LightUpon.Cloud provides a variety of information, Internet, network-, and technology-related services ("Services"), such as tool for collaboration and file sharing.

Your privacy is very important to us, and in order to best protect your information, we have adopted this privacy policy ("Privacy Policy"), which describes the types of information we collect from registered or unregistered end users (each, a "User", "you" or "your") of the lightup.cloud website (the "Site"), and/or the mobile application (the "App", and collectively with the Site and all services provided therein, the "Platform"), how such information is used and processed, and your rights and choices regarding the information you provide to us.

Please read this Privacy Policy carefully prior to your use of, or creation of a registered User account (an "Account") on, the Platform. If you do not agree to abide by this Privacy Policy, please do not use our Platform or create an Account.

By accessing and using the Platform and/or creating an Account, you are deemed to have read, accepted, executed and be bound by this Privacy Policy, including, without limitation, the information collection, use and disclosure practices described herein. This Privacy Policy is governed by the Platform Terms of Service available at /tos/, which includes all disclaimers of warranties and limitations of liabilities. Capitalized terms that are used but not defined in this Privacy Policy have the respective meanings assigned to such terms in the Terms of Service.

1. Information We Collect and Receive

In order for us to (i) provide you with the services and functionalities offered via the Platform, (ii) engage in troubleshooting activities, and (iii) improve upon the Platform’s performance, safety and security, we may collect and process some or all of the following types of information about you:

Personal Information. Information that could be directly associated with you, or used to contact or identify you, without the aid of additional information, including, without limitation, information you provide us when you create an Account such as your name, email address, telephone number and username/password, as well as certain User Content you upload to the Platform.

Usage Information. Information that is not Personal Information, but that relates to your usage of the Platform or that is necessary for the proper functioning or improvement of the Platform, including: (i) times and dates and the extent of your usage of the Platform; (ii) time zone, language, screen resolution, and other usage preferences you select when using the Platform; (iii) device keyboard settings; (iv) usage history such as areas and pages within the Platform that you access or use and/or which buttons in the Platform you click on; (v) search terms you type in on the Platform; (vi) the URL or advertisement that may have referred you to the Platform; (vii) the search terms you entered into a search engine or app store that may have led you to the Platform; (viii) the mobile platform or service provider you use, and (ix) other device and Platform access information such as your browser type, operating system, IP address, referring/exit pages, and other unique device identifiers, as well as your push notification token.

Metadata. When you upload User Content, you automatically upload certain metadata that is connected to the User Content. Metadata describes other data and provides information about your User Content that will not always be evident to the applicable viewer. In connection with your User Content, the metadata can describe how, when and by whom the piece of User Content was collected and how that User Content is formatted. It further includes certain Personal Information, such as your account name, that enables other Users to trace back the User Content to your Account. Metadata will further consist of additional Personal Information that you chose to provide (e.g., file modification time ).

Customer Support. We collect information that you provide to us, including any Personal Information, when you contact us for customer-support purposes.

While certain types of information described above, such as Usage Information and Third-Party Information, are generally non-identifying on a standalone basis, we may in certain instances combine this information with other information collected on the Platform, as described above. If we ever combine non-identifying information with Personal Information or other information that enables you to be identified, we will treat such combined information as Personal Information. We do not currently use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

2. GDPR Compliance

European Union data protection law requires a "lawful basis" for collecting and retaining Personal Information from citizens or residents of the European Economic Areas ("EEA"). Our lawful basis for collecting such information about you is permitted under "Article 6", Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 ("GDPR"), which are summarized below.

Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your email address when you create your Account, or making certain User Content publicly available on the Platform.

Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Platform, such as fulfilling any future subscription based, or other transactional, services.

Legal Obligations. Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Platforms.

Legitimate Interests. This is a technical term that means we have a good and fair reason to use your Personal Information and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we use identity and device information to prevent abuse of the Platform by Users and to keep the Platform secure.

3. California Privacy Rights ( CCPA )

This section provides additional details about the Personal Information we may collect about California-resident Users and the rights afforded to them under California Civil Code Section 1798.83 and the California Consumer Privacy Act of 2018 ("CCPA"). California-resident Users are entitled to additional privacy rights which are further described below. California-resident Users who wish to request further information about our compliance with the above referenced statutes or who have questions more generally about our Privacy Policy or the CCPA and our privacy commitments to our Users should not hesitate to contact us in accordance with the procedures set forth below.

What Information We Collect

As also detailed in the "Information We Collect and Receive" section above, through the Platform we collect certain Personal Information, including such information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California-resident User or his or her device. In particular, the Platform, collects the following categories of Personal Information:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.	YES
B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, telephone number.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

How We Use Personal Information. We collect Personal Information for the business and commercial purposes described in the "Use of Information We Collect" section above.

We share Personal Information with the categories of third parties described in the "Sharing Your Information" section above. We do not sell (as such term is defined in the CCPA) Personal Information we collect (and will not sell it without providing a right to opt out).

Please note that we do use third-party cookies for certain purposes as further described in the "Cookies and Other Tracking Technologies" section above.

California Residents’ Rights and Choices with Respect to Personal Information Subject to certain limitations, the CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights, which specifically includes:

• Right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this information);
• Right to delete their Personal Information;
• Right to opt out of any "sales" that may be occurring; and
• Right to not be discriminated against for exercising the foregoing rights.

Access to Specific Information and Data Portability Rights. You have the right to request that Company disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights subsection below), we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing the following: (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights. You have the right to request that Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising

Access, Data Portability, and Deletion Rights subsection below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at legal@lightupon.cloud

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an Account with us. However, we do consider requests made through your password protected Account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format. Company endeavors to respond to a verifiable California residents request within forty-five (45) days of its receipt. If Company requires more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Personal Information Sales Opt-Out and Opt-In Rights. We will not sell your Personal Information to any party. If in the future, we anticipate selling your Personal Information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.

Non-Discrimination Company will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Company will not:

• Deny you products or services on the Platform.
• Charge you different prices or rates for products or services on the Platform, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of products or services on the Platform.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of products or services on the Platform.

4. Personal Information Protection ( PIPEDA )

We protect and use your information by observing principles and guidelines in the Personal Data Protection and Electronic Documents.

If LightUpon.Cloud seeks to use your Personal Data for a new purpose, we will contact you to obtain the appropriate consent.

5. Use of Information We Collect

We may use the information we collect about/from you to:

• Identify you and potentially improve and/or customize the Platform
• Send you administrative notices or Account notifications
• Send you requested service and other Platform information
• Address inquiries and respond to customer service requests, questions and comments
• Administer your Account and manage your Account profile information
• Send you newsletters and mail (including email)
• Contact you with offers, promotions and other product specials
• Send you SMS messages (subject to certain opt-ins described herein)
• Send you more relevant marketing communications and general Platform information/updates
• Create a more personalized User experience and customize certain content you see on the Platform
• Identify trends, conduct data analysis and determine the effectiveness of our marketing and promotions and other service offerings
• Improve your User experience and increase the efficiency and effectiveness of the Platform service and functionality offerings
• Maintain security
• Enforce our Terms of Service and applicable law
• Analyze Platform usage and other trend data
• Solicit feedback, reviews, and other information regarding your experience with the Platform, including, without limitation, with respect to certain features and functionalities that you would like to see on the Platform, or that we have recently rolled out onto the Platform
• Test new features, service offerings and functionalities on the Platform
• Other purposes that we believe are necessary to protect our rights and the rights of others, or as otherwise described to you at the time of collection

We may also use certain collected information on an aggregated and/or anonymized basis in order to conduct market research, engage in project planning, for troubleshooting purposes, to help detect and protect against error, fraud or other criminal activity.

6. Email Notifications and Opt-Out

We maintain a strict "no-spam" policy. Unless you requested otherwise in your account settings at the time of your initial registration or specifically opt-out as provided herein, by accepting the Terms of Service and this Privacy Policy, you expressly agree that we may use your information to contact you by email in order to deliver you information that is relevant to your use of the Platform such as administrative notices, product/service enhancements or "newsletters", or that, in some cases, is targeted to your interests, such as information about User Content or service/functionalities offerings that we believe you may be interested in learning more about. You may choose to stop receiving these email communications from us by following the instructions included in such communications or by contacting us at legal@lightupon.cloud. If a third party vendor provides such newsletters, you may unsubscribe in accordance with the instructions provided by such third party. If you are having problems unsubscribing please contact us at legal@lightupon.cloud (forwarding the newsletter, if applicable, and including in the Subject line the word "Unsubscribe"), and you will be removed within seven (7) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any newsletter.

7. Sharing Your Information

We do not share your information publicly. But certain Personal Information that you upload to the Platform will automatically, or upon your selection, be made available to other Users on the Platform, selected by you.

You acknowledge and agree that certain Account information (such as your Account profile name and/or User Content, etc.) that you provide in connection with (i) the registration of your Account and (ii) your general use of the Platform, such as uploading User Content, will be viewable by Users from your security groups.

We are not responsible for the privacy practices of the other Users who will view and use this information, so you should carefully consider whether to upload any User Content on the Platform or how you identify yourself on the Platform.

Information We May Share with Third Parties. We may share aggregated usage information and may otherwise disclose non-Personal Information that we collect to third parties. However, absent your prior consent, we will share your Personal Information with third parties only in the ways that are described in this Privacy Policy, including as set forth below, and we do not otherwise sell your Personal Information to third parties.

• We may use third parties to outsource one or more aspects of our business and/or Platform operations (including, but not limited to, email or customer service functions, data processing, web analytics, maintenance, online advertising. Such third parties will only use your Personal Information to the extent necessary to perform their functions and will be contractually bound to process your Personal Information only on our behalf and in compliance with our requests.
• We also work with (or may in the future work with) network advertisers, ad agencies, analytics service providers, and other vendors to provide them with information regarding traffic on the Platform, including pages viewed, content interacted with, and actions taken by Users when visiting the Platform; to serve advertisements on other web sites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Platform and the effectiveness of our advertisements and other marketing campaigns. Our service providers may collect certain information about your visits to, and activity on, the Platform as well as other websites or services, they may set and access their own tracking technologies on your device (including Cookies and Web Beacons), and they may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Platform or other online websites and services. We may also share certain non-Personal Information with these parties, in connection with the services they provide to us.
• We will also share your information with any member, subsidiary, parent or affiliate of our company, only for the purposes set out above, to assist in the improvement and optimization of the Platform, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes.

8. Storage and Transfer of Information

• Information collected by us may be stored and processed in Ukraine or any other country in which we or our agents maintain facilities. By using the Platform, you expressly consent to any such transfer and storage of information outside of your country of residence, where data protection laws may be different and/or less stringent. However, we will endeavor to take reasonable measures to keep up an adequate level of data protection also when sharing your Personal Information with such countries.
• We make no representation or warranty with respect to any duty to permanently store any information you may provide or that we otherwise collect about you. We strive to keep our processing activities with respect to your Personal Information as limited as possible. In the absence of specific retention periods set out in this Privacy Policy, we will retain the information we collect from or about you only as long as necessary to provide you with the Platform or our services, which includes for the duration of, but could extend beyond, your active participation on the Platform, or as otherwise set forth in this Privacy Policy, and to the extent set out in this Privacy Policy and as necessary to comply with our legal and/or statutory obligations, resolve disputes, enforce our agreements, and protect our legal rights. Additionally, we may retain indefinitely any aggregated, anonymized, or pseudonymized information which we may collect and maintain, and may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format. By using the Platform and providing us with information (including Personal Information), you waive any claims that may arise under your own or any other local or national laws, rules or regulations or international treaties. We may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format. This Privacy Policy applies to your information for as long as your information is in our possession, even if you terminate or discontinue your use of the Platform.
• With respect to any Personal Information that may be originally collected and stored in the EEA, if and when we transfer your Personal Information to countries outside the EEA, we will do so under the Commission’s model contracts for the transfer of Personal Information to third countries (i.e., standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as appropriate).

9. Cookies and Other Tracking Technologies

We may use cookies, for example, to keep track of your preferences and Account profile information, or to engage in certain retargeting activities that we feel will better enhance your User experience and the efficiency and effectiveness of the Platform and certain services and functionalities offered thereon. Cookies are also used to collect general usage and volume statistical information that does not include Personal Information. We may also use another company or third-party service to place cookies on your computer to collect non-personally identifiable information to compile aggregated statistics for us about Users of the Platform.

Cookies are small pieces of information that are stored as text files by your Internet browser on your computer's hard drive. Most Internet browsers are initially set to accept cookies. You can set your browser to refuse cookies from websites or to remove cookies from your hard drive, but if you do so, you may not be able to access or use portions of the Platform, or certain offerings on the Platform may not function as intended or as well. Also, some browsers have "do not track" features that allow you to tell a website not to track you. These features are not all uniform. If you block cookies, certain features on the Platform may not work. If you block or reject cookies, not all of the tracking described herein will stop. Please note that certain options you select are browser- and device-specific.

A more detailed list of the cookies we currently, or in the future may, use and how we use, or may use, them are as follows:

• Security;: We secure the Platform with cookies that facilitate security features and allow us to detect activity that might violate our rules and Terms of Service, such as unauthorized access or activity.
• Localization: We use some cookies to help us provide localized experiences, such as displaying the Platform in the local language.
• Platform Features and Services: We use certain cookies to provide greater functionality to the Platform and help us deliver our products and services.
• Performance: We use performance cookies to help us route traffic between servers and understand how the Platform is performing so we can provide users with the best experience possible.
• Analytics and Research: We use certain cookies and other technologies also help us to understand, improve, and research features and content on the Platform.

10. Your Rights

In certain circumstances you have the right to access the Personal Information that we collect/hold about you and to correct, update, or request deletion your Personal Information. Prior to the fulfilment of your request concerning your Personal Information, we will ask you to verify your identity before we can act upon your request.

You have the following rights:

• The right to require free of charge (i) confirmation of whether we process your Personal Information and (ii) access to a copy of the Personal Information retained;
• The right to request proper rectification, removal or restriction of your Personal Information;
• Where processing of your Personal Information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Information concerning you in a structured, commonly used and machine-readable format or to have your Personal Information transmitted directly to another company (data portability);
• Where the processing of your Personal Information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;
• The right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Information, as well as to lodge complaints before the competent data protection regulators.

As far as we process your Personal Information on the basis of our legitimate interests, you can object to processing at any time. You can find a detailed description of our processing activities and the legal basis in the sections above. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your Personal Information and decide whether to adjust the processing accordingly.

11. Do Not Track Requests

Please note that your browser setting may allow you to automatically transmit a "Do Not Track" signal to websites and online service you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, we do not alter our practices when we receive a "Do Not Track" signal from a visitor’s browser.

12. Security

The security of your information is important to us, and we take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.

We follow generally accepted industry standards to protect your information, both during transmission and once we receive it, and to keep such Information confidential (unless it is non-confidential by nature, for example, publicly-available information) and free from any unauthorized alteration. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. While we strive to keep current our security technology and will review, refine and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, the complete and absolute security of any Information collected, stored or used by us cannot therefore be guaranteed. In the unlikely event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately.