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Updated as of March 2018

PRIVACY POLICY

MG Innovation Labs, Inc. dba Globaleur (“Company”) values your privacy and is committed to maintaining your trust. We provide this Privacy Policy to inform you of our policies and procedures regarding the collection, use, and disclosure of personally identifiable information received from users of this website located at https://www.globaeur.com (the "Website") and all of the Company’s other products and/or services, mobile application (the “Application”), interactive features, widgets, and/or other online services that post a link to this Privacy Policy, and all content offered as a part thereof (collectively, the "Services").

Changes. This Privacy Policy may be updated from time to time for any reason, at our sole discretion. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our Website. You are advised to consult this Privacy Policy regularly for any changes.

Incorporation into Terms of Service. By using or accessing the Website or the Services, you are accepting the practices described in this Privacy Policy, and you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us.

This Privacy Policy is incorporated into, and considered a part of, the Company’s Terms of Service.

Personal Information.  “Personal Information” may include, but is not limited to information that identifies you as an individual or relates to an identifiable person, such as name, postal address, telephone number, email address, etc. The Company does not collect any personal data from visitors to its website that is not voluntarily provided. The Company only collects your Personal Information if you register for an account with the Company’s Website, when you use the Company’s Services, and when you send the Company communications in connection with your use of the Services.

Third Party Personal Information. We may obtain your Personal Information from third parties, such as third parties with whom we affiliate in providing the Company’s services. If you provide the Company with Personal Information about third parties, you warrant to the Company that any Personal Information that you provide to the Company about any third party individuals was obtained by you with full consent, and that the individual has not communicated to you that they wish to opt out of receiving communication from the Company or having the Company collect information about him or her.

Use and Sharing of Personal Information. We use the information we collect from our Website and your use of our Services to provide and improve existing Services; to develop new Services; and to protect you and the Company. We also may use this information to offer you tailored content when you visit our Website. We will not share your personal information with

anyone except for our Company’s authorized service providers,1 business affiliates,2 and business partners3 for business purposes; or unless we specifically inform you and give you an opportunity to opt out of our sharing your personal information.

In general, we may use and/or share your Personal Information:

• To respond to your inquiries and your requests regarding our Services.

• To send you information regarding our services and changes to our terms, conditions, and policies.

• To complete your registration, process your payments, and communicate with you regarding your purchase of our Services.

• To send you marketing communication and newsletters about our Services.

• To personalize your experience on our Website or Application.

• To inform you and allow you to participate in our promotions.

• To facilitate social sharing functionality.

• To collaborate with business affiliates, partners, vendors, or service providers to provide you with our Services.

• In connection with our business purposes, including but not limited to data analysis, audits, fraud monitoring and prevention, developing or enhancing new and existing products and/or services, expanding our business activities, etc.

• If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

We will not use and/or share your Personal Information in any other ways than stated herein, above.

1 Authorized service providers are companies that perform certain services including, but not limited to, fulfilling orders, processing credit card payments, delivering packages, providing customer service and marketing assistance, performing business and sales analyses, supporting the functionality of the Services, and supporting contests, sweepstakes, surveys and other features we offer, on our behalf.

These service providers may have access to your Personal Information, but to the extent necessary to perform or fulfill their business purpose. We do not permit them to share or use any of your Personal Information for any other purpose.

2 Affiliate businesses are those businesses with whom we may affiliate to sell our products or Services. We may share information we collect, including Personal Information, with affiliated businesses. Sharing such information with our affiliates enables us to provide you with information about a variety of products and Services that might interest you. We instruct all affiliated businesses to comply with applicable privacy and security laws and, at a minimum, in any commercial e-mail they send to you, to give you the opportunity to choose not to receive such email messages in the future.

3 Business partners are typically merchants offering the products, services, promotions, contests and/or sweepstakes in connection with or somehow related to our own products and Services. We will not share your Personal Information with business partners unless you choose to participate in their offer or program. When you choose to engage in a particular offer or program, you authorize us to share your email address and other Personal Information with the relevant business partner.

However, we reserve the right to disclose Personal Information that we believe to be necessary or appropriate in the following circumstances:

• As required by law, such as to comply with a subpoena, or similar legal process.

• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

• To enforce our Terms and Conditions.

• To allow us to pursue available remedies or limit the damage we may sustain.

Personally Non-Identifiable Information: We may collect personally non-identifiable information, including but not limited to demographic data, age, education level, profession, geographic location or gender, from you at the time of registration, or when you choose to use our Services. This information is not, by itself, sufficient to identify or contact you. The Company may store such information, or it may be included in databases owned and maintained by partners, affiliates, agents, or service providers of the Company. The Company may use such information and pool it with other information to track data related to growing the business, such as the total number of visitors to our Website and the domain names of our visitors' Internet service providers.

Location-Based Information. Our Services, including the Website and Application, may use location-based services in order to locate you so we may verify your location, deliver you relevant content based on your location as well as to share your location with our vendors as part of the location-based services we offer.

Specifically, the Application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link. By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. By using our implementation of the Google Maps APIs, you agree to allow us to gain access to information about you including personally identifiable information (such as usernames) and non-personally identifiable information (such as location).

We may, from time to time provide settings in the Services that permit you to disable location- based services. Changing setting options may not result in immediate changes to the settings, which are subject to our operations and maintenance schedules. Users should carefully consider the use of such settings to improve information display options and to ensure the settings are properly set and functioning in the manner desired.

Notwithstanding the availability of privacy preference settings, you should be aware that these settings are for convenience only, do not employ complex data security protection and may not be error free. Please note that we will only directly provide third parties we work with access to your exact location information if you first give us permission to do so. You should always consider the risks involved in disclosing your location information to other people or third parties.

Passively Collected Information: Your visit to our Website may allow us to obtain certain additional, personally non-identifiable information that is collected passively using various technologies. This information includes but is not limited to, for example, IP addresses, browser types, date and time of page views, location information associated with your IP address,

domain names, your interactions to an ad delivered by us or our ad technology partners and other anonymous statistical data involving your use of the Website and/or our services. This information cannot presently be used to specifically identify you.

Aggregated Personal Data: The Company may analyze your personal data provided through the Website or in connection with rendering the Services, in aggregate form. This aggregate information does not identify you personally. We may share this aggregate data with our partners, affiliates, agents, or service providers for business purposes. We may also disclose aggregated statistics to explain our Services to current and prospective business partners, and to other third parties for other lawful, business-related purposes.

Tracking and Advertising. The Company’s Website may use the foregoing technologies to track your activity on our Website:

• Cookies. When you visit our Website or otherwise interact with the Service, we may send one or more “cookies” to your computer or other devices. Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third party websites. Some features on this site will not function if you do not allow cookies. We may link the information we store in cookies to any Personal Information that you submit while visiting our Website.

We may use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies enable us to track and target the interest of our users to enhance the experience on our site.

Functional cookies, persistent and session type, store information to enable core site functionality, such as Live Chat and Client ID remembrance.

Analytics cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site and our marketing campaigns.

Advertising cookies may be set through our Website by our advertising partners. Data may be collected by these companies that enable them to serve up advertisements on other sites that are relevant to your interests.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/ index.html.

If you reject cookies, you may still use our site, but some features on the site will not function properly.

• Web Beacons. Web beacons are electronic files that signal when a webpage, advertisement, video, other content, an email or newsletter has been viewed. They are usually invisible to you. We may use web beacons alone or in conjunction with cookies to compile information about our Service. Web beacons may be used within the Service to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by web beacons to your Personal Information to gauge the effectiveness of certain communications and our marketing campaigns.

• Log Files. A Log File is a file that records either events that occur in an operating system or other software runs, or messages between different users of a communication software. Log file information is automatically reported by your browser or mobile application each time you access the Website or our Services. Along with cookies and web beacons, log files help provide additional functionality to the Website and Services and help us analyze Website and Services usage more accurately. We and our third party tracking-utility partners may use log files on our Service to gather automatically gather and store information including, but not limited to, internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for business purposes. We may use Google Analytics, which uses cookies and other, similar technologies to collect and analyze information about use of the Service and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/ policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt- out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

• Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

• Browser Fingerprinting. Collection and analysis of information from your Device, such

as, without limitation, your operating system, plugins, system fonts and other data, for purposes of identification.

• ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.

We may, either directly or through third party companies and individuals we engage to provide

services to us, also:

• Track your use of our Website and the Services for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, etc.

• Track your use of the Website and the Services to enable you to use and access the Services and pay for your activities on the Website and through the Services.

Track your behavior on our own Website and use of the Services to market and advertise our services to you on our Website platform and third party websites. You may opt out of receiving advertisements by visiting the Network Advertising Initiative (http:// www.networkadvertising.org/choices/) and/or the Digital Advertising Alliance (http:// www.aboutads.info/choices/). Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on the Services, generally. The advertising will simply not be targeted or specific to your interests.

Children. The Website and our related Services are not intended for anyone under 13, and we do not knowingly collect information from anyone under the age of 13. Anyone aged 13 or under should not submit any Personal Information without the permission of their parents or guardians. By using the Website and our related Services, you are representing that you are at least 13 years old.

Links to Other Websites. This Privacy Policy applies only to this Website and the Company’s Services. It does not apply to any third-party sites. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties such as blog sites with which we partner or affiliate. The inclusion of a link does not imply endorsement of the linked site or service by us.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Website or Service.

Security. We maintain reasonable and appropriate, although not infallible, security precautions. However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your Personal Information, despite our reasonable efforts. You should note that in using the Website and our related Services, your information will travel through third party infrastructures which are not under our control. Please feel free to raise any questions, concerns or specific directions you may have regarding the privacy and security of your information to info@theexplorer.io.

Data Retention. We will retain your Personal Information for as long as needed to provide you with the applicable Services, unless a longer retention period is required or permitted by law.

Do Not Track. Your browser setting may allow you to automatically transmit a "Do Not Track" signal to websites and online service you visit. The Company’s Website does not respond to "Do Not Track" signals or other mechanisms from a visitor's browser. If, in the future, we create a program or protocol to respond to such web browser "Do Not Track" signals, we will inform you of the details of that protocol in this Privacy Policy. To find out more about "Do Not Track," please visit https://www.allaboutdnt.com.

Google AdWords. This Website uses the Google AdWords in order to advertise on third party websites (including Google) to previous visitors to our site or to similar audiences online. This

may result in you seeing an advertisement on the Google search results page, or a site in the Google Display Network. Google may include in-ads notice labels to disclose interest-based advertising to their users. Third-party vendors, including Google, use cookies to serve ads based on someone's past visits to the Website. Any data collected will be used in accordance with our own privacy policy and Google's privacy policy. Google reserves the right to display to users which remarketing lists users are on, along with the corresponding domain name. You can set preferences for how Google advertises to you using the Google Ad Preference Manager (https://www.google.com/settings/ads/onweb/), and you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

Analytics Software.  We and our third party tracking-utility partners use log files on our Service to automatically gather certain information, including but not limited to internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for analytics purposes. Specifically, we analyze trends, administer the site, track users’ movements around the Website, and gather demographic information about our user base as a in the aggregate.

We use Google Analytics, which uses cookies and other, similar technologies to collect and analyze information about use of the Service and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources.

You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

OpenID Providers. OpenID is an open standard and decentralized authentication protocol. You may create and log into your account by selecting an OpenID identity provider such as but not limited to such as Facebook Connect, Twitter, Instagram, etc., and then use those accounts to sign onto our Website or Application, both of which accept OpenID authentication.

You may log into your account on our Website and/or access our Services using sign-in services such as Facebook Connect, Twitter, Instagram, Google+ or a comparable OpenID provider (“OpenID Provider”). In doing so, you provide us with access to your social media account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, checkins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding permissions, you may refer to the relevant permissions/Terms of Use/Privacy Policy pages at the websites belonging to each OpenID Provider named above.

By logging in through an OpenID provider, you have the option to post information about your activities on this Website or on the Application to your social media profile page to share with others within your network, if you so choose.  You may also share with us the contact information of anyone you invite to use our Website and/or join the Application. You agree that if you share with us any Personal Information of third parties, you have obtained their consent to do so.

Mobile Device Data/Access. When you utilize our Application in particular, we may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, calendar, camera, contacts, microphone, reminders, SMS messages, social media accounts, storage, sensors, and other features. If you wish to change our access or permissions, you may do so in your device’s settings. Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide. We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Public Forum on our Website.  Our Website offers publicly accessible message boards, blogs, and community forums to which you may contribute. You may submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, "User Content"), such as on profiles, blogs and message boards. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed), and may or may not attribute it to you.

Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that the Company does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. Our promises regarding handling of your Personal Information under this Privacy Policy do not apply to any information that you disclose publicly, share with others or otherwise upload onto the publicly available positions of our Website. We are not responsible for the accuracy, use, or misuse of any User Content that you disclose or receive from third parties through the Website.

To request removal of your Personal Information from our blog or community forum, contact us at info@globaleur.com. In some cases, we may not be able to remove your Personal Information, especially if it was already re-posted by another user. If this is the case, we will let you know if we are unable to do so and why in response to your request.

Testimonials, Ratings and Reviews. If you submit testimonials, ratings, or reviews of the Services directly on our Website, any Personal Information you include will be displayed on the Website. We may also partner with third-party service providers to collect and display ratings and review content on our Website. If you provide our third-party service providers with your Personal Information in the process of submitting your rating and review, the content and Personal Information collected by a third party will be posted on our Website, absent your express instruction not to do so. If you want your testimonial, rating, or review removed from our Website at any time, please contact us at info@globaleur.com.

Opt-Out Policy. If, at any time after registering, you change your mind about receiving information from us or about the use of information volunteered by you, or if you prefer that we do not share your Personal Information with third parties for marketing purposes, please contact us at info@globaleur.com.

Contact Us. If you have any questions or concerns relating to our use of your Personal Information, please email info@globaleur.com. Additionally, you may reach us by postal mail at: MG Innovation Labs, Inc. dba Globaleur, 4500 Great America Pkwy, Suite 1039, Santa Clara, CA 95054.

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