Effective Date: January 1, 2020:

Jerome Alexander Consulting Corporation (“Jerome Alexander,” “we,” or “us”) respects your privacy. This privacy policy (“Privacy Policy”) provides you with information regarding how we collect, use, and disclose information when you visit all Jerome Alexander-owned websites and domains (collectively, our “Sites”).

PLEASE NOTE: BY USING OUR SITES, YOU CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND TO OUR PROCESSING OF INFORMATION FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SITES.

A. Information Collected

This Privacy Policy applies only to information that you provide to us online while visiting our Sites and does not apply to any information that we have received or obtained or may obtain offline or through other traditional means. We may collect information about you from various sources, such as:

Directly from youwhen you use our Sites; andOur affiliates, services providers, business, parties, and other third parties.

For the purposes of this Privacy Policy, “personal information” is information that identifies you personally, such as your name, address, telephone number, email address, or company name. The personal information that we may collect about you may include, without limitation:

Contact information, such as name, postal address,email address, and phone number;Demographic information, such as age, date of birth, gender,companyinformation;andLogin information, such as usernameandpassword.

While you may provide your billing or credit card information to make a purchase from us, this information is handled by our third-party service providers.

Much of the information that we collect on our Sites is provided directly by you, such as when you make a purchase, sign up for a mailing list, or communicate with us about a product or an order. We also collect certain information about you automatically in connection with your use of our Sites, including by use of cookies and web beacons.

Cookies.Like most e-commerce websites, we use“cookies”technology. A cookie is a very small text file that a website can save onto your computer’s hard disk to store your information and settings. When you log on, the cookie tells us whether you have visited us before or are a new visitor. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but if you do, you may not be able to take advantage of the personalized features enjoyed by other users to our Sites. Some of the cookies we use may be“Flash”cookies. A Flash cookie is a data file placed on a computer via the Adobe Flash plug-in that may be built-in to or downloaded by you to your computer. While they are harmless, depending on your browser, these cookies may not be deleted when your cookies are deleted or disabled and, in some instances, they may cause your cookies to reappear in your browser. Please check your browser to determine where these types of cookies are stored and how they may be deleted or disabled.Web Beacons(also known as“clear gifs,”“web bugs”or“pixel tags”).“Webbeacons”are tiny graphics with a unique identifier, similar in function to cookies, and are used to allow us to count users who have visited certain pages ofour Sitesand to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, web beacons can tell the sender whether and when the email has been opened. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded invisibly on web pages.

This automatically collected information helps us to improve and personalize our Sites, including by enabling us to identify and authenticate users. To the extent that this automatically collected information includes personal information, we will maintain it in accordance with this Privacy Policy.

Additionally, we use certain third-party service providers, including specifically Google Analytics, to assist us by providing analytics information for our Sites. For more information about Google Analytics’ privacy practices, see here: https://policies.google.com/technologies/partner-sites. You may opt out of the aggregation and analysis of data collected about you on the Sites by Google Analytics by installing the following browser extension from Google: https://tools.google.com/dlpage/gaoptout.

B. Use Of Information Collected Via The Site

We use your personally identifiable information that is collected on our Sites to:

Deliver services, such as products, information, or newsletters you request or purchase;Alert you to special offers, updated information and other new services, or other third parties, or to forward promotional materials;Complete a transaction or service requested by you;Fulfill the terms of a promotion;Ensureour Sitesis relevant to your needs;Notify you about a material change to this Privacy Policy or other terms pertaining toour Sitesor our products, if necessary;Enforce our agreements with you;Comply with applicable legal requirements and legal standards;Protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;andContact you in response to sign up forms such as“Contact Us”or“Order Now”.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

C. Sharing And Disclosure Of Information

We may disclose aggregated and/or de-identified information about our users without restriction. We may share or disclose your personally identifiable information in the following instances:

To fulfill a service to you. Forexample, we may hire companies to help provide products or services, like a shipping company that may deliver packages or any other third party that is needed to assist in the completion of transactions requested by you. In addition, if you email us a question, we may use your email address to process your request and respond to your question. Also, if you are entering a sweepstakes or contest, we may use your personally identifiable information in order to fulfill the terms of that promotion. This means that we may share the information for prize fulfillment purposes or mail carriers. We also may share your information with the co-sponsor of that promotion.To affiliates, strategic partners, agents, third party marketers or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your personally identifiable information for research, administrative and/or internal business purposes. These parties may use your personally identifiable information to contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes. If you do not want us to share your personally identifiable information in this manner, please do not provide us with this information.To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Sitesand provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions). We seek to ensure that these unaffiliated third parties will not use the personally identifiable information for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Siteswill have access to users’personal information, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit anypersonalinformation to us.To complete your purchases. If you choose to make a purchase onour Sites, we may collect from you your credit card number, billing address and other information related to such purchase, and we may use such collected information in order to fulfill your purchase. We may also provide such information, or other personally identifiable information provided by you, to unaffiliated third parties as necessary to complete your purchase (for example, to process your credit card).To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of our company and or to act in urgent circumstances to protect the personal safety of our end users.To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.To track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.To protect against potential fraud, we may verify with third parties the information collected fromour Sites. In the course of such verification, we may receivepersonalinformation about you from such services. In particular, if you use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us, and that the card has not been reported as lost or stolen. Except as described in this Privacy Policy or at the time we request the information, we do not otherwise use, share or otherwise disclose your personally identifiable information to any third parties.

D. Collection And Use Of Information From Children Under The Age Of 13

To ensure compliance with federal law, our Sites do not maintain information provided by children under the age of 13. If we learn we have collected or received personal information from a child under the age of 13, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us as set forth below.

E. TransferOf Personal Information

If you are visiting our Sites from a location outside of the U.S., your connection will be through and to servers located in the U.S. Your orders placed through our Sites will be accepted and fully processed in and shipped from the U.S. and all information you provide will be securely maintained in our Web server and internal systems located within the U.S. By using the Sites, you consent to the transfer to and processing and storage of your information in countries outside of your country of residence, which may have different data protection laws than those in the country where you reside.

F. Opt-OutOf Communications

We communicate with users who subscribe to our services on a regular basis via email. For example, we may use your email address to confirm your request, to send you notice of payments, to send you information about changes to our products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature rather than promotional. However, we provide you with an opt-out choice if you do not want to receive other types of communications from us, such as emails or updates from us regarding new services and products offered on our Sites or if you do not want us to share your personally identifiable information with third parties. On your registration form you may select whether or not you want to receive emails from us. You can unsubscribe at any time you wish by ticking or un-ticking the appropriate box on your registration form or by contacting us. We will process your request as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed. You also may opt-out of receiving such emails by clicking on the “unsubscribe” link within the text of the email.

G.Posting Your Information

Please note that any information you include in a message you post to any comment section or other public posting area is available to anyone with Internet access. If you don’t want people to know your email address, for example, don’t include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN ANY PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN THOSE AREAS.

H. Third Party Websites And Links

For your convenience, our Sites may contain links to other sites. Ours Sites are not responsible for the privacy practices or the content of such websites, and we encourage you to review the terms and privacy policies for any third-party websites that you visit.

I. 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

J. Changes To Our Privacy Policy

Jerome Alexander reserves the right to update or change this Privacy Policy at any time. If we make a material change to our Privacy Policy, we will provide prominent notice (by email and/or posting on our website) that our privacy practices have changed and will provide a link to the new policy. The date this Privacy Policy was last revised is at the top of this page. We encourage you to review this Privacy Policy periodically to check for any updates or changes.

K. Your California Privacy Rights

California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please contact us at the customer service number provided.

L. Do Not Track Signals

Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services. At this time, the Sites do not respond to the preferences you may have set in your web browser regarding such collection of your information, and the Sites may continue to collect information in the manner described in this Privacy Policy.

M. Contacting Us

IIf you have any questions about this Privacy Policy or our privacy practices, please contact us at the customer service number noted on our Sites or email customer services at: support@jeromealexander.com.