Effective April 22, 2013

First Orion Corporation, along with its subsidiaries or affiliated companies (“First Orion” or “we”), is committed to safeguarding your privacy. This
Privacy Policy describes First Orion’s policies and procedures on the collection, use and disclosure of the personal information collected through First
Orion websites, which includes www.privacystar.com, and First Orion applications, which include PrivacyStar™ and Lookup+™, as well as any other sites or
applications owned or operated by First Orion (hereinafter referred to collectively as the “First Orion Websites”). If you download or use any First Orion application or service the terms and conditions contained within the applicable End User License Agreement (the “EULA”) shall also apply to use of the application or service.

Location Services

Some services on First Orion Websites collect information about your location. First Orion Websites use this information to provide you with location-based services and information, such as local search results or special offers, and to produce aggregate statistical data for the improvement of services offered by First Orion Websites. We may outsource some of our technical, tracking and reporting functions, and other services to third parties. We may share information from or about you with them so that they can perform their services. Most mobile devices allow you to turn off location services. For more information about how to do this, please contact your mobile service carrier or your device manufacturer.

Collection and Use

First Orion Websites may collect the following information from you:

• Contact Information such as name, phone number, email address, mailing address
• Financial and Billing Information such as credit card number, billing address and bank account number
• Unique Identifiers such as user name, account number, password
• Device and mobile device information such as device type, mobile device id (including unique device identifier), and mobile service carrier
• Preferences Information you provide such as product or content interests, or communication or marketing preferences
• Usage activity about how you interact with us such as purchase history, what content you viewed, and which areas of our site you visited.
• Demographic information such as interests, and zip code

Some services on First Orion Websites also gather complaint information and allow you to enter associated comments for submission to regulatory authorities and other third parties to aid in their enforcement of marketing laws and prevention of unwanted communications. You should be aware that any information you provide in these areas may be read, collected, and used by such third parties.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP)
addresses, mobile device information, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or page views. We use this information, which does not usually identify individual users, to analyze trends, to administer the First Orion Websites, to track users’ movements around the First Orion Websites and to gather demographic information about our user base as a whole.

We may use information to:

• Fulfill your order
• Send you an order confirmation
• Assess your needs to determine suitable products or services
• Send product or service information
• Send product updates
• Respond to customer service requests
• Administer your account
• Send you push notifications, text messages or emails when you are using a First Orion application or service. If you do not want these notifications,you can manage your preferences either through your device or app settings depending on your device type or contact us at support@privacystar.com.

• Send you newsletters
• Send you marketing communications, including emails and banner advertisements
• Administer contests and sweepstakes you entered, and notify you if you won
• Improve our websites, applications and marketing efforts
• Conduct research and analysis
• Respond to your questions and concerns
• Display content based upon your interests or location

Updating Your Information

To update the personal information you provide to First Orion to ensure it is accurate; contact us at support@privacystar.com.

Information Obtained from Third Parties

• We may obtain data about our customers from third parties and combine it with information we already have about you, to create more tailored
  advertising, products and user experience.
• We may in certain cases obtain credit information about you from an outside credit reporting agency to help us with customer authentication and credit-related decisions.

Sharing your Information

We may disclose your personal information

• 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 or prevent fraud, or respond to a government request.
• if First Orion is involved in a business transition, such as a merger, acquisition, or sale of all or a portion of its assets, your personal
  information will likely be among the business assets transferred. You will be notified via email and/or a prominent notice on our website of any such
  change in ownership or control of your personal information, as well as any choices you may have regarding your personal information.
• to facilitate payment for your subscription to a First Orion product or service.
• to any other third party with your prior consent to do so.

We may provide your personal information to companies that provide services to help us with our business activities such as fulfilling your order, offering customer service or supporting payment related activities.

Some services and features on First Orion Websites access third party databases, services and/or functionality provided or supported by third parties. We share your personal information with such third parties in order to provide you the services and features. Third party collection and use of your personal information is governed by the applicable third party privacy statement.

First Orion Websites may include links to third party websites whose privacy practices may differ from those of First Orion. If you submit personal
information to any of those third party websites your information is subject to their privacy statements. We encourage you to carefully read the privacy
statement of each website you visit.

We may also make your personal information available to other companies so that they can market their products or services to you.

Payment

If you choose to use Google Wallet to finalize and pay for your order, you will provide your payment information to Google Wallet only. Google Wallet’s
privacy policy will apply to the Google Wallet payment information you provide on our website.

If you choose to pay via direct carrier billing through your mobile service provider (payment added to your phone bill) your mobile service provider’s
privacy policy will apply to the payment information you provide.

Web Beacons

A web beacon is an electronic image placed on a web page that can serve many of the same purposes that cookies serve, For example, recording the pages you visit on our site. We or third parties may use Web beacons to track the traffic patterns of users from one page to another.

We or our third party service provider may use web beacons in some of our emails to let us know which emails have been opened by recipients or track
click-through rates. This allows us to gauge the effectiveness of our communications to customers and our marketing campaigns.

Widgets

First Orion Websites may include widgets, which are interactive mini-programs that may run on our site and are designed to provide single-purpose services
(e.g. displaying the latest news, etc). Widgets are hosted by a third party. Personal information, such as your email address, may be collected through the widget. Cookies may also be set by the Widget to enable certain features of the Widget to function properly. The information collected by this widget is subject to the widget’s privacy policy. First Orion is not responsible for personal information you choose to provide through the widget.

Tracking and Ads

We may partner with a third party ad network to either display advertising on our applications or manage our advertising on other websites. Our ad network partner may use technologies to collect non-personally identifiable information about your activities on First Orion Websites and other applications to provide you targeted advertising based upon your interests.

Cookies and other technologies

As is standard practice on many corporate websites, First Orion Websites use “cookies” and other technologies to help us understand which parts of our
websites are the most popular, where our visitors are going, and how much time they spend there. We also may use cookies and other technologies to make
sure that our online advertising is bringing website users to our products and services. We may use cookies and other technologies to study traffic
patterns on our website, to make it even more rewarding as well as to study the effectiveness of our website user communications. And we may use cookies to customize your experience and provide greater convenience each time you interact with us.

If you prefer not to enable cookies certain features of the First Orion Websites may not be available once cookies are disabled.

In some of our email messages, push messages, text messages and other communication; we may use a “click-through URL” linked to content on First Orion
Websites. When website users click one of these URLs, they pass through our web server before arriving at the destination web page. We may track this
click-through data to help us determine interest in particular topics and measure the effectiveness of our communications.

In addition we may use pixel tags — tiny graphic images — to tell us what parts of First Orion Websites users have visited or to measure the effectiveness of searches website users perform on our site. Pixel tags also enable us to send email messages in a format website users can read, and they tell us whether emails have been opened to ensure that we are sending messages that are of interest to Fist Orion Website users.

Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Children’s Privacy

The First Orion Websites are not directed at or intended for use by children under the age of thirteen. First Orion does not knowingly collect or solicit any information from anyone under the age of thirteen or knowingly allow such persons to use or subscribe to any of the First Orion Websites. In the event that we learn that we have collected personal information from a child under the age of thirteen without parental consent, we will delete that information as soon as possible. If you believe that we might have any information from or about a child under thirteen please contact us at support@privacystar.com.

Other Information

First Orion Websites offers publicly accessible areas such as blogs and community forums that allow users to submit comments and other information. You
should be aware that any information you provide in these areas, and any reviews you provide of the First Orion Websites or services in these or any third party forums, may be read, collected, and used by others who access them. First Orion is not responsible for any personally identifiable information you choose to submit in these forums. To request removal of your personal information from any First Orion blog or community forum, contact us at support@privacystar.com. In some cases we may not be able to remove your personal information, and we will let you know if we are unable to do so.

Your California Privacy Rights

California Civil Code Section 1798.83 permits our customers who are California residents to request and obtain from us once a year, free of charge,
information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If
applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third
parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a
request, please submit your request to First Orion in writing to the address below.

Notification of Privacy Statement Changes

We may update this privacy statement to reflect changes to our information practices. We encourage you to periodically review this page for the latest
information on our privacy practices.

Contact

You may contact us about this privacy statement by writing us at the address below:

First Orion Corporation
1111 Main Street, 2^nd Floor
Conway, AR 72032

© 2013 First Orion Corporation. All rights reserved.