ffective 10/01/2023

Last Updated 09/21/2023

This Privacy Policy is provided by LeaseAccelerator, Inc. and its affiliates, which include LeaseAccelerator Services, LLC (“LAS”) and EZLease, LLC (“EZLease”), (which are collectively referred to below as “we” or “us” and in the possessive “our”) to address our processing of personal information. “You” or “your” refers to an individual whose personal information we process. “Personal Information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable natural person or household. “Process” means any set of operations performed on personal information, such as collection, storage, use, disclosure by transmission or sharing.

We market and provide on-premises software or access to cloud-based “software-as-a-service” applications to that assist businesses in commercial lease management, sourcing, and accounting (our “Applications”). We also provide our customer support for our Applications and educational and training services (“Support Services”, and collectively without our Applications, our “Services”). Our provision of Services to each customer is governed by one or more agreements, including incorporated policies and addenda and our Terms of Use (the “Customer Agreements”).

What Personal information do we process?

The Personal Information we process and how we process it falls within four activities we conduct in connection with our Services.

Our Public Websites: We obtain Personal Information directly from visitors (“Visitors”) to our public websites under the following domain names (the “Public Websites ”):

www.leaseaccelerator.com

www.ezlease.com

www.purelease.net

www.lessornetwork.com

A Visitor may choose to provide us with the Visitor’s contact information, including first and last name, work email, work phone, company name and country in order to for us to answer questions or inquiries about our Services or to download resources that we provide, such as newsletters, case studies, and white papers.

Additionally, like most web-based services, we (or our service providers) may automatically collect information when a Visitor accesses the Public Websites, such as source IP addresses and information that may be derived from IP address, such as general geographic location, time and duration of each visit, the device type, operating system and the networks, and information about a device a User uses, such as browser type. See “How do we use cookies and similar technologies?” below. If we combine any automatically collected information with Personal Information the Visitor provides, we will treat the combined information as Personal Information, and it will be treated in accordance with this Privacy Policy.

Offering Registrations: We obtain Personal information from registrations of individuals to our training and other educational offerings (“Registrants”). For a Registrant or a third party who uses one of our Public Websites to complete a registration, Visitor Personal Information may also be collected. (See “Our Public Websites”).

A Registrant (or other person completing the registration on the Registrant’s behalf) may choose to provide us with contact information, including first and last name, work email, work phone, company name and country in order for us to complete the registration and to provide access to materials.

We may also collect information regarding participation of a Registrant at a training or other educational offering. This Personal Information may include the time and duration of participation, the IP address from which any online program is accessed and, if professional credits are offered, the Registrant’s accrediting body and member id. If a program includes self-assessments or certifications, we will collect information regarding the Registrant’s performance on evaluations.

Services: The Customer Agreements permit the customer access to and use of Services through one or more individuals that the customer authorizes (each a “User”). The customer controls what information to provide in our Applications to identify each User. Additionally, when requesting support, a User may provide identifying information in order for us to contact that User.

We provide fields that are required for the customer to input into the Applications that include User Name, Password (not shown), Name, City, and Country.  All other fields are optional. This information is automatically associated with the Customer. This Personal Information may, in turn, be used to process additional Personal Information arising from a User’s use of the Services, which includes log files, event files, and other trace and diagnostic files, as well as statistical information that relates to the User’s use of our Services and the systems and networks our Applications run on, the accessing the User’s IP address and information that may be derived from IP address, such as general geographic location, and information about a device a User uses, such as browser, device type and operating system.

Lease Transactions: Our customers and, in the case of the sourcing Application, respondents (“RFP Bidders”) to our Customers’ requests for proposal (“RFPs”), have the ability to include information in lease transactions that identifies persons involved in the lease transaction or management or administration of the lease or leased asset whether as representatives of the parties or otherwise (together with the Users involved in the transaction, the “Transaction Participants”). This Personal Information may be included in digital copies of the proposals of RFP Bidders or the Customer’s lease documentation.

Because we only provide Services with respect to lease transactions between businesses, Personal information included within a Lease transaction is generally limited to name, job title, email address, office address and phone number of individuals who are identified in the Transaction communications -- e.g. in notice or contact provisions or as signatories to the lease documentation as representatives of the lessee, lessor or other party to the Transaction.

General Correspondence: We may correspond with Visitors, Registrants, Users, Customers and RFP Bidders outside of the Applications as well as through the use of an online chat feature.  We collect only limited personally identifiable information that is voluntarily provided by visitors to the Chat, such as name, title, address, email address, and telephone numbers of Chatbot users. Chat exchanges may be recorded for quality control, service improvements, marketing purposes and future reference and by participating in the chat each Chat participant acknowledges and consents to such recording.

General correspondence may include any of the Personal Information described above and any additional Personal Information that the correspondent may choose to include.

How do we use the personal information we possess?

We may process the Personal Information of a Visitor:

• To administer our Public Websites, including to protect the security of our Public Websites;

• To respond to inquiries regarding our Services, including to engage in chats with the Visitor;

• To improve and personalize a Visitor’s experience while visiting our Public Websites;

• For statistical analysis and record keeping;

• To improve our marketing and sales activities, including by doing internal research on our Visitor’s demographics and behavior while on the Public Website; and

• Using Cookies, as described in “How do we use tracking technologies?”.

We may process Personal Information of a Registrant:

• To provide the Registrant requested offering and resources;

• To directly market our Services to the Registrant and the Registrant’s employer or sponsor;

• To notify the Registrant of offerings and materials we believe may be of interest to the Registrant;

• To obtain feedback and suggestions from Registrant;

• If professional credits are offered, to provide the certifying body information regarding the Registrant’s participation;

• To provide a Registrant’s employer or sponsor information regarding the Registrant’s participation; and

• If a program includes knowledge assessments, to provide the Registrant’s performance results to the Registrant’s employer or sponsor.

We may process Personal Information of a User:

• To provide or facilitate the provision of the Services, including to create and manage log-in accounts, administer the Customer Agreement, to provide support and respond to requests and inquiries, to improve the Services for all Users, to monitor progress of a Users’ training and instruction and to log use of the Services, including for administration and security purposes;

• To facilitate communications with stakeholders involved in the leasing process and in lease accounting;

• To verify the customer’s authorization of the Users, validate the authenticity of the User, enforce Customer and User compliance with our Customer Agreements, process User requests and Transactions, contact the User regarding its use of, changes to, or new Services available through our Applications, and for billing purposes, and do internal research on our Users’ interests in using our Services and behavior in using our Application to better understand and serve all Users;

• To respond to the User’s requests, including support issues, notify the User about changes to our Applications and policies and communicate with the User for purposes related to its use of the Applications and policies, and to solicit User feedback.

• In relation to a known or suspected violation of the Customer Agreements or Terms of Use, to prevent fraud or other unlawful use, including, as necessary in the event of a court order, regulatory inquiry, or other lawful request.  Unless legally prohibited from doing so, we will direct any such request to the Customer or notify the Customer before responding, in accordance with our contractual obligations.

• To protect our rights and the rights of others.

We may process Personal Information of Transaction Participants:

• To facilitate responses to and participating in a Customer’s RFP activities, such as to allow sourcing participants to solicit, send out, or respond to an RFP; and

• In the provision of our Services.

Who do we share personal information with?

We share your Personal Information in the course of providing our Services.  This may include sharing with LeaseAccelerator affiliates and third-party service providers providing services to us to support our provision of Services (“Sub-Processors”). For example, Sub-Processors may include providers of data hosting/storage, virtual assistance and learning, service/support management, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, marketing, security, and other similar service providers).  A list of our current Sub-Processors is here: LeaseAccelerator Trust Center. In sharing Personal Information with Sub-Processors, we take reasonable steps to assure that the Personal Information is only processed in accordance with this Privacy Policy.

Without limiting the preceding paragraph:

• We may share User Personal Information with the customer or its affiliates who authorized the User’s access;

• We may share User Personal Information as we are instructed by customer or its affiliates who authorized the User’s access;

• We may share Personal Information in the course of a Customer’s RFP activities with lease transaction participants – e.g., to allow sourcing participants to solicit, send out or respond to an RFP.

• We may share Personal Information when we believe in good faith that disclosure is necessary to protect our rights, protect a User’s safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside a User’s country of residence, for national security and/or law enforcement purposes or to comply with compulsory process.

• In the event of transfer of our business, whether by way of a reorganization, merger, sale, assignment, bankruptcy, or similar business change, we will need to transfer the User’s Personal Information to a reorganized entity or new owner for their use in accordance with this Privacy Policy.

• We may allow third parties through the use of cookies and other tracking technologies to obtain information regarding Visitors to or websites. See Third Party Cookies and Tracking below.

How long do we retain personal information?

Personal Information about our Users that we collect in performing our Services for a Customer will be retained for the duration of the Customer Agreement and thereafter for a period specified in the Customer Agreement unless deleted earlier at the Customer’s request. Personal Information about our Registrants, who are not also Users, may be retained as long as we provide and market the offerings and resources for which the Registrant expressed an interest and the Registrant has not “opted out” from receiving these email messages. Marketing and Application emails are managed separately. For a discussion of how to “opt out”, see Opting Out of Marketing Emails below. Users can manage their communication preferences for our Applications here:

• Email Communications Preferences for LeaseAccelerator can be communicated via this form: https://forms.office.com/r/xvAHkTAK8E

• Email Communications Preferences for Real Estate Manager can be communicated via this form: https://forms.office.com/r/E30DQjfb0Z

Personal Information about our Visitors may be retained for as long as is necessary for the purpose for which it was provided, including to provide you with access to, and to provide security for, our Websites or for as long as is permissible under applicable law.

Personal Information about our RFP Bidders and Transactions consummated through our Sourcing Application may remain available to multiple financing sources for bidding purposes (“RFP Bidders”) and is retained for as long as is necessary to provide Services with respect to lease transactions.

How do we use tracking technologies?

We use cookies and similar technologies. Cookies are small data files stored on your computer or device that contain a string of characters and uniquely identify a browser on a device connected to the Internet. Cookies allow us to recognize your browser when you return to our Services and Websites. To understand our use of cookies, please review our Cookie Policy.

Third Party Cookies and Tracking: We allow third party cookies for analytics and marketing purposes. A list of the cookies that we use on our Websites, and information on how you may opt out of certain cookies, is included in our Cookie Policy.  Most browsers can be set to detect browser cookies and to let a user reject them but refusing cookies may affect certain features of our Websites that are provided for your convenience.

To make choices about cookies placed by us or our third parties on our Websites, you may do so by visiting our Cookie Preferences link in the footer of our websites. If you do not want, or no longer want, to have cookies placed on your browser by third parties, many of them offer ways to opt out. To learn more about browser cookies, including how to manage or delete them, refer to the “Tools,” “Help,” or similar section of your web browser.

We do not honor “do not track” (DNT) signals transmitted by web browsers as there is no industry standard for implementing such programs. For more information about third-party advertisers and how to prevent them from using your information, visit the NAI’s consumer website at http://www.networkadvertising.org/choices, http://www.aboutads.info/choices/, or http://www.youronlinechoices.com/uk/. If you do want to opt out using these tools, you need to opt out separately for each of your devices and for each web browser (such as Chrome, Edge, Firefox, Safari or others) that you use on each device. To find out more about DNT, please visit http://allaboutdnt.com. Note that DNT is different than the Global Privacy Control (GPC), which we do respond to in certain territories, such as Europe and California. To find out more about GPC, please visit https://globalprivacycontrol.org/.

We do not serve targeted advertising on our Websites; however, when you use the Internet, we and our third parties, as well as unaffiliated third parties including ad networks, web analytics companies and social networking platforms may use tracking technologies such as those described above, to collect information about your online activities over time and across our and other websites. We and they may use this information to measure the effectiveness of our advertising and to target advertisements for products and services that may interest you.

Website Links: Our Websites may contain links to websites or services provided by third parties, including social networking websites. The fact that we provide links to a given website is not an endorsement, authorization or representation that we are affiliated with that third party, neither is it an endorsement of their privacy or information security policies or practices. These other websites may place their own cookies or other files on your computer, collect data, or solicit Personal Information from you. We are not responsible for the content or privacy and security practices and policies of third-party websites or services. We encourage you to learn about third parties’ privacy policies before providing them with Personal Information.

Security: We have implemented technical, physical and organizational measures intended to safeguard Personal Information from unauthorized or unintended access, loss, damage, alternation, disclosure or other processing.  However, the internet is not perfectly secure, and we are not responsible for security incidents not reasonably foreseeable or reasonably within our control.

Opting Out of Marketing Emails: We may send you emails with information about our Services that we believe may be of interest. You may opt out of receiving these email messages from us by clicking on the “unsubscribe” link found at the bottom of every email that we send or by contacting us at https://explore.leaseaccelerator.com/unsubscribe/, https://ezlease.com/unsubscribe, and https://purelease.net/unsubscribe.

We do not send email messages on behalf of third parties.

How do we implement changes to this Privacy Policy?

As our Websites and Services evolve and as changes occur in laws governing Personal Information, we may make changes to this Privacy Policy. We will change the “Last Updated” date at the top of this Privacy Policy when we make those changes, or otherwise alert you as required by law. Changes to the Website Privacy Policy will become effective when posted.

If we make a material change to the privacy practices impacting our Services, we will notify our Users by sending an email to the email address we have for the User and/or posting a notice on our Application.

Notice For California Residents and Other US Residents

California has adopted, and other states of the United States either have adopted, or may adopt in the future, laws granting their residents certain rights with respect to their Personal Information.

Under these laws, California residents have, and residents of other states, have the following rights:

• Right to Know and Access Information: You have the right to request access to the Personal Information we maintain about you in the ordinary course of business and to receive it in a machine-readable format so that it is available to you. This may include Personal Information we collect, use, or disclose about you.

• Right of Correction: You have the right to correct inaccuracies in the Personal Information we maintain about you.

• Deletion of Information: You have the right to request that we delete your Personal Information.

• Right to Opt Out of “Sale” or “Sharing” of Personal Information: You have the right to opt out of a “sale” or a “sharing” of Personal Information for cross-contextual behavioral advertising, which includes our sharing of your Personal Information with third parties for commercial purposes, including advertising purposes. To learn how to opt out, visit the “Do Not Sell My Personal Information” link in the footer of the Websites.

Users wishing to exercise their rights should contact the Customer, and we will work with them as needed to facilitate your request. Website visitors wishing to exercise their rights may do so on our websites using the Cookie Preferences link in the footer.

Before fulfilling your request to exercise your rights under applicable state laws, we are required by law to verify your identity. Since we will facilitate User requests through our Customers, we will rely on their verification of your identity and our existing Customer contact information in order to process requests.

Where authorized by your state law, you may be entitled to use an authorized agent on their behalf to exercise a privacy right described above.

Please note that your exercise of the above rights is subject to certain exemptions, and so these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law.

Where applicable and where required, we will provide you with reasons why we may be unable to honor your request.

We do not discriminate or otherwise penalize anyone for exercising their rights under applicable law or this Privacy Policy.

The following reflects our current practices and our practices that have been in place over the past 12 months. WEBSITE SERVICES See Visitor and Registrant information usage under “How do we Use the Personal Information we Possess?” See User and Transaction Participant information usage under “How do we Use the Personal Information we Possess?” Categories of Personal Information we collect Personal information, including first and last name, work email, work phone, company name, and country; Internet Protocol address; Internet or other electronic network activity information related to your use of our Websites; Personal Information, including first and last name, company name, business email address, job responsibility or title, telephone number, and log-in credentials that have not been reasonably de-identified. Internet Protocol address Internet or other electronic network activity information related to your use of our Services; Categories of sources from which the Personal Information is collected We collect the Personal Information directly from you or automatically through the Website as described above. We collect the Personal Information directly from you or automatically through the Website as described above. Business or commercial purpose for sharing or selling Personal Information We collect your Personal Information to operate the Websites, to respond to your requests, and for the following business purposes: Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity. Debugging to identify and repair errors that impair existing intended functionality. Marketing communications. Marketing and remarketing efforts. We collect your Personal Information to operate the Services, respond to your requests and for the following business purposes. We do not sell, rent, or receive consideration for any Personal Information in providing the Services. Providing the Services in accordance with our contract with the Customer, including maintaining or servicing accounts, providing Customer service, processing transactions, verifying Customer information, and processing payments. Detecting security incidents, and protecting against malicious, deceptive, fraudulent, or illegal activity. Debugging to identify and repair errors. Sending you information and updates about our Services. Improving the Services when permitted by the Customer. Categories of third parties with whom we share Personal Information We may share your IP address, device ID or similar online identifier, with certain third parties for analytic and marketing purposes, see Cookie Policy. We may also share your Personal Information with our affiliates, as well as with legal and security consultants as we deem necessary for their lawful business purposes. We disclose your Personal Information to service providers who support us in delivering the services as described above. We may also share your Personal Information with our affiliates, as well as with legal and security consultants as we deem necessary for their lawful business purposes. Specific Personal Information we have collected Internet Protocol address, device ID. Internet or other electronic network activity information, including, but not limited to, how you use the Services. Name, address, and email address Internet Protocol address, device ID. Internet or other electronic network activity information, including, but not limited to, how you use the Services. Name, address, and email address. User account log-in information, including a User’s or Transaction Participant’s user name and password

Additional Information for Residents from the European Union, United Kingdom, and EEA

When we provide Services to you as a Customer or a User, we function in the capacity of a “data processor.” Our processing of your Personal Information is governed by this Privacy Policy as well as the contractual agreement with the Customer.

With respect to Visitors to our Websites, we function in the capacity of a “data controller,” and our processing of your Personal Information is governed by this Privacy Policy.

For All International Visitors: If you are located outside of the United States, please be aware that your Personal information will be transferred to, processed, or stored in the United States or other countries outside of where you live for the purposes as described in this policy. These data transfers are necessary to provide our Services. By submitting your Personal Information, you acknowledge that we may transfer, process, and store your Personal Information in this way. Wherever the information is, it will be treated and protected in accordance with this Privacy Policy and applicable privacy laws, including all applicable laws relating to the cross-border transfer of your Personal Information. Where required, and as applicable, we implement Standard Contractual Clauses with our Customers and with our third parties or rely on such other transfer mechanism to ensure that the transfer of your Personal Information outside of the European Union, United Kingdom, or the EEA is lawful. You may request details of the transfer mechanisms that we rely on to transfer personal information outside of the EEA by emailing us at infosecquestions@leaseaccelerator.com.

Additional Rights

In addition to the below, the laws in your country may provide you with other rights related to our processing of your Personal Information or they may limit these rights. In all cases, our provision of rights will comply with the applicable laws.

If you are based in the European Union, United Kingdom, or EEA, for example, you may have the right to access, update, or correct your Personal Information, to request deletion of such Personal Information, and to object to certain processing, including that related to marketing, to receive a machine-readable copy of the Personal Information concerning you that you provided to us, or request us to transfer such data to an applicable third party in certain circumstances.

In addition, where you provided your consent for our processing of your Personal Information, you may withdraw your consent by contacting us using the details provided in the “Contact” section. You may also restrict how we use your Personal Information while a complaint is being investigated. You may also have the right to lodge a complaint with a supervisory authority.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege).

In addition, as necessary to operate and provide our Services, LeaseAccelerator Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. LeaseAccelerator has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. LeaseAccelerator Inc has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

Our operations primarily are located in the United States, Canada, Europe, UK, India, and Australia. EU, UK and Switzerland.  Swiss User information will be transferred out Switzerland to the United States, Canada, the UK, India and Australia. By registering as a User, under our Terms of Use, you consent to the storage and use as described in this Privacy Policy of any Personal Information provided to us.

In compliance with the EU-US Data Privacy Framework program’s Principles, LeaseAccelerator, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union individuals with DPF inquiries or complaints should first contact LeaseAccelerator Inc., privacy@leaseaccelerator.com.

LeaseAccelerator, Inc. has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint.

This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2

Our compliance with the Data Privacy Framework requirements is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).

How to contact us?

If you have any questions or concerns about this Privacy Policy, please contact us by email to DataPrivacy@leaseaccelerator.com