Privacy Policy

The purpose of this Privacy Policy is to explain how Symmetric Technologies, Inc. doing business as Main Street Sites (“MSS”, “we”, “us”, or “our”), collects and uses information pertaining to each of our unregistered visitors and registered users (each, a “Visitor” or “Subscriber” (respectively and as further defined below), or “you”), in connection with their access to and use of MSS’s websites (including www.mainstreetsites.com and any of its subdomains, the “Website”), Website Hosting and Back Office services (“Software Services”), payment processing and gateway services (“Payment Services”) and related services (collectively, the “Service” or “Services”).

Before using our Website or Software Services, read this Privacy Policy thoroughly. Make sure you understand our practices and policies with respect to your personal information. If you disagree with our practices and policies, you must immediately discontinue use of our Services and leave this Website.

If you have any questions or concerns regarding this Privacy Policy or our practices, please see the “Contact Us” section below.

Definitions

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other
information either in our possession or likely to come into our possession), such as name, postal address, telephone number, email address, credit card number, and social media account ID. It does not include strings of code such as browser cookie IDs.

Non-Personal Data

Non-Personal Data means un-identified and non-identifiable information pertaining to an individual, which may be made
available to us, or collected automatically via his/her use of the Services. Such Non-Personal Data does not enable us to identify the individual from whom it was collected. The Non-Personal Data collected by us mainly consists of
technical and aggregated usage information, such an individual’s browsing and ‘click-stream’ activity on the Services
as well as non-identifying information regarding the individual’s device, operating system, internet browser, screen
resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.

Subscriber

Subscriber means a natural or legal person who has registered for an account with us in order to use our Software
Services or Payment Services. With respect to Software Services, Subscribers include those who have a paid account or
a free trial account.

Visitor

Visitor means a natural or legal person who visits the Website.

End User

End User means a visitor, user, prospect or customer who interacts with a Subscriber via one of our Software
Services.

Data Controller

Data Controller means the natural or legal person who determines the purposes for which and the manner in which any
personal information is processed.

Data Processor

Data Processor means any natural or legal person who processes personal data on behalf of the Data Controller.

Our Data Processing Roles

Main Street Sites acts in different data processing roles depending on the specific activity:

  • As Data Controller: For Subscriber account information, billing data, security monitoring, and service analytics
  • As Data Processor: For End User data processed through our Services on behalf of Subscribers
  • Mixed Role: For certain technical operations where we process data for both service delivery (processor) and platform security (controller)

Information We Collect

Visitor and Subscriber Information

We collect or obtain Non-Personal Data and Personal Data. Personal Data we collect or obtain includes:

  • Contact details (e.g., name, address, email, telephone number),
  • Billing data (e.g., name, physical billing address, payment method and transaction details, etc.). Payment card data is handled directly by our payment processors; MSS does not store full credit or debit card numbers.
  • Browsing and usage data which, in some jurisdictions, is considered to be Personal Data.
  • Information voluntarily submitted to us by a Subscriber in connection with Software Services or Payment Services,
  • Scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents),
  • Any other Personal Data provided to us by Visitors and/or Subscribers through their access to and/or use of the Services.

End User Information

We may also collect similar information pertaining to End Users, solely for and on our Subscriber’s behalf as
described in the “End User Information” section below.

How We Collect Information

  1. Personal Data provided by you. We collect information which you provide us voluntarily. For
    example, we collect the Personal Data you provide us when you register to our Services; when you submit, upload or
    otherwise voluntarily provide Personal Data in connection with any of our Services; and/or when you contact us
    directly by any communication channel (e.g., email, phone, text messages).
  2. Automatically Collected User Information. When you access and use our Service, we and/or third
    party Service Providers may automatically collect and store, in log files or other electronic formats, your
    Internet Protocol (IP) address, browser type, referring/exit pages, operating system, date/time stamp and other
    information. If you are a resident of the European Union, information such as an IP address is considered to be
    Personal Data.

Data Processing Activities and Legal Bases

When We Act as Data Controller

  • Account management and billing (Legal basis: Contract performance)
  • Service analytics and improvements (Legal basis: Legitimate interest with opt-out)
  • Security monitoring and fraud prevention (Legal basis: Legitimate interest)
  • Marketing communications (Legal basis: Consent with easy withdrawal)
  • Legal compliance activities (Legal basis: Legal obligation)

When We Act as Data Processor

  • Processing End User data according to Subscriber instructions
  • Storing and transmitting content through our platform
  • Providing technical services as configured by Subscribers
  • Generating reports and analytics as requested by Subscribers

Use of your Information

  • To provide, operate and maintain our Service
  • To further develop, customize and improve our Services based on the experiences of Visitors and Subscribers.
  • To notify Subscribers about changes to our Service
  • To provide customer assistance and technical support to our Subscribers
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To enhance our data security and fraud prevention capabilities
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
  • To comply with applicable laws and regulations

We may access Subscriber Accounts and Content only as reasonably necessary for customer support, system maintenance,
security monitoring, legal compliance, or enforcement of our Terms of Service.
This may include limited access to message content when necessary to deliver the Service (for example, to troubleshoot technical issues, respond to support requests, detect spam or abuse, or comply with legal obligations). We do not otherwise routinely review message content.

We will only use your Personal Data for the purposes set out above where we are satisfied that:

  • you have given us permission to do so, or
  • our use of your Personal Data is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide Software Services to you, to provide you with our customer assistance and technical support, etc.), or
  • our use of your Personal Data is necessary to comply with a relevant legal or regulatory obligation that we have, or
  • our use of your Personal Data is necessary to support legitimate interests, provided that such use is not overridden by your privacy rights.

End User Information

Our Role as Data Processor for End User Data

Main Street Sites processes End User personal data solely as a Data Processor on behalf of our Subscribers. Our
Subscribers act as the Data Controller for all End User relationships and data processing decisions.

Our Processing Activities by Data Type

Data TypeOur RoleControllerPurpose
End User content and communicationsProcessorSubscriberService delivery per Subscriber instructions
End User contact/profile dataProcessorSubscriberPlatform functionality per Subscriber configuration
End User system/access logsProcessorSubscriberTechnical service delivery
Security threat dataControllerMain Street SitesPlatform security (limited to threat mitigation)

Subscriber Responsibilities

  • Obtain all required End User consents for data processing
  • Provide End Users with appropriate privacy notices
  • Handle all End User rights requests
  • Ensure End User data processing complies with applicable laws
  • Maintain their own privacy policies covering End User relationships

End User Rights

If you are an End User of one of our Subscribers, you must direct all privacy rights requests to the Subscriber (your
Data Controller). We cannot respond to direct End User requests without Subscriber authorization. We will assist
Subscribers in fulfilling valid End User requests within our technical capabilities.

Limited Controller Activities

We act as Data Controller for End User data only when necessary for:

  • Platform security measures that protect all users
  • Compliance with direct legal obligations where Main Street Sites is specifically named
  • Prevention of fraud or abuse that threatens platform integrity

If requested to remove any End Users’ Personal Data, we will comply with such requests as required by applicable law.
Unless otherwise instructed by our Subscriber, we will retain End User Personal Data for the period set forth in the
“Data Retention” section below.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of
your state, province, country or other governmental jurisdiction where the data protection laws may differ from those
from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the
data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

International Data Transfers

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, your personal data may be
transferred to and processed in the United States or other countries where the data protection laws may differ from
those of your home jurisdiction. In such cases, we take steps reasonably necessary to ensure that your data receives
an appropriate level of protection consistent with applicable legal requirements.

MSS will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this
Privacy Policy and that no transfer of your Personal Data will take place to an organization or a country unless
there are adequate controls in place including the security of your data and other personal information.

How Personal Data May Be Disclosed

We may disclose your Personal Data:

  • To our strategic partners and third-party service providers who provide services such as website hosting, content
    delivery services (CDN), domain registration, data analytics, payment processing services, customer service and
    technical support, email delivery, text message delivery, credit card processing, auditing and other similar
    services (collectively, “Third Party Service(s)”).
  • To our Subscribers, if you are an End User and are using Services to interact with that Subscriber. Please contact
    the Subscriber you interact with directly for more information on that Subscriber’s privacy practices.
  • To business partners in the context of a corporate transaction. Symmetric Technologies, Inc. will retain a
    legitimate interest in disclosing or transferring Personal Data to a third party in the event of any reorganization,
    merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business,
    assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include,
    for example, an acquiring or target entity and its advisors.
  • To comply with a legal obligation
  • To protect and defend our rights or property
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Please note that we may use and disclose Non-Personal Data for any purpose, except where not allowed under applicable
law. If we are required to treat Non-Personal Data as Personal Data under applicable law, then we may use it for all
the purposes for which we use and disclose Personal Data. In some instances, we may combine Non-Personal Data with
Personal Data. If we combine any Non-Personal Data with Personal Data, we will treat the combined information as
Personal Data.

Cookies and Other Tracking Technologies

MSS, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies
(such as cookies, beacons, pixels, tags and scripts).

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your
browser from a website and stored on your device. You can instruct your browser to refuse all cookies or to indicate
when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our
Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Cookies and other tracking technologies are used in order to maintain, provide and improve our Services on an ongoing
basis, and in order to provide a better experience to Visitors, Subscribers and End Users.

Please note that Third Party Services placing cookies or utilizing other tracking technologies through our Services
may have their own policies regarding how they collect and store information. Such practices are not covered by our
Privacy Policy and we do not have any control over them.

Security

We take reasonable steps to put in place appropriate physical, electronic, and procedural safeguards to protect the
integrity and security of Visitor, Subscriber and End User Personal Data and to prevent unauthorized or unlawful
processing of, or the accidental loss, destruction, or damage to such data. However, data transmissions over the
Internet and methods of electronic storage are not 100% secure. Consequently, we cannot guarantee or warrant the
security of any Personal Data transmitted to us. Visitors and Subscribers who transmit Personal Data to us do so at
their own risk.

Data Retention

We will retain Personal Data of Visitors, Subscribers and End Users for as long as permitted in light of the
purpose(s) for which it was obtained and consistent with applicable law, or as otherwise needed to provide Services
to our Subscribers.

We may continue to retain such Personal Data even after a Subscriber ceases to use any particular Services, as
reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Subscribers and/or their
End Users, to prevent fraud and abuse, to enforce our agreements and/or to protect our legitimate interests, or to
facilitate account reactivation.

Your Privacy Rights

MSS as Data Controller

Upon request, we will provide you with information about whether we hold or process your Personal Data. Subscribers
can access and edit their account information with MSS at any time by logging into their Software Services account.
You can also contact us at [email protected], and we will respond within the timeframes required by applicable law.

MSS as Data Processor

MSS acknowledges that End Users have the right to access and change the Personal Data we collect and process as a
Data Processor. An End User who seeks to access or to correct, amend, or delete Personal Data should direct their
request to the MSS Subscriber who is the Data Controller, and not to MSS directly. If the Data Controller requests
MSS remove Personal Data we will respond within a reasonable timeframe.

End User Rights Requests

If you are an End User seeking to exercise privacy rights regarding data processed through our platform:

  • Contact the Subscriber (business) you interacted with directly
  • They are the Data Controller responsible for your privacy rights
  • We can only act on End User data upon instruction from the controlling Subscriber
  • For platform security issues, you may contact us directly at [email protected]

Visitors and Subscribers from the European Economic Area

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. MSS aims to take
reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems,
please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you. Whenever made possible, you can access,
    update or request deletion of your Personal Data directly within your Software Services account. If you are unable
    to perform these actions yourself, please contact us to assist you.
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Data.
  • The right of restriction. You have the right to request that we restrict the processing of your Personal Data.
  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where MSS relied on your consent to process your Personal Data.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For
more information, please contact your local data protection authority in the European Economic Area (EEA).

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our
administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of
the same information. Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this
will be within one month from when we receive your request but, if the request is going to take longer to deal with,
we’ll come back to you and let you know.

Use by Minors

Our Service is not intended for or directed to anyone under the age of 18. We do not knowingly collect Personal Data
from anyone under the age of 18. If you learn that your child has provided us with Personal Data without your
consent, you may alert us at [email protected]. If we
learn that we have collected any Personal Data from children under 18 without verification of parental consent, we
will take steps to delete such information.

Changes

We may update this Privacy Policy from time to time. We will post any adjustments to the Privacy Policy on this web
page, and the revised version will be effective when it is posted. Your continued use of the Services after any changes means you accept the revised Privacy Policy. If you do not agree to any changes, you must stop using the Services.
It is your obligation to ensure that you read, understand and agree to the latest version of the Privacy Policy. The “Effective
Date” date at the bottom of the Privacy Policy indicates the effective date of the current policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email:
[email protected]

 

Effective Date: September 3, 2025