Klick Guardrail™
Privacy Policy

Effective Date: June 12, 2026

We at Klick Inc. and our affiliates Klick USA, Inc., Klick Health UK Private Limited, Klick Health Asia-Pacific Pte. Ltd., Klick Health EU GmbH, Klick Health Brasil Ltda, Klick Health Japan G.K., Klick Health Latin America SRL,, and Klick Health Germany GmbH (collectively, “Klick”, “us”, “our”, or “we”) are strongly committed to transparency, and we want you (“you” or “your”) to understand how we collect, use, share and protect your personal information, as well as how you can manage the personal information we collect. The following privacy policy (“Privacy Policy”) applies to your interactions with us, including your visits to our websites, located at https://guardrail.klick.com and your assigned specific Guardrail™ URLs (collectively, the “Site”), and use of our Guardrail™ software and related features and services (collectively with the Site, the “Services”).

Please note that this Privacy Policy does not address our practices with respect to: (i) the information we may collect and process about our employees, job applicants or independent contractors; and (ii) the information we may collect and process on behalf of our customers as processors or service providers, which is instead subject to the privacy policies of our customers.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you provide us with your information, including when you visit our Site, you accept the terms of this Privacy Policy and our Terms of Use, and consent to our collection, use, disclosure, retention and other processing of your information as described in this Privacy Policy.

1. Information We Collect

a. Personal Information

Klick collects personal information about you, which may include:

• Identifiers: name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address
• Categories Listed in the California Customer Records Statute: name, address, telephone number. If you are a customer, we may also collect bank account number, credit card number, debit card number, or any other payment information (e.g., billing and shipping address, card expiration date, security code) for the Services you purchase from us.
• Commercial Information: details of your specific orders and transactions with us, records of Services purchased, obtained or considered
• Internet or Other Electronic Network Activity Information: IP address, operating system type, browser type, access times and dates, device type, approximate geographic location, your interaction with our Services and advertisements, other technical information such as protocol status and substatus, bytes sent and received, and server information
• Geolocation Data: approximate geographic location.
• Professional or Employment-Related Information: Job title, company name.
• Miscellaneous: Any information you may provide when you contact us, including through our Contact Us web page on the Site.

This information is collected and stored electronically when you access the Site, purchase or use our Services, request a demo, subscribe to our newsletter, or otherwise contact us.

We may also collect personal information from:

• Service providers;
• Website analytics and digital advertising partners
• Our customers for whom you are accessing the Services for/on behalf of; and
• Publicly available information.

Where permitted by applicable law, we may combine your personal information with other information we have collected from you. We may also combine personal information we collect from you with information we receive about you from other sources, such as our service providers and website analytics and digital advertising partners.

b. Information Collected Automatically

In addition, information about your device's hardware and software is automatically collected by Klick when you access and/or use the Services. This information may include:

• IP address
• Operating system type
• Browser type
• Access times and dates
• Device type
• Approximate geographic location
• Other technical information such as protocol status and substatus, bytes sent and received, and server information.

We may also collect information regarding traffic patterns and your interaction with our Services and advertisements. This information is used by us for our business purposes, including for the operation and improvement of the Services, for technical troubleshooting, to maintain the quality of the Services, to provide general statistics regarding use of the Services and to determine the effectiveness of our promotional campaigns.

We may also receive similar data from our website analytics and digital advertising partners, online advertising networks and from social media platforms, subject to your registration and privacy settings with such third-party social media platforms, and we may share this data with such third parties.

c. Cookies and Other Information Collection Tools

Cookies

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information.

We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date.

The types of cookies Klick may use on the Site include:

• Strictly Necessary Cookies. These cookies are necessary for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Site will not then work.
• Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our Site pages. If you do not allow these cookies then some or all of these services may not function properly.
• Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Site. They help us to know which pages are the most and least popular and see how visitors move around the Site. All information these cookies collect is aggregated. If you do not allow these cookies we will not know when you have visited our Site, and will not be able to monitor its performance.
• Analytics Cookies. These cookies help us understand and measure how you interact with our Site, allow us to collect and report statistical information on Site traffic, and to test new Site content, features or interactions so we can improve the Site experience and appearance for all.
• Advertisement/Targeting Cookies. These cookies enable us to display ads on this Site, any other Sites that are more relevant to your interests, to find others who look similar in interests, and to measure the effectiveness of our marketing efforts. These cookies may be set through our Site by our advertising partners. The use of these cookies may involve tracking, targeting and re-engaging our visitors across multiple sites and social media networks. They may be used to build a profile of your interests and show you relevant advertisements on other sites. If you disable these cookies, you will still see advertisements about our products, however they will not be personalized for your interests.

We may also use third-party cookies, like Google Analytics, for example, which sets cookies on the Site to help analyze how visitors use the Site. You can visit https://www.google.com/settings/ads to learn more about Google's use of cookies. If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics' opt-out browser add-on designed for this purpose. Please note that information collected via third-party cookies may be shared with our website analytics and digital advertising vendors.

Cookies help us improve the Site by providing us with information about which parts of the Site are most popular, enabling us to analyze technical and navigational information about the Site, and helping us to detect and prevent fraud. We also use cookies and other data collection tools, such as pixels/web beacons, to help improve your experience with the Site.

Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user's computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Site. You may also manage your cookie preferences by clicking on the “Cookie Settings” link set forth in the footer of our Site.

Pixels / Web Beacons

A pixel or web beacons is an HTML code snippet embedded in a website or email that collects information about user behaviors and interactions with the website or email.

We may utilize pixels/web beacons both on certain aspects of the Site and in HTML-formatted email messages to you. Pixels/web beacons may be used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Site usage and tracking the activities of users of the Site and email recipients. For instance, we may use pixels from Meta and LinkedIn on the Site to enable us to create targeted advertisements and measure the effectiveness of our advertisements. Please note that information collected via pixels/web beacons may be shared with our website analytics and digital advertising vendors. For additional information on interest-based advertising, please see Section 2 (Interest-Based Advertising).

2. Interest Based Advertising

We may collect information about your online activities on our Site to provide you with advertising about products tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our advertisements are served.

You may see certain advertisements on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites, including our Site, by collecting information through automated means, including through the use of third-party cookies and pixels/web beacons, including the pixels/web beacons that we may utilize on the Site and in our HTML-formatted email messages to you. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our advertising partners' targeted advertising services to show you our advertisements on other websites based on your prior visits to our Site and other online activity.

Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you may opt out of interest-based advertising generally through the U.S. Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising). To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices. In Canada, you can learn more about online behavioural advertising and manage your advertising preferences through the Digital Advertising Alliance of Canada (“DAAC”) at https://youradchoices.ca/en/tools. For mobile applications, you may use AppChoices, available at https://youradchoices.ca/en/appchoices.

You may also opt-out of interest-based advertising by clicking on the “Cookie Settings” link set forth in the footer of our Site and managing your preferences. Opting-out does not mean that you will stop receiving advertisements from us. It means that you will stop receiving advertisements from us that have been targeted to you based on your visits and browsing activity across websites over time.

3. How Information is Used

We may use the information we collect for any of the following purposes:

• to provide, operate, and personalize the Services we offer, which includes updating, securing, troubleshooting and providing support, and to give each user a more consistent and personalized experience when interacting with us;
• to manage your account with us;
• to deliver and personalize our marketing communications;
• if you sign up for our email list, to send you our newsletters and emails about our Services or offers that we think might be of interest to you;
• to complete and fulfill your purchase, for example, to process your payments through our third-party payment processor, communicate with you regarding your purchase, and provide you with related customer service;
• for security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Services;
• to respond to your inquiries and communicate with you;
• For our other business purposes, such as data analytics, accounting, auditing and reporting, developing new or improving our Services, identifying Site usage trends and determining the effectiveness of our promotional campaigns;
• As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Use; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

For information on the lawful bases and personal data involved (relevant to UK and EEA data protection law) please see the Appendix at the end of this privacy policy.

4. Disclosure of Information

We may disclose your information:

• With our Family of Companies: We may share your personal information within our family of companies, including our parent, subsidiaries and affiliates, for our internal business purposes.
• With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Services or assist us in providing functionality on the Services, provide data analytics on the Site, send out email updates about our Services, and process payments.
• Through Tracking Technologies. We may share information collected through tracking technologies set on the Site with our website analytics and digital advertising partners, including but not limited to the cookies and pixels/web beacons we may utilize on the Site and in our HTML-formatted email messages to you as described above.
• For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental or law enforcement request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain.
• Changes of Control. We reserve the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

5. Links to Third-Party Websites and Online Services

The Site may contain links to websites or online services that are not owned or controlled by Klick. Please be aware that we are not responsible for the privacy practices of such third parties. We encourage you to read the privacy statements of such third parties. This Privacy Policy applies only to information collected by Klick.

6. Social Media

Some aspects of the Site may allow you to interface with social media, such as Instagram, Facebook, X, LinkedIn and YouTube. We will attempt to identify these aspects of the Site to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. If you interface with the Site through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

7. Your Rights and Choices

a. Opt-out

You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in such emails or contacting us at privacy@klick.com.

b. Access and Correction

You have the right to request access to and to correct the personal information that we hold about you. If you want to review, verify, correct, or withdraw consent to the use of your personal information you may email us at privacy@klick.com. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

c. Additional Rights

As required or permitted by law, you may be entitled to additional rights depending where you live, including:

1. the right to control the dissemination of your personal information;
2. the right to receive computerized personal information collected from you in a structured, commonly used and technological format and to have this information transferred directly to another organization;
3. the right to be informed of and submit observations regarding automated decision-making;
4. the right to request information about data processing;
5. the right to request access to your personal data;
6. the right to request erasure of your personal data in certain circumstances;
7. the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests);
8. the right to request restriction of processing of your personal data - this enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
   • if you want us to establish the data's accuracy;
   • where our use of the data is unlawful but you do not want us to erase it;
   • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
   • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
9. the right to make a complaint to us if you believe we are not processing your personal data in accordance with data protection law, and/or to complain to a relevant data protection regulator.

d. Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at privacy@klick.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

8. Data Security and Retention

Klick uses reasonable security measures designed to prevent unauthorized intrusion to the Services and the alteration, acquisition or misuse of personal information. However, please note that no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. It is your responsibility to protect the security of your login information.

We will retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

9. Do Not Track

Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

10. Transfer of Your Personal Information

The personal information that we collect from you may be transferred to, and stored at, a destination outside of Canada (including in particular, in the United States and countries in the European Economic Area). with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country.

You may ask for further information on the safeguards that we have put in place to safeguard the transfer of your personal information by contacting us at privacy@klick.com.

11. Children

We do not knowingly collect or maintain Personal Information from any person under the age of 18. No parts of our Site are directed to or designed to attract anyone under the age of 18.

12. Nevada Residents

Under Nevada law, Klick does not sell your Personal Information. However, if you are a Nevada resident, you may submit a request that we not sell any Personal Information we have collected about you by contacting us at privacy@klick.com.

13. California Residents

CCPA

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (“CCPA”) provides California residents with specific rights regarding their personal information. The below describes such rights and how you may exercise such rights, and our information practices, including the categories of personal information we collect, use, retain, disclose, sell or share, and how and why we collect, disclose, sell or share such information.

CCPA Rights

Right to Know

You have the right to request that we disclose what personal information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

• The categories of personal information we have collected about you.
• The categories of sources from which the personal information is collected.
• The business or commercial purpose for collecting, selling or sharing personal information.
• The categories of third parties with whom we disclose personal information.
• The specific pieces of personal information we have collected about you.

You may also request that we disclose to you:

• The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.
• The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Right to Delete

You have the right to request that we delete any personal information about you which we have collected from you. If it is necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.

Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to direct a business that sells or shares personal information about you to third parties not to sell or share your personal information. We do not sell your personal information for monetary consideration. However, we do use tracking technologies such as cookies and pixels/web beacons for analytics and targeted advertising purposes. The collection of data through certain tracking technologies for analytics and targeted advertising purposes may be considered a “sale” and is considered “sharing” under the CCPA. To opt-out of having your information sold and shared with third-party website analytics and digital advertising vendors for this purpose, please click the “Do Not Sell or Share My Personal Information” link set forth at the footer of our Site.

The CCPA requires businesses to process opt-out preference signals (“OOPS”), such as global privacy control (“GPC”) signals, which are signals sent by a platform, technology or mechanism, enabled by individuals on their devices or browsers, that communicate the individual's choice to opt-out of the sale and/or sharing of personal information. To use an OOPS/GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the OOPS/GPC (for example, https://globalprivacycontrol.org/). We have configured the settings of our consent management platform to receive and process GPC signals on our Site.

Klick does not have actual knowledge that it sells or shares personal information about minors under the age of 18.

Right to Correct Inaccurate Personal Information

You have the right to request a business that maintains inaccurate personal information about you to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to direct a business that collects sensitive personal information about you to limit its use of your sensitive personal information (1) to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; (2) for certain business purposes; and (3) as authorized by the implementing regulations of the CCPA. Klick does not collect your sensitive personal information.

No Discrimination

You have the right not to be discriminated against because you exercised any of your aforementioned rights.

How to Submit a Request

To exercise the rights to know, delete and correct described above, you must submit a verifiable request to us. You can do so by calling us at 1-877-885-9957, completing the form here, or emailing us at privacy@klick.com.

To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor's identity or authority to make the request.

How We Collect, Use, Disclose, Sell and Share Personal Information

Please see Section 1 (Information We Collect) for the categories of personal information we have collected about you in the twelve (12) months prior to the effective date of this Privacy Policy. Each of the categories are disclosed for a business or commercial purpose as described above in Section 3 (How Information is Used) to the third parties listed in Section 4 (Disclosure of Information).

Klick collects the personal information described in Section 1 (Information We Collect) from or through the following categories of sources:

• You, directly and indirectly, including when you access the Site, purchase or use our Services, request a demo, subscribe to our newsletter, or otherwise contact us;
• Service providers
• Website analytics and digital advertising partners
• Our customers for whom you are accessing the Services for/on behalf of; and
• Publicly available information.

As noted in Section 8 (Data Security and Retention), we will retain the Personal Information described above for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulations.

The following categories of personal information were sold or shared in the twelve (12) months prior to the effective date of this Privacy Policy:

• Identifiers: unique personal identifier, online identifier, IP address.
• Internet or Other Electronic Network Activity Information: IP address, operating system type, browser type, access times and dates, device type, approximate geographic location, your interaction with our Services and advertisements, other technical information such as protocol status and substatus, bytes sent and received, and server information.
• Geolocation Data: Approximate geographic location.

Such information is sold to or shared with our third-party website analytics and digital advertising partners.

We share or sell such information:

• to provide, operate, and personalize the Site, and to give each user a more consistent and personalized experience when interacting with us;
• to deliver and personalize our marketing communications;
• for security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
• to respond to your inquiries and communicate with you;
• For our other business purposes, such as data analytics, accounting, auditing and reporting, developing new or improving our Services, identifying Site usage trends and determining the effectiveness of our promotional campaigns;
• As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Use; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

California Shine the Light

Under California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, if you are a California resident, you have a right to prevent your personal information from being disclosed to third parties for those third parties’ direct marketing purposes. If you would like to exercise this right, please opt out of the Analytics and Advertising Cookies by clicking the “Cookie Settings” link set forth in the footer of the Site.

14. Questions / Contact Us

If you have any questions regarding this Privacy Policy, please contact us at:

15. Notification of Changes

Any changes to our Privacy Policy will be posted to this page so users are always aware of the information we collect and how we use it. Accordingly, please refer back to this Privacy Policy frequently as it may change.

Appendix

HOW WE USE YOUR PERSONAL DATA (UK and EEA)

Legal basis

The law in the UK and EEA requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to marketing emails.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.