Red Lantern Strategy, Inc., a New York corporation (“Red Lantern Strategy”), respects your individual privacy. This Privacy Policy documents our adherence to industry standards for the protection of your Personal Information.

Scope of the Privacy Policy

This Privacy Policy covers Red Lantern Strategy’s treatment of Personal Information that is collected while you are on the Red Lantern Strategy site or when you participate in a study conducted on behalf of a Red Lantern Strategy client (“Client“). Within this Policy, the term “Personal Information,” refers to any information that (a) can be used to identify the personal data principal to whom such information related or, (b) is or might be directly or indirectly linked to a personal data principal. This Policy does not apply to the practices of companies not owned or controlled by Red Lantern Strategy or to people whom Red Lantern Strategy does not employ or manage, nor does it address non-Personal Information. This Policy specifically addresses the following areas:

• What Personal Information is collected by Red Lantern Strategy or by any third party through our site;

• How Red Lantern Strategy uses your Personal Information;

• With whom Red Lantern Strategy may share your Personal Information;

• What choices are available to you as a user of the site with respect to collection, use and distribution of your Personal Information;

• What types of security procedures are in place to protect the loss, misuse, or alteration of Personal Information under our control; and

• How you can correct any inaccuracies in the Personal Information

Information Collection and Use

Red Lantern Strategy collects Personal Information from you on behalf of the Client and whose study you have participated in. Online account creation through one of Red Lantern Strategy’s clients may require you to submit the following Personal Information: name, address, company information, email address, and phone number. Red Lantern Strategy and/or our Clients may also collect characteristics of protected classifications under federal law, such as race or ethnicity, audio, electronic, visual, or similar information, professional or employment-related information, or educational information. Clients may have their own privacy policies which apply to studies that they have created using our services and that detail how they handle your Personal Information. We encourage you to read any such policy. Your submission of Personal Information is voluntary and you may opt out of responding at any time. If you do respond, you consent to its provision to us for the purpose of delivering our services to the Client and or their end-client.

We collect this information in the following ways:

• You may voluntarily provide us certain information, for example your real name or email address, when you interact with the site or use our services.

• Our service providers that administer services for us, for example our hosting provider(s) and newsletter vendors, may provide us access to certain information we request from time to time.

Personal Information of Children Under 13

Red Lantern Strategy complies with the requirements of the Children’s Online Privacy Protection Act (COPPA) and the FTC’s Rule interpreting COPPA (16 CFR § 512). This site is not directed to children and does not knowingly collect any Personal Information from children under 13 years of age. If we learn that Personal Information from users less than 13 years of age has been collected, we will deactivate the account or cancel the order and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under 13 years of age, please contact us at info@redlanternstrategy.com.

How We Use the Information We Collect

We use your Personal Information primarily for the purpose of delivering our services to the Client and/or their end-client, and as otherwise described in this Privacy Policy or at the time of collection. We may also use your Personal Information in the following ways:

• Delivery of Services. We may use your Personal Information in order to achieve our legitimate business interest of delivering services you request or to fulfill contractual obligations to you.

• To comply with laws and regulations. We may use your Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

• For compliance, fraud prevention and safety. We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) audit our internal processes for compliance with legal and contractual requirements; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyber-attacks and identity theft.

• For any other purpose you consent to at the time of collection. Provided that if we intend to subsequently use your Personal Information for a different purpose, we will obtain your consent for such different purpose.

How And When We Share Information

Red Lantern Strategy will never give or sell your Personal Information to, or share your Personal Information with, any third parties other than our service providers and the Client, except as permitted by law. The following categories of recipients may have access to your Personal Information:

• Service providers. We share your Personal Information with service providers to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above (e.g., information technology services, information storage and security, payment processing, fraud detection, marketing management and communications, customer service functions, statistical analysis).

• Affiliated Companies. We may also share your Personal Information with our subsidiaries, affiliates and other related companies for purposes consistent with this Privacy Policy and providing you with our Sites and services.

• Business reorganization. We may share your Personal Information with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Information would be transferred as an asset of Red Lantern Strategy.

• Mandatory Disclosures and Legal Rights. We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other legal or governmental request for information. We also share Personal Information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.

Data Retention

We retain Personal Information for as long as necessary for the relevant purpose for which that Personal Information was provided or collected, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). This will be for as long as we provide access to the site to you. However, we may keep some data after your account is closed or you cease using our site for the following purposes: After you have closed your account or ceased using our site we usually delete Personal Information, however we may retain Personal Information where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our contracts, or fulfill your request to “unsubscribe” from further messages from us.

Security

Wherever your Personal Information may be held within Red Lantern Strategy or on its behalf, we intend to take commercially reasonable and appropriate steps to protect the Personal Information that you share with us from unauthorized access or disclosure. However, given the nature of the Internet and the fact that network security measures are not infallible, we cannot guarantee the security of your Personal Information. We use encryption to protect sensitive Personal Information online. The servers that store your Personal Information are housed in a secure environment. Finally, we also make an effort to protect your Personal Information off-line.

Our computer systems are currently based in the United States, so your data will be processed in the United States. As a visitor from outside the United States, by using the site you agree to this Privacy Policy and you consent to the transfer of all such Personal Information to the United States and to the processing of that Personal Information as described in this Privacy Policy.

Correcting, Updating, Deleting and Deactivating Personal Information

If your Personal Information changes, you may contact us to correct, update, or delete and deactivate our record of your Personal Information. Where we have collected your Personal Information on behalf of a study moderator, contact the study moderator if you want to access, update, or delete that information. If the study moderator has their own privacy policy, please refer to it.

Notification of Changes

Red Lantern Strategy may edit this Policy from time to time. If we make any substantial changes, we will prominently post a notice on the main page and update the “Last Updated” date to alert you of the change.

Other Sites, Mobile Applications, and Services

The site may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your Personal Information. We encourage you to read the privacy policies of the other websites and online services you use.

Contact Information

If you have any questions about our Privacy Policy, please email us at info@redlanternstrategy.com.