Privacy Policy

What is covered by this Policy? Invoca (“Invoca” “we” or “us”) provides pay-per-call services, using unique phone numbers and other forms of call tracking used in both
online and offline advertising. Using unique phone numbers with personalization components, database management, and our proprietary and confidential
systems we provide networks, advertisers, agencies, publishers (directly and indirectly, our “clients”), and consumers with pay-per-call features and
services that are unmatched in our industry.

We recognize that privacy is important, and our collection and use of information is limited to what is necessary to create innovative and reliable
services for our clients, without compromising the individual privacy of consumers. This policy covers data collected through our website, www.invoca.com and data collected through our services.

CONSUMER PRIVACY

What information does Invoca collect about consumers?

General When a consumer uses our services, for example, by calling a unique phone number associated with one of our advertiser clients, we will collect their
personal information if it is made available to us by the consumer or by a third party. This information includes limited personal data such as the
caller’s name, address, phone number and email address. We will not knowingly collect personal information from children under the age of thirteen.

User-supplied Information We and our clients, for example, an advertiser, may set up order forms, questionnaires, or other mechanisms through which a consumer may be asked to
provide certain information either online or via telephone or other communications medium. Participation is purely voluntary, and any consumer not
wanting to participate may decline or terminate contact (e.g., navigate away from the web page or hang up the phone).

If such mechanisms are initiated by one of our clients outside of our services and our clients collect the information themselves, we cannot be
responsible for that information, although we will endeavor to ensure that such clients maintain reasonable and appropriate privacy policies.

In addition, we may receive from clients email addresses and telephone numbers of consumers for various purposes, for example, facilitating an outbound
marketing campaign. Prior to obtaining any such information, we will require assurances from our clients that such information was obtained rightfully,
and we must rely on those assurances in delivering our services.

Usage Information

Web services When a consumer responds to or views an internet advertisement served by a Invoca client (such as through third-party web sites or email
solicitation) or visits a Invoca site, we may send one or more cookies (an anonymous, unique identifier) to the consumer’s computer to uniquely
identify that consumer’s browser. Like most companies doing business on the internet, we use cookies to improve the quality of our services by storing
user preferences, tracking user trends, determining how our services are used and navigated. Most cookies are automatically deleted at the end of a
session at the Web Site. While we may use what are commonly described as “persistent” cookies that remain on a specific browser after termination of a
session, any consumer may set their browser to refuse cookies or automatically clear cookies after termination of a session. Cookies we service on
third party web sites only collect data in the aggregate.

Phone services We provide our clients unique telephone numbers to utilize on a web site, email, mobile or offline promotion. This enables us to both determine what
the consumer was looking at when making a telephone call and personalize the experience for that consumer. Our phone servers automatically collect the
caller ID results when a consumer calls the number, and we may also occasionally collect other usage information from third-party databases, including
the name and/or the address of the caller when available.

In addition, our phone servers use software that may be employed on behalf of an advertiser to record calls. This recorded information may be evaluated
in order to determine the quality of that call from the advertiser’s perspective and for training or other purposes. This enables us to identify high-quality
calls and collect additional usage data we can use to provide our clients with improved services and sales. We may also use third-party
services or technology for the transcription or analysis of such information. In the event we record a call on behalf of an advertiser, we will ensure
that call participants are advised of the existence and intent of the recording in a manner consistent with applicable state and federal laws. We are
not responsible in any way for the accuracy or validity of the content of any such recordings, and we take no steps to evaluate such accuracy or
validity.

While we strongly encourage clients to adopt responsible approaches to marketing, we are not responsible for the information practices of clients or
their partners. The collection, use, and disclosure of information by clients and partners are subject to their respective privacy policies, which may
differ from Invoca’s policy.

Reasons for collecting usage information We may collect usage information when an internet user clicks on a link, creates a lead, initiates a phone call, receives a phone call, makes a
purchase on an advertiser’s web site, sends us a text message, receives a text message from us, or makes an inquiry or a purchase during a phone call
to an advertiser. We collect this information primarily for the purpose of paying third-parties commissions and also to optimize and personalize the
internet and phone user’s experience. If the internet user re-visits the advertiser’s site directly, or if the phone user calls the advertiser using
the unique phone number again, Invoca is able to continue to track the user’s activities on the advertiser’s site and compensate the third party
that referred the user. We reserve the right to retain all data as long as may be reasonably necessary for accounting and audit purposes.

Like most standard Web site servers, we use log files to collect Internet protocol (IP) addresses, browser type, Internet service provider (ISP),
referring/exit pages, platform type, and date/time stamp. We may use the information to analyze site usage, administer the site, understand usage and
navigation trends in aggregate, and determine the relevance of content.

We also may develop predictive statistical user profiles of consumers’ needs and interests by collecting both internet browsing and online purchase
data and phone user data. For improved audience targeting, some Invoca services may use marketing technology to allow advertisers to supplement
non-personally-identifying demographic information, such as age, gender, area code, or ZIP code, to the non-identifiable profile data.

Invoca may collect personal information, such as consumers’ names, physical addresses, email addresses, phone numbers and other information in
order to better target campaigns to meet user’s interests and to provide customized experiences. We will share this information only as described
herein.

Does Invoca share consumers’ personal information with others? We do not share consumers’ personal information we have gathered except as described below. Our clients, however, may gather personal information by
other means, especially if a consumer completes a transaction with them.

We only share consumers’ personal information with companies or individuals outside of Invoca in the following limited circumstances:

  • We have the consumer’s consent. We require opt-in consent for the sharing of any sensitive personal information.
  • We provide such information to our subsidiaries, affiliated companies, or other trusted businesses or persons for the purpose of processing
    personal information on our behalf. We will require these parties to agree to process such information based on our instructions and in compliance
    with this privacy policy and other appropriate confidentiality and security measures.
  • We provide such information to our clients to enable them to better provide consumers with information about products or services about which the
    consumer may be inquiring.
  • We may share personal information with our affiliates and other third parties to provide consumers with goods or services requested by them.

Invoca may also share personal information in connection with the sale, merger, consolidation, change in control, transfer of substantial asset,
reorganization or liquidation of Invoca.

Finally, Invoca may release personal information when we believe release is appropriate to respond to a subpoena or otherwise comply with the
law; enforce or apply our Terms and Conditions and other agreements; or protect the rights, property, or safety of Invoca or others. This
includes exchanging information with other companies and organizations for fraud protection.

Can a consumer “opt-out” of providing information? For consumers accessing our services through the internet, some of our cookies may have an “opt-out” option. This process does not remove the Invoca cookie from a consumer’s system; it simply replaces it with an opt-out cookie that does not contain any unique identifiers.

Some of our cookies do not have an “opt-out” option, but consumers always have the option of blocking the use of cookies by changing a setting in their
Internet browser.

Invoca does not maintain a process for an individual consumer to opt-out of a Invoca ad serving cookie. However, any consumer may set their
browser to refuse cookies or automatically clear cookies after termination of a session.

With regard to phone services, consumers are able to submit their phone numbers to “do-not-call” registries. We will use our best efforts to observe
do-not-call registries in any outbound calling campaign we perform or facilitate, provided that consumers who have opted-in to receive such messages,
either with a client or with us, shall not be subject to any do-not-call restriction.

We may partner with third-party ad networks to either display advertising on our Web site or to manage our advertising on other sites. Our ad network
partner(s) may use cookies and Web beacons to collect non-personal information about your activities on this and other Web sites to provide you
targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may
opt-out by clicking here http://preferences.truste.com/truste/. Please note this does not opt you
out of being served advertising. You will continue to receive generic ads.

Can a consumer access the personal information acquired by Invoca? Invoca’s services are not directed towards individual consumers, and we are collecting personal information on behalf of our clients to provide
them a service. Therefore, we do not maintain a process for an individual consumer to review and/or request changes to any personal information
collected.

Except as provided below, we do not maintain a process for an individual consumer to access his or her personal information.

CLIENT PRIVACY

What information does Invoca collect from its clients (e.g., networks, agencies, advertisers and publishers)? We may collect personal information from all of our clients (e.g., networks, agencies, advertisers, and publishers. The collection of this information
is a part of our normal business practices. Advertisers or their representatives will be asked to provide personal information through the sign up and
registration process either directly or through a network or agency partner. This information may include name, address, phone number, hours of
operation, coverage areas and email address. Additionally, we may collect sensitive personal information such as social security number and tax ID
number.

In addition, we will use cookies, third party tracking technologies such as scripts, log files and unique phone numbers to optimize and personalize the
clients’ experience and allow us to monitor those services and usage patterns. Both our cookies and third party tracking technologies are not linked
to personal information.

When using our service, clients may enter third party personal information such as other user’s email on the platform. This information is only used to
provide the client access to the system and for no other purpose.

How does Invoca use its clients’ information? Much of the information collected from clients is principally intended for administrative needs (e.g. accounting and performance reporting), for which
purpose such data are required.

While we strongly encourage clients to adopt responsible approaches to online marketing, we are not responsible for the information practices of
clients or their partners. The collection, use, and disclosure of information by clients and partners are subject to their respective privacy policies,
which may differ from Invoca’s policy.

Periodically we may use clients’ information to communicate via email newsletters or other avenues to offer strategic marketing information and other
communications to assist in business related activities. Our clients can elect to opt-out from future communications by clicking on the unsubscribe
link in the email.

Except as otherwise agreed, we will keep all personal data provided by individual clients in strict confidence and will treat such data with the same
level of respect and care that we treat our own proprietary information and trade secrets. We do not sell, rent, exchange or barter any personal client
information to or with any third party for financial gain or marketing purposes. We may, from time to time, provide personal information to certain
third-party administrative vendors for efficiency purposes in providing administrative or program management services. Examples include an email
service provider, marketing solutions provider, and a blog provider. Any third-party vendor so used has agreed to protect the confidentiality of
information provided by Invoca.

Invoca may also share information in connection with the sale, merger, consolidation, change in control, transfer of substantial asset,
reorganization or liquidation of Invoca.

Invoca may release information when we believe release is appropriate to respond to a subpoena or otherwise comply with the law; enforce or apply
our Terms and Conditions and other agreements; or protect the rights, property, or safety of Invoca or others. This includes exchanging
information with other companies and organizations for fraud protection.

Can a client “opt-out” of providing information? Collecting information from our clients is required as a part of doing business. Invoca’s primary intent in collecting information is for
administrative purposes including accounting and reporting. However, we may periodically use information for marketing and communication purposes
targeted to our clients. Clients wishing not to receive such communications may do so by informing their designated Invoca representative in
writing at any time or by clicking on the unsubscribe link in the promotional communication.

When a client logs on to any browser-based Invoca reporting system, a cookie is placed within their computer. The cookie allows us to validate
the client’s identity and maintain the security and privacy of the client’s account data. This cookie does not contain any personal information. It is
required to log into Invoca’s reporting systems and there is no method to opt-out of this cookie.

If you are a client, and would like the personal information we hold about you deleted, please contact legal@invoca.com or contact their designated Invoca representative. We will respond to your request to access within 30 days.

Data Retention:

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or
request that we no longer use your information to provide you services contact us at legal@invoca.com.
We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

GENERAL

Public Forums:

Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read,
collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at legal@invoca.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to
do so and why. With your consent we may post client testimonials along with their name.

Links to Other Web Sites

Our Site includes links to other Web sites whose privacy practices may differ from those of ours. If you submit personal information to any of those
sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

How does Invoca protect the security of personal information? Invoca takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of
data. Any data stored on our servers is treated as proprietary and confidential and is not available to the public. We restrict access to personal
information to those employees or third parties who have a need to know such information for the purpose of effectively delivering Invoca
products and services by means of user login and password requirements. We routinely evaluate our data security practices to identify security threats
or opportunities for improvement.

No transmission of data over the Internet or even the phones is guaranteed to be completely secure. It may be possible for third parties not under the
control of Invoca to intercept or access transmissions or private communications unlawfully. While we strive to protect your personal
information, we cannot ensure or warrant the security of any information you transmit to us.

How are changes made to the Privacy Policy? We may find it necessary or be legally obligated to update this Privacy Policy from time to time. When we do, we will post those changes on this page
and update the effective date so that everyone is aware of the information we collect, how we use it, and under what circumstances we disclose it.
Except as otherwise required by law, modifications to this Privacy Policy will not affect the privacy of data collected by Invoca prior to the
effective date of the policy change.

What are Invoca’s policies regarding children and SPAM? Our services are not developed for or directed at children. Children (persons under the age of 18) are not eligible to do business with us, and we do
not collect personal information from any person we actually know is under the age of 13. If you believe your child has provided Invoca with any
personally identifiable data, please contact us at legal@invoca.com to have them removed.

Invoca is committed to proper Internet practices and full compliance with the CAN-SPAM Act of 2003 (15 U.S.C. § 7701). It is our policy to
prohibit the sending of unsolicited or “Spam” e-mail by Invoca or any of its marketing partners.

Please note that under the CAN-SPAM Act, an advertiser is required to provide an opt-out mechanism for consumers to unsubscribe from future emails
about the advertiser.

Safe Harbor Compliance The European Union (“EU”) maintains strict privacy laws. These rules differ significantly from U.S. laws. To reconcile these differences,
the United States and the EU have created a Safe Harbor that defines mutually acceptable privacy operations for personal data transferred from the EU to the United States.
The U.S. and Switzerland have created a similar, but separate Safe Harbor that defines mutually acceptable privacy operations for personal data transferred from Switzerland to the United States.
Invoca, Inc. complies with the U.S. – E.U. Safe Harbor Framework and U.S – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal
data from the European Union and Switzerland. Information regarding both the Safe Harbor Frameworks can be found at: http://export.gov/safeharbor.

Contact Us For more information or if you have questions or concerns regarding the Invoca Privacy Policy, please contact us at legal@invoca.com or you
can send correspondence to the following address: Privacy, 1025 Chapala Street , Santa Barbara, CA 93101.

Policy Updated: November 7, 2011