RAKA

PRIVACY POLICY

Purpose

The purpose of this policy is to inform customers of RAKA Group and its subsidiary and affiliated companies (“us,” “we”or “our”) and users of our websites regarding the collection and use of Customer Information (as defined below).

Overview

The exchange of information is critical in business relationships. Customers and potential customers (“Customers”), in their interactions with us, may provide and disclose various types of information to us which enables us to provide products, services or support to our Customers. In some cases, providing this information to our critical manufacturers and suppliers (“Critical Vendors”) furthers our mission to provide these benefits to our Customers. This information will be referred to throughout this policy as “Customer Information.”

Implementation and Responsibility

We recognize the importance of Customer Information to our Customers and have enacted this Privacy Policy to set out how we will collect, communicate and disclose, and make use of our Customer Information. Due to the nature of our business, it is anticipated that this information will be of a commercial nature and not consumer or personal information.

Collection of Customer Information

We may obtain Customer Information from a variety of sources, including, without limitation, Customer transactions and related documents, Customer survey responses, equipment technology, its website or other Customer interacting technology, Customer inquiries, third party brokers, resellers and data aggregators or industry sources.

The Customer Information will generally include, but is not limited to, Customer name, company size and sector, individual contact names and job titles, postal address, telephone and fax numbers, e-mail addresses, and equipment owned and/or used by Customer. We may also has access to Customer Information that is generated from equipment usage.

Company Use of Customer Information

In all cases, we will utilize Customer Information and safeguard it as required by applicable laws.

Our use of Customer Information generally enables us to provide services to our Customers (including order processing, warranty, delivery, installation and support services, invoicing and answering Customer inquiries). In addition, we may also use Customer Information to improve the level and type of services and products that we offer. As part of this interest in improving the services and products provided, Customer Information may be processed and enhanced as provided below.

We may from time to time inform our Customers about products and services and other information we feel may be of interest.

To Whom Do We Disclose Customer information?

We may exchange Customer Information within our company, as well as our subsidiary and affiliated companies and among their internal departments in order to fulfil sales and support obligations, as well as for marketing, operational or strategic functions. As a general rule, we do not disclose Customer Information to parties outside of our company except as set forth herein.

Certain Customer Information of a general nature (i.e. Customer name, address, equipment purchased and serial numbers) that is necessary for post-sale functions by our Critical Vendors (such as documenting purchases and providing warranty and other service functions) may be passed to these Critical Vendors. In addition, the products sold may also contain technology for transmitting information on the product’s use directly to the Critical Vendor. Critical Vendors may use Customer Information provided by us for their own direct marketing purposes.

In addition, we may contract with a third party marketing consultant(s) and/or data processor(s) to provide strategic guidance, outsource services or exchange, collect and process Customer Information. In such case, we will enter into a contract with such parties that requires such parties to employ reasonable and appropriate safeguards to protect the confidentiality of Highly Sensitive Customer Information (which is defined as Customer Information of such a sensitive nature that a reasonable person would believe it presents a serious and imminent risk to the Customer’s business if discovered by a competitor or the general public, such as financial data or trade secrets). We do not authorize these third parties to use Customer Information for purposes other than for which they has been provided, and do not authorize these third parties to disclose that information to unauthorized parties or use that information for their direct marketing purposes. We may, as part of our transactions with these parties, allow such parties to aggregate the Customer Information for use in its products.

In certain limited situations, we may share “de-identified” Customer Information with affiliated third parties. “De-identified” Customer Information means Customer Information which has been scrubbed of the identifying elements so that it does not specifically identify a company or individual and there is no reasonable basis to believe that the company or individual to which the information applies can be discerned.

Unless required by law, Highly Sensitive Customer Information will not be disclosed for use by parties outside of our company.

Any Customer Information provided to any third party is governed by the third party’s privacy policy.

Finally, we may share Customer Information if required or permitted to do so for any or all of the following reasons: (i) to comply with a subpoena, legal process, government request or any other legal obligation, (ii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of the website or our network, (iii) to protect our rights, privacy, property, business or safety, as well as those of our partners and employees, the visitors of the website, or the public; and (iv) in conjunction with the sale of all or a part of our assets.

Protection of Customer Information Held by Us

While it is impossible to avoid all security risks, we take Customer confidentiality and security very seriously. We have implemented reasonable and appropriate security procedures that restrict access to and disclosure of Customer Information within our company. These procedures will be reviewed from time to time to determine whether they are being complied with and are effective.

Children’s Privacy

Our website is not directed to children under 13. We do not knowingly, through the website or by any other means, collect personally identifiable information from children under 13. If a parent or legal guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she may contact us at [email protected] to review what has been collected or to request the deletion of any information collect.

Opt Out Option and Correcting Your Information

You may opt out of receiving emails from us by following the instructions in those emails. Please allow ample time for us to process your request. You may also request changes to your contact preferences and to your information by emailing us at [email protected].

Contact Details

Questions related to this Privacy Policy should be directed to [email protected].

Policy Updates

As part of our commitment to compliance with data privacy requirements, and to reflect changes in our operating procedures, we may update the terms of this Privacy Policy from time to time and will post the revised policy on our website.