Privacy Policy

This Privacy Policy (this "Policy") applies to our use of your Personal Information in performing the class action settlement administration services we provide, including the websites where this Policy is posted (each, a "Site"), as well as to other services we may provide on our own behalf to customers (collectively, the "Services"). In this Policy, "we," "us," or "our" are references to Fidexis.

Please read this Policy carefully to learn how we collect, use, share, and otherwise process your Personal Information, and to learn about your rights and choices regarding such Personal Information. By visiting or using the Services, and by providing Personal Information to us by any means, whether on a Site or in any type of correspondence, you consent to our use of such information in accordance with this Policy. If you do not agree with this Policy or our practices, please do not use the Services.

Notice at Collection for California Residents

We collect your Personal Information as detailed here and in our Privacy Policy. In accordance with applicable California law, this serves as our Notice at Collection of such Personal Information. We do not "sell" or "share" Personal Information, as defined by applicable law. We will only retain Personal Information for as long as reasonably necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements to which we are subject, as well as to resolve disputes and enforce our agreements. We also keep Personal Information as otherwise required by law.

What categories of Personal Information do we collect?

• Identifiers. Your name, postal address, email address, mobile or other telephone number.
• Any Personal Information described in subdivision (e) of Cal. Civil Code section 1798.80. Bank account and routing numbers.
• Commercial information. Transaction information such as receipts and proofs of purchase.
• Internet or other electronic network activity information. Information about your use of the Services, including your IP address, referring URLs, and the time and date of your usage.
• Geolocation data. Information about the location of the devices used to access a Site.
• Sensitive Personal Information. Information required by law to process certain claims, such as your social security number.

What are the purposes for which we collect and use Personal Information?

• To fulfill our legal obligation to provide class action settlement administration services to you and to the settlement administrator, class counsel, defendant's counsel, and the court;
• To assess your eligibility to participate in a class action settlement, including to verify your identity based on Personal Information provided by the parties to the action;
• To detect and prevent claims-related fraud and other unlawful activity;
• To apply software processing, including algorithms, to generate a "score" describing your eligibility to participate in a settlement based on the absence of indicators of fraud and the presence of indicators of eligibility, e.g., proof of purchase;
• To facilitate payments to you pursuant to the settlement;
• To respond to your questions related to the claims administration process;
• To use third-party analytics and tracking tools to better understand who is using the Services and how they are using them, as well as how to improve the effectiveness of the Services;
• To develop, maintain, and offer Services on our own behalf to customers, including the ability to predict the characteristics of future class action settlements, e.g., claimant composition and financial outcomes;
• To develop new services and product offerings;
• To perform our legal, regulatory, and contractual obligations, and enforce our rights;
• To notify you of changes to a Site, its policies, or the Services.

1 Types of Personal Information we collect

When information identifies or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, we refer to it as "Personal Information," which we collect from you and about you. This may include:

Identifiers

This includes your name, postal address, email address, mobile or other telephone number.

Any Personal Information described in subdivision (e) of Cal. Civil Code section 1798.80

If you seek payment under settlement of a class action claim, we may collect payment-related information such as bank account and routing numbers, depending on the form of payment you choose.

Commercial information

This includes transaction information such as receipts and proofs of purchase.

Internet or other electronic network activity information

This includes information about your use of the Services, including your Internet Protocol ("IP") address, referring URLs, and the time and date of your usage. We also collect and store information about how you interact with a Site. We may link certain data elements we have collected, such as IP address, with other information we have obtained about you.

Geolocation data

This includes information about the location of the devices used to access a Site, including the IP address of the device or internet service used to access a Site.

Sensitive Personal Information

This includes information required by law to process certain claims, such as your social security number.

2 How we collect your Personal Information

There are several ways we may obtain Personal Information, including through information you provide to us directly through both online and offline interactions, information we receive from third parties, and information that we automatically collect when you use the Services.

We collect information from you when you or someone acting on your behalf chooses to disclose it to us in order to make a claim under a settlement, whether on a Site, by telephone, or by mail.

We collect Personal Information from the settlement administrator, and class counsel and defendant's counsel (on behalf of each of their clients), to fulfill our legal obligation to provide the Services, namely class action settlement administration services, from which you may benefit. For example, if you are known to the defendant due to a purchase you made in the past, and therefore may be eligible for a claim, the defendant may provide elements of your Personal Information to us, which we will then validate if you visit a Site.

When you visit or interact with the Services, we and our service providers may use cookies, web beacons, pixel tags, or other technologies to automatically or passively collect information about your online activity. As you interact with the Services, we may automatically collect technical information about your device as well as usage information through these and other similar technologies.

3 How we use the Personal Information we collect

We may use the Personal Information that we collect for the following purposes:

• To fulfill our legal obligation to provide class action settlement administration services to you and to the settlement administrator, class counsel, defendant's counsel, and the court;
• To assess your eligibility to participate in a class action settlement, including to verify your identity based on Personal Information provided by the parties to the action;
• To detect and prevent claims-related fraud and other unlawful activity;
• To apply software processing, including algorithms, to generate a "score" describing your eligibility to participate in a settlement based on the absence of indicators of fraud and the presence of indicators of eligibility, e.g., proof of purchase;
• To facilitate payments to you pursuant to the settlement;
• To respond to your questions related to the claims administration process;
• To use third-party analytics and tracking tools to better understand who is using the Services and how they are using them, as well as how to improve the effectiveness of the Services;
• To develop, maintain, and offer Services on our own behalf to customers, including the ability to predict the characteristics of future class action settlements, e.g., claimant composition and financial outcomes;
• To develop new services and product offerings;
• To perform our legal, regulatory, and contractual obligations, and enforce our rights;
• To notify you of changes to a Site, its policies, or the Services.

4 How we disclose the Personal Information we collect

The parties. We will disclose Personal Information and Scores to the settlement administrator, class counsel, defendant's counsel, and the court to fulfill our contractual obligation to provide class action settlement administration services, including to determine the eligibility of your claim.

Our service providers. We may disclose Personal Information to our service providers (such as vendors and consultants) that perform certain functions or services on our behalf to perform the Services. These include companies that host our Services, manage databases, perform analyses, send communications for us, process payments to you, or provide certain other components of the Services. Our service providers are prohibited from using or disclosing Personal Information we share with them for any purpose other than performing the Services on our behalf.

Third parties pursuant to legal process. We may share Personal Information to the extent necessary to respond to subpoenas, court orders, or other legal process; in response to a request for cooperation from law enforcement or a government agency; or to otherwise comply with our other legal and regulatory obligations.

Relevant third parties as part of a transaction. To advance our lawful commercial interests, we may share Personal Information with certain third parties (including our professional advisers) in connection with a corporate transaction, such as a sale, assignment, divestiture, merger, bankruptcy, consolidation, reorganization, liquidation, or other transfer of the business or its assets. When we do this, we will incorporate reasonable security and other measures to protect Personal Information.

Aggregated or de-identified information. We may use and disclose your Personal Information to third parties in anonymous, de-identified, or aggregate form, e.g., to provide industry metrics.

5 Security of Personal Information

We maintain reasonable security procedures to help protect against loss, misuse, or unauthorized access, disclosure, alteration, or destruction of Personal Information and Scores. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. As a result, while we strive to protect Personal Information, we cannot guarantee or warrant the security of any information you disclose to us. If you prefer not to transmit Personal Information over the Internet, we make other methods (e.g., telephone and postal mail) available in the claims process. If you have any questions regarding security, you can contact us through the means set forth in the "How to contact us" section.

6 Children's privacy

We are committed to protecting the privacy of children. The Services are not directed to children and we do not knowingly collect any Personal Information from children. If a child under the age of 16 has provided us with Personal Information online, we ask that a parent or guardian please contact us, and we will take reasonable steps to delete Personal Information provided by the child. We do not knowingly collect, sell, or share the information of anyone under 16 years of age.

7 Retention of Personal Information

We will only retain Personal Information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements to which we are subject, as well as to resolve disputes and enforce our agreements. We also keep Personal Information as otherwise required by law.

8 Your privacy rights

If you are a California or Virginia resident, you may take advantage of the following privacy rights:

• Right to know. You have the right to know and access what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you.
• Right to portability. You have the right to obtain a portable copy of the Personal Information that you provided to us.
• Right to delete. You have the right to delete Personal Information that we have collected from you. Note that there are some reasons we will not be able to fully address your request, such as to detect and protect against fraudulent and illegal activity, to exercise our rights, for our legitimate internal purposes, or to comply with a legal obligation.
• Right to correct. You have the right to correct inaccurate Personal Information that we may maintain about you, subject to appropriate verification.
• Right to appeal. If we deny your request, and you wish to appeal, you may appeal our decision.

To take advantage of your rights, please contact us by email at [email protected]. We may request certain information about your interactions with us to verify your identity before we can respond to your requests. Where applicable, we will confirm receipt of your request within 10 business days, and we will respond to your request within 45 calendar days, after proper verification, unless we need additional time, in which case we will let you know.

We value your privacy and will not discriminate in response to your exercise of your privacy rights.

Subject to applicable law, you may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you have authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent's identity. An authorized agent is prohibited from using Personal Information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer's requests, for verification, or for fraud prevention.

9 Locations

Fidexis is based in the United States. The Sites are intended for use only by persons located in the United States. We make no claims that the Sites or any of their content is accessible or appropriate outside of the United States. Access to the Sites may not be legal by certain persons or in certain countries. If you access a Site from outside the United States, you do so on your own initiative, at your sole risk, and you are responsible for compliance with all applicable laws.

10 Modifications to this Policy

Any changes we may make to this Policy will be posted on this page. Please check back frequently to see any updates or changes to the Policy. If you do not agree or consent to these updates or changes, do not continue to use the Site. If we make a material change to this Policy, we will provide notice to you as required by law.

11 How to contact us