VOYAGER LABS PRIVACY POLICY

This Privacy Policy was published on October 1, 2016

1. Summary

This Privacy Policy (this “Policy”) describes the types of information about you (your “Personal Data”) which Bionic 8 Analytics Limited and its affiliates (collectively, “Voyager Labs”, “we” or “us”) may collect, and further process. As set out below, your Personal Data includes any information that identifies you, or from which you are identifiable.

We at Voyager Labs respect your privacy and invest in keeping your information secure. We are committed to abide all applicable privacy regulations. By accessing or using any of our websites or services you agree to this Privacy Policy.

Please note that some of Voyager Labs’ data processing activities are performed on behalf of its third party customers. In respect of those processing activities, the customer is the controller and Voyager Labs is merely a data processor, and you should consult the customer’s privacy policy for further information. This Policy applies only to processing activities that Voyager Labs performs for its own purposes, and in respect of which Voyager Labs is the data controller.

2. Categories of Personal Data

The types of Personal Data that Voyager Labs may collect and further process include:

• publicly available data, including social media information which was not labelled as private;

• contact information (e.g., your name, postal or email address, and/or phone or fax number as applicable);

• results of searches of publicly available databases;

• education details;

• employment history;

• feedback from past employers;

• cookies (as further described in section 3 below);

• your previous addresses and/or any previous names you may have used; and

• any additional information you may provide.

3. Cookies data and other device data

To the extent Voyager Labs elects to use cookies the following shall apply. A cookie is a small file that is placed on your device when you visit a website. It records information about your device, your browser and, in some cases, your preferences and browsing habits. This information can be used to improve the service delivered to you when you visit any website owned or operated by Voyager Labs (each a “Site”). In this Policy, the term “cookie” is used to refer to any means by which the Site stores data on, or reads data from, your device. The technologies used may vary and may include, for example, cookies, beacons, clear pixels, tags and other means of collecting data via your browser.

Voyager Labs may use the Google Analytics cookie to gather information about the ways in which the Site is used. The Google Analytics cookie is subject to Google’s own privacy policy. For more information on Google Analytics, visit http://www.google.com/analytics.

Cookies served through the Site will expire after 30 days.

It is not mandatory to accept cookies. You may set your browser to reject cookies. However, if you do so you may not be able to access all of the features of the Site. For more information on deleting or controlling cookies, please visit www.AboutCookies.org.

The Site does not respond to or honour “Do Not Track” requests at this time.

4. Device and browser data

When you visit the Site your device and browser will automatically disclose certain information. The disclosed information may include your device operating system, browser type and version, IP address, language settings, screen resolution, dates and times of access to the Site, and other technical data. You may use your device or browser settings to disable the collection of some or all of this data. However, if you do so you may not be able to access all of the features of the Site.

5. Collection of Personal Data

Voyager Labs may collect Personal Data by various means, including:

• collecting publicly available information, including social media information that was not labelled as private;

• receiving information that you send to Voyager Labs (e.g., email correspondence);

• receiving information from third parties (e.g., Voyager Labs’ customers); and

• receiving data in accordance with this Policy.

6. Purposes for which Personal Data are processed

Voyager Labs may process your Personal Data for the purposes of:

• verifying information about you, including for purposes of current or prospective employment;

• provision of services to Voyager Labs’ customers, including information such customers use to make risk assessments ;

• compliance with applicable law;

• audits, compliance and legal reporting functions;

• responding to requests from law enforcement bodies and other governmental agencies;

• providing customer support;

• providing advertisements and messages;

• monitoring the use of the services, offers and products made available by our third party partners or advertisers; and

• such other purposes as Voyager Labs may notify to you prior to the commencement of the relevant processing activity.

7. Principles for processing Personal Data

Voyager Labs respects your right to privacy. At a minimum, Voyager Labs will observe the following privacy principles when processing your Personal Data, in addition to the requirements of applicable law:

• Personal Data will be processed fairly and lawfully.

• Personal Data will be collected for specified and legitimate purposes, including as set out in this Policy, and will not be further processed in a way incompatible with those purposes.

• Personal Data will be adequate, relevant and not excessive, in relation to the purposes for which that data is collected and further processed.

• Personal Data will be accurate and, where necessary, kept up to date. Voyager Labs will take reasonable steps to ensure that inaccurate, incomplete or outdated Personal Data are corrected or deleted.

• Personal Data will be kept in a form which permits identification of individuals for no longer than is necessary for the purposes for which the Personal Data were collected or are to be further processed.

• Personal Data will only be collected and further processed in accordance with your rights under this Policy and/or applicable law.

• Voyager Labs will implement appropriate technical and organisational measures to protect against unauthorised access, unlawful processing, and unauthorised or accidental loss or destruction of Personal Data.

• Personal Data will only be transferred out of the country in which that data was collected in accordance with the provisions of this Policy, as further detailed in section 10 below.

8. Security and confidentiality

Voyager Labs has implemented appropriate technical and organisational measures to protect against unauthorised access, unlawful processing, and unauthorised or accidental loss or destruction of Personal Data. In particular, all electronic Personal Data held by Voyager Labs are maintained on systems that are protected by secure networks. Voyager Labs limits access to internal systems that hold Personal Data to those personnel who have a legitimate business need to access such systems.

9. Access, correction and deletion

You may request access to the Personal Data relating to you, which is stored or processed by Voyager Labs. You will be provided reasonable access to a copy of your Personal Data. In accordance with applicable law, a fee may be payable in connection with such requests. Subject to applicable law, you may also have the right to: request that Voyager Labs corrects any errors in your Personal Data; object on legitimate grounds to the processing of that Personal Data; and/or request the deletion of that Personal Data. All such requests for access may be made by sending a request in writing to the Voyager Labs entity or to:

Human Resources Department

Voyager Labs Limited,

22 Manchester Square

London

W1U 3PT

HRDepartment@voyagerlabs.co

We will endeavour to provide an initial response to such requests, or any queries or complaints relating to your Personal Data, within 10 business days, and will investigate and attempt to resolve each query or complaint within 40 days, or such other period as may be specified by applicable law.

10. International transfers and disclosures of Personal Data

To facilitate our global operations, Voyager Labs may transfer your Personal Data to other countries where we do business, but we will do so only for the purposes described in this Policy. When we transfer your Personal Data to other countries, we will comply with the requirements of applicable law regarding international data transfers, and take steps to ensure the same level of protection for that Personal Data as is set out in this Policy.

Voyager Labs may disclose your Personal Data to selected external third parties that have been engaged to perform services on behalf of Voyager Labs. To the extent that these third parties process your Personal Data, they will do so in accordance with the provisions of this Policy and in accordance with applicable law. When visiting a third party’s website, we encourage you to carefully read the privacy policies of those third parties.

Voyager Labs may also disclose your Personal Data to third parties for the following purposes:

• compliance with applicable law (e.g., disclosures to tax and social security authorities);

• to protect Voyager Labs’ legal rights (e.g., where Voyager Labs is involved in legal proceedings); and

• in the event that Voyager Labs sells its business, or any part of its business, Voyager Labs may disclose your Personal Data to the relevant purchaser(s).

11. Changes to this Policy

Voyager Labs may need to modify this Policy as needed, for example, to comply with changes in business operations or applicable laws and regulations. Voyager Labs will post all changes to this Policy.

12. Applicable law

This Policy is designed to provide a minimum standard of protection for your Personal Data worldwide. Voyager Labs recognizes that certain applicable laws may require stricter standards than those described in this Policy. Voyager Labs will process your Personal Data in accordance with all applicable laws and regulations. Where the applicable laws and regulations provide a lower level of protection of your Personal Data than that established by this Policy, then the requirements of this Policy will apply in addition to those laws and regulations.