Section 2.01 Data You Provide to Us.

Our websites and any portal of Helm may collect information related to your identity, name, email id, phone number and location. If you submit an online inquiry for more information, we can contact you using any of the contact details you’ve supplied. The information in inquiries will be kept temporarily then destroyed if the inquiry does not lead to a contractual relationship. We also know that some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However, for all confidential matters, we’ll ensure we interact with you via a secure forum. To improve our services and products, we sometimes collect de-identified information from web users. That information could include IP addresses or geographical information to ensure your use of our website is secure

Section 2.02 Data We Receive from Other Sources.

We may receive personal data about you in connection with the Helm Services from publicly and commercially available sources, including our business partners and vendors. Such personal data may include:

Section 2.03 Data Collected Through Automated Means.

We gather by automated means (such as cookies, web beacons, web server logs and similar technologies) certain information through the Helm Services. For more information on tracking technologies, please see Section 2.04 below. Such data collected through automated means may include:

Section 2.04 Tracking Technologies.

We and may collect information about your activity, or activity on Devices associated with you, on our sites and Applications, using tracking technologies. Examples of online tracking technologies include:

Section 2.05 Web Beacons.

Web beacons are small pieces of data that are embedded in images on the pages of sites. Web beacons may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its Privacy Policy. We may use web beacons to bring together information we collect about you.

Section 3.01 To Provide and Manage the HelmServices.

This may include to:

Section 3.02 To Measure and Improve the Helm Services.

This may include to:

Section 3.03 To Protect the Rights of Helm and Others.

Helm may use your personal data as we believe necessary or appropriate to:

Section 3.04 Legal Basis for Processing Data (Where Applicable).

For users in jurisdictions where a legal basis for processing personal data is required (such as California under the CCPA/CPRA), we rely on the following bases:

Section 4.01 Our Affiliates.

We may share your personal data with our affiliated companies for the purposes described in this Privacy Notice, including for each company’s marketing purposes (with your consent if required by applicable law).

Section 4.02 Our Service Providers.

We may share some or all of your personal data identified above, as necessary for the specific services, with our service providers, who provide services to us or to you on our behalf (e.g., sending email or Text Messages on our behalf, processing payments, fulfilling orders or improving or customizing the Helm Services). These third-party service providers are not authorized to use it for any other purpose than the specific service they are providing to us or to you on our behalf.

Section 4.03 For Legal Requirements and Proceedings.

We may disclose your personal data to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other government measures, and to comply with other legal obligations. We may also disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraud or illegal activity.

Section 4.04 With Other Third Parties to Complete a Corporate Transaction.

We may disclose information we have about you in the event we sell or transfer all or part of our business or assets (including in the event of a merger, reorganization, dissolution or liquidation) to the third party or its advisors involved in such corporate transaction.

Section 4.05 With Third Parties for the Protection of the Services and Our Users.

We may disclose your personal data to protect and defend the rights, interests and safety of the Services and our users, our subsidiaries and affiliates, and our and their employees, contractors and agents; and to protect the security of our Services, including when we believe necessary or appropriate to prevent physical harm or financial loss.

Section 5.01 Your Choices.

We offer you many choices and you may have certain rights in connection with the personal data we collect about you.

(a) Email Communications. You may ask us to remove your information from our marketing mailing lists by contacting us in accordance with the “Contact Us” section below. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link at the bottom of each email. Even if you unsubscribe from our marketing communications, we may still need to send you communications related to your use of the Helm Services, such as account-related information, service announcements or personalized communications.

(b) Push Notifications and Text Messages. If you have installed a mobile application and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the application. You can opt out of text message alerts at any time by following the instructions in the text message you receive.

(c) Browser Controls. You have choices about whether cookies or similar technologies are placed on your computer or mobile device. For more information about tracking technologies, please see the “Tracking Technologies” section above. You may also choose to opt out of our use of data that we or our third party service providers collect about your activities to provide you with tailored advertising about products or services of interest to you by contacting us as specified in the “Contact Us” section below.

Section 5.02 Your Rights.

Subject to applicable law, you may have certain rights to access, review, update, correct inaccuracies in or delete your personal data in our custody and control, or opt-out of receiving certain communications, by submitting a request here, or by contacting us as specified in the “Contact Us” section below. For security purposes, we will seek to verify your identity – in part by requesting certain information from you – as part of our process. For instance, you may need to provide your name and email address. For certain types of requests, we may also need to ask you for additional information to verify your identity. Once we have verified your identity, we will respond to your request as appropriate.

(a) Right to Access and Rectification or Correction. You may have the right to access, correct or update your personal data at any time by contacting us as specified in the “Contact Us” section below. Where you have provided your consent for our use of your personal data, you have the right to withdraw your consent and we will apply your preferences going forward.

(b) Right to Deletion. Under certain circumstances, you may have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with applicable legal requirements. Certain data may be exempt from such requests under applicable law. We may also need to retain certain types of data so that we can provide the Helm Services to you. If you ask us to delete your data, you may no longer be able to access or use our Services.

Section 5.03 Privacy Rights for California Residents.

This notice to California residents is provided under California law, including the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code 1798.100, et seq. This notice supplements our Privacy Policy by explaining your privacy rights if you are a California resident, providing our “notice at collection,” and providing certain mandated disclosures about our treatment of California residents’ information, both online and offline. We collect these categories of personal information when you interact with us: identifiers/contact information, demographic information (such as gender and age), payment card information associated with you, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We collect this information so that we can best serve you, including to fulfill your requests and to share offers that we think you may be interested in. California residents also have the right to “opt out” of the “sale” of their “personal information” to “third parties” (as those terms are defined in the CCPA and described below). As a California resident, you have the following rights:

• Right to Access. If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell.

• Right to Delete. If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

• Right to Opt Out of Sale of Personal Information. If you are a California resident, you have the right to “opt out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA).

• Removal of Content. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted.

• Shine the Light Act. If you are a California resident, California Civil Code Section 1798.83 (the “Shine the Light Act”) permits you to request information regarding the disclosure of your personal information by Helm to third parties for the third parties’ direct marketing purposes.

To make a request in accordance with your California privacy rights, please contact us as specified in the “Contact Us” section below.

We also make the following disclosures for the purposes of complying with the CCPA:

• We collected the following categories of personal information in the last 12 months: identifiers/contact information, demographic information (such as gender and age), payment card information associated with you, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above.

• The sources of personal information from whom we collected are: directly from our users, third-party sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and third-party services that update or supplement information we hold about you.

• The business or commercial purposes of collecting personal information are as summarized in the “How we Use Data We Obtain” section above.

• We disclosed the following categories of personal information for a business purpose in the last 12 months: identifiers/contact information, demographic information (such as gender and age), payment card information associated with you, commercial information, Internet or other electronic network activity information, geolocation data, audio, electronic, visual or similar information, and inferences drawn from the above. We disclosed each category to third-party business partners and service providers, third-party sites or platforms such as social networking sites, and other third parties as described in the “Data Sharing” section above.

• As the term is defined in the CCPA, we have not sold any personal information during the last 12 months.

Section 5.04 Privacy Rights for Colorado, Connecticut, Utah & Virginia Residents.

The Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act and Virginia Consumer Data Protection Act each provide certain rights to residents in the states of Colorado, Connecticut, Utah and Virginia, respectively. This section of the Privacy Notice applies if you are a natural person who is resident of any of these states and use the Helm Services (each and all of whom shall be referred to collectively as “Consumer”). Certain terms below have the meanings given to them in the respective laws. In addition to your rights of access, correction, and deletion as described in above, Consumers have additional rights in connection with the personal data we collect about you, many of which are subject to exceptions under applicable law.

• Non-Discrimination. We will not deny, charge different prices for, or provide a different level of quality of goods and services if you choose to exercise your rights.

• You have, subject to certain exceptions, the right to obtain a copy of your personal data in a portable and readily usable format.

• Opt Out of Sale or Other Processing of Your Personal Data. You have the right to opt out of the sale of your data to a third party or the processing of your personal data for the following purposes: (i) targeted advertising and (ii) profiling.

To make a request in accordance with your Colorado, Connecticut, Utah, or Virginia privacy rights, you may contact us as specified in the “Contact Us” section below.

Section 5.05 Privacy Rights for Nevada Residents.

If you are a Nevada resident, Nevada Revised Statutes Section 603A gives you the right to submit a verified request to us, directing us not to make any sale of certain personal information, as defined under this law, that we have collected or may collect about you. To make a request in accordance with your Nevada privacy rights, you may contact us as specified in the “Contact Us” section below.

Section 7.01 Do Not Track Disclosure.

Some browsers or other tools include “Do Not Track” (“DNT”) features which, when turned on, send a signal to websites you visit indicating you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, Helm does not currently respond to DNT signals.

Section 7.02 Transfers of Personal Data.

Your personal data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside your country of residence, including the United States, and may have different data protection laws than in the country in which you initially provided the data. Applicable laws in the United States and/or other countries may allow the courts, law enforcement and national security authorities to access your personal data when in such country. If you are a user located outside the United States or the country to which your information may be transferred, you understand (and, as permitted under applicable law, consent to) having any personal data processed in the United States or such country. When we transfer your data, we will protect that data as described in this Privacy Notice.

Section 7.03 Collection of Personal Financial Information by a Payment Service.

In some cases, we may use an unaffiliated payment service to allow you to purchase a product or service or make payments (“Payment Service”). If you wish to purchase a product or service or make a payment, in such a case, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy notice, rather than this Privacy Notice. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.

Section 7.04 Links to Third Party Sites or Applications.

The Helm Services may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality, games or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third party Linked Services may use automated means to collect information about you and your use of these features. Some of these third party sites may be co-branded with a Helm logo, even though they are not operated or maintained by us. Helm is not responsible for the privacy practices of such third parties, and once you leave the Helm Services or click an advertisement, or sign up for a special offer, you should check the applicable third party privacy notice.

Section 7.05 Updates to Privacy Notice.

Helm may periodically update this Privacy Notice without prior notice to reflect changes in our privacy practices and the Helm Services. If we modify the Privacy Notice, we will update the Effective Date and the changes will become effective as of the date we post such Notice. We will notify you of any material changes by posting a prominent notice on the Helm Services indicating we have updated this Privacy Notice.