD AND SWISS-US PRIVACY SHIELD
We, through our affiliate Plus Relocation Services, LLC (“PLUS”) comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom and/or Switzerland, as applicable to the United States in reliance on Privacy Shield. PLUS has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

We are responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

Our commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal
Trade Commission. If you believe that we are not processing your personal data within the scope of our Privacy Shield certification, you may direct any inquiries or complaints concerning our Privacy Shield compliance in the following ways:

1) In the first instance, please send your inquiry or complaint to:

Plus Relocation Services, LLC
600 Hwy 169 South, Suite 500
Minneapolis, MN 55426
United States of America
ATTN: Privacy Officer
privacy@plusoneinnovates.com

2) If you are not satisfied with our response, for complaints that cannot be resolved with us directly, if you have an
unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third
party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

3) Under certain conditions, more fully described on the Privacy Shield website
https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint you may invoke binding arbitration when other
dispute resolution procedures have been exhausted.

CHANGES TO THIS PRIVACY POLICY
From time to time, we may revise this Privacy Policy as well as the Terms and Conditions of Use. Any revisions made will be posted within the Privacy Policy or Terms and Conditions of Use, as applicable, on the Site and will take effect immediately as indicated by the “last updated” date, unless otherwise noted. Collection and use of information from that point forward will be subject to the revised terms. If you do not agree with any revision to this Privacy Policy or Terms and Conditions of Use, you must stop using and accessing the Site. Your continued access or use of the Site after any such revisions are posted will constitute your acceptance of these changes. You should review the Privacy Policy and Terms and Conditions of Use from time to time for any changes. This Privacy Policy was last updated on September 16th, 2022.

GOVERNING LAW / VENUE / FORUM
Unless otherwise noted in this Privacy Policy, this Privacy Policy and Terms and Conditions of Use shall be governed by the laws of the State of Minnesota and by the federal laws of the United States, excluding their conflicts of laws provisions. Without prejudice to the procedure for making inquiries or complaints under the Privacy Shield Framework, as outlined below, all disputes, controversies and disagreements between the parties arising out of or related to this Privacy Policy shall be exclusively submitted for, resolved and finally settled by, binding arbitration. The arbitration shall be conducted by three (3) arbitrators exclusively in Hennepin County, Minnesota, in accordance with the Commercial Arbitration Rules of the American Arbitration Association. The Parties waive any objection that might be made on the ground that such venue may be in an inconvenient forum.

CONTACT INFORMATION
We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. To ask questions or provide any comments
about this Privacy Policy or our privacy practices, please use the following contact information:

Plus One Services, LLC
600 Hwy 169 South, Suite 500
Minneapolis, MN 55426
United States of America

ATTN: Stacey A. Myhro, CCMAP
Toll-Free: 1-888-251-2825 (Mon-Fri, 8 am – 5 pm MST)
Direct: 952-512-5530
Fax: 952- 593 2748
Email: privacy@plusoneinnovates.com

We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.