Welcome to the website or mobile application (as the case may be) (collectively, the “Platform”) of Cobalt Management Services, LLC, a Delaware limited liability company (along with its directors, officers, employees, agents, and service providers, collectively referred to herein as “Cobalt”; “we”; “us” and/or “our”).

The Cobalt website and/or mobile application, which were created and currently operated by us to provide information about our organization to the users of the Platform (“you”; “your”) and allow you to access and benefit from any and all services we offer (together with the Platform, the “Services”). This Privacy Policy sets forth our policy with respect to information, including personally identifiable information (“Personal Data”) and other information that is collected from users of or visitors to the Platform.

Information We Collect

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Services: We may collect Personal Data from you (including, but not limited to, your name, email address and location), when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services. Wherever we collect Personal Data, we make an effort to provide a link to this Privacy Policy.

We collect this Personal Data for the purposes of providing the Services to you, as well as providing customer service, conducting research, and improving the Services. For more details on why we collect your Personal Data and how we use it, please see the section below entitled “Our use of Personal Data and other information.” While you are under no obligation to provide any Personal Data, should you choose to withhold such information, we may not be able to provide you with some or all of the Services.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to our offices and servers, along with the authorized third parties located in the United States that are referred to herein.

Other Information

Non-Personal Information: When you interact with us through the Services, we automatically receive and store certain non-identifiable personal information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Examples of this non-identifiable personal information include the type of internet browser or mobile device you use, any website from which you have come to the Services, your operating system, location data (which is anonymous and where you login through the Platform you will be asked if you consent to the Services accessing your location, which can be updated at any time in your device settings) (“Non-Personal Data”). We may store such Non-Personal Data itself, or such information may be included in databases owned and maintained by our affiliates, agents, or service providers. The Services may use such Non-Personal Data to assist us in providing effective Services and to collect broad demographic information for aggregate use.

Aggregated Data: In an ongoing effort to better understand and serve the users of the Services, we may conduct research on its customer demographics, interests, and behavior based on the Personal Data, Non-Personal Data, and other information provided to us. This research may be compiled and analyzed on a de-identified, aggregate basis, and we may share this aggregate data with its affiliates, agents, and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Location Information: When you use the Services, you may be requested to provide your city or town and state or province of residence. Please keep in mind that other users of the Services may be able to view your city or town and state or province of residence in connection with their use of the Services. We may also use your location information in an aggregate way (as described in the “Aggregated Data” section above).

Mobile Services: The Services may include certain services that are available via a mobile device, including (i) the ability to upload content to the Services via a mobile device; (ii) the ability to browse the Platform and Services from a mobile device; and (iii) the ability to access certain features through an application downloaded and installed on a mobile device (collectively, the “Mobile Services”).

To the extent you access the Services through a mobile device, your wireless service carrier’s standard charges, data rates, and other fees may apply. In addition, downloading, installing, or using certain Mobile Services may be prohibited or restricted by your carrier, and not all Mobile Services may work with all carriers or devices. By using the Mobile Services, you agree that we may communicate with you by SMS, MMS, text message, or other electronic means to your mobile device and that certain information about your usage of the Mobile Services may be communicated to us. In the event you change or deactivate your mobile telephone number, you agree to promptly update your account information to ensure that your messages are not sent to the person that acquires your old number.

Our Use of Personal Data and Other Information

We use Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we only will use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem.

Also, if you provide Personal Data about yourself, or have provided (or otherwise permitted the Services to access) any Third-Party Personal Data in order to obtain access to or make use of particular features of the Services, we will use your Personal Data and any such Third-Party Personal Data to provide you with access to such services and to monitor your use of such services.

We also may use your Personal Data and other Non-Personal Data collected through the Services to help us in providing the Services, processing transactions, fulfilling requests for information, receiving, and sending communications, updating marketing lists, analyzing data, providing support services, or other tasks from time to time.

We may, with your consent, use your Personal Data to contact you in the future to tell you about services we believe will be of interest to you where permitted by applicable law. If we do so, each marketing communication we send you will contain instructions permitting you to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

We may also use your Personal Data and Third-Party Personal Data to send communications relating to the Services, in accordance with applicable laws. For example, we may send periodic emails to registered users of the Services relating to their recent interactions with the Services.

If you use any feature of the Services permitting you to communicate with third parties (such as to refer a third party to the Services or to communicate with them regarding a feature of the Services), either by submitting Third-Party Personal Data to the Services or otherwise permitting the Services to automatically access Third-Party Personal Data in your possession, you acknowledge and agree that you have the authority of the relevant third party for us to access and use the relevant Third-Party Personal Data and that you have notified these third parties and informed them how their information is collected and used by us to provide the Services. We reserve the right to identify you as the person who has made the referral in any messages that are sent to them. We may use Third-Party Personal Data to (i) contact such third party using the Third-Party Personal Data provided; and/or (ii) provide you with an editable template message designed to facilitate communication between you and such third party through the Services.

In addition to sending the foregoing communications, we may also send reminders or related messages to you and to third parties on your behalf from time to time, where permitted by applicable law. In each case, any such communications sent to third parties using Third-Party Personal Data will provide a means to “opt-out” of receiving further communication of the same nature. If we intend to use any Personal Data in any manner or for any purpose that is not consistent with this Privacy Policy, we will obtain your prior informed consent as required by applicable law.

Our Disclosure of Personal Data and Other Information

We are not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Agents, Consultants, and Related Third Parties: Like most businesses, sometimes we hire other companies to perform certain business-related functions. Examples of such functions include mailing information and maintaining databases. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function and require them to only use the information for the purposes for which it was collected.

Legal Requirements: We may disclose your Personal Data if required to do so by law or in the good-faith belief that such action is necessary to: (i) comply with a legal obligation; (ii) protect and defend the rights or property; (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public; or (iv) protect against legal liability.

Cookies

When you interact with the Services, we try to make that experience simple and meaningful. When you visit our Platform, our web server sends a cookie to your computer or mobile device (as the case may be). Cookies are small pieces of information that are issued to your computer or mobile device (as the case may be) when you visit a website or access or use a mobile application, and which store and sometimes track information about your use of the Platform (as the case may be).

A number of cookies we use last only for the duration of your web or application session and expire when you close your browser or exit the application. Other cookies are used to remember you when you return to the Platform and will last for longer.

Some of the cookies used by the Platform are set by us, and some are set by third parties who are delivering services on our behalf. Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org, which provides additional useful information on cookies and how to block cookies using different types of browsers or mobile devices. Please note, however, that by blocking or deleting cookies used on the Platform, you may not be able to take full advantage of the Services.

The Platform uses cookies, and similar technologies to cookies, to collect information about your access and use of the Platform. You can also update your privacy settings on your device by setting the “Limit Ad Tracking” and Diagnostics and Usage setting property located in the settings screen of your Apple iPhone or iPad, or by resetting your Android ID through apps that are available in the Play Store.

Some information on the types of cookies we use and how we use them is set out below:

• Essential: Allow you to navigate and use all the features provided by our Platform.

• Functional Cookies: These cookies customize elements of the promotional layout and/or content of the pages of the Platform and remember that you have visited us before; this means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get. So when you use our Platform, we remember you and your preferences and the information you have submitted to us to provide you with a customized experience.

• Performance and Analytics: Performance cookies let us collect information about how you use the Platform. They collect anonymous statistical information about how you use the Platform (including how long you spend on the Platform) and where you have come to the Platform from so that we can improve the Platform and learn which functions of the Platform are most popular with users. This information does not include Personal Data, although we might be able to associate such information with user accounts once we receive it from the third party.

Your Choices

As mentioned throughout this Privacy Policy, you can visit the Platform without providing any Personal Data. If you choose not to provide any Personal Data, however, you may not be able to use certain Services.

Exclusion

This Privacy Policy does not apply to any Personal Data we collect other than Personal Data collected through the Services.

This Privacy Policy shall not apply to any unsolicited information you provide us through the Services or through any other means. This would include, but not be limited to, information posted to any public areas of the Services, such as forums or comment sections, any customer support communications, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”).

You agree that any Unsolicited Information becomes our intellectual property, to the furthest extent permitted by applicable law, and agree to assign any and all residual rights or interests that you may have in such Unsolicited Information. All Unsolicited Information shall be deemed to be non-confidential, and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution to the extent permitted by applicable law.

Children

We do not knowingly collect Personal Data from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not use the Services and/or submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of thirteen (13) has provided Personal Data to us through the Services, please contact us at Info@cobaltms.com, and we will endeavor to delete that information from our databases.

Links to Other Web Sites

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by us (the “Third-Party Sites”). The policies and procedures we described here do not apply to Third-Party Sites. The links from the Services do not imply that we endorse or have reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their respective privacy policies.

Security

We take reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We have implemented and maintain appropriate technical and organizational security measures, policies, and procedures designed to reduce the risk of accidental destruction or loss, or unauthorized disclosure or access to such information appropriate to the nature of the information, concerned, including where appropriate:

• Password protection, encryption, tokenization, and secure socket layering to protect our Sites;

• Following strict security procedures in the storage and disclosure of your personal information to prevent unauthorized access to it; and

• Placing confidentiality requirements on our employees and service providers.

However, please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time. Please keep this in mind when disclosing any of your personal information via the Internet.

As the security of Personal Data depends in part on the security of the computer you use to communicate with us and the security you use to protect usernames and passwords, you should take steps to protect against unauthorized access to your password, computer, and web-enabled devices, among other things, by signing off after using a shared computer, inserting a password on your web-enabled device, choosing a password that nobody else knows or can easily guess, keeping your password private, and periodically changing your password. You should never share your login information with others. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.

In particular, emails sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to us via the Internet.

Changes to Our Privacy Policy

The Services and our business may change from time to time. As a result, at times, it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time. Any material changes will be preceded by a notice posted on the relevant Service(s). If you disagree with our revisions to the Privacy Policy, you may de-activate your account or discontinue the use of our Services. Please review this policy periodically, especially before you provide any Personal Data. This

Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting Us

To keep your Personal Data accurate, current, and complete, please contact us as specified below. You may request in writing copies of your Personal Data held by us. If your Personal Data that we hold is inaccurate, please let us know, and we will make the necessary amendments, erase, or block the relevant Personal Data as you request, and notify you within thirty (30) days of such request that the relevant action has been taken.

Please also feel free to contact us if you have any questions about our Privacy Policy or the information practices of the Services.

You may contact us as follows: info@cobaltms.com.