Privacy Policy

This document serves as our Privacy Policy and it governs the privacy terms of our Software and is considered part of our Legal Terms. Any capitalized terms not defined herein have the meaning as specified in our Terms of Use. The last update to our Privacy Policy was posted on March 19, 2013.

Your Privacy

Two Roads follows all legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information. You will see terms in our Privacy Policy that are capitalized. These terms have meanings as described in the Definitions section below.

Definitions

“Non Personal Information” is information that is not personally identifiable to you and that we automatically collect when you access our Software with a web browser.

“Personally Identifiable Information” is non-public information that is personally identifiable to you and obtained in order for us to provide you within our Software. Personally Identifiable Information may include
information such as your name, email address, email account information, email content, and other related information that you provide to us or that we obtain about you.

Information We Collect

Generally, you control the amount and type of information you provide to Two Roads when using our Software.

As a Visitor, you can browse our Website to find out more about our Software. You are not required to provide us with any Personally Identifiable Information as a Visitor.

However, if decide to use our Software, you must provide Personally Identifiable Information through our Software in order to use it. As a Member, we collect your Personally Identifiable Information in the
following ways:

At Registration

If you register to receive our Software through our Website, we collect your email address.

Premium Features

While our Software is free to use for now, we may begin charging for use of premium features. If we were to charge you for the use of these premium features, we would need to collect payment source information (i.e. credit card, in-app billing to your mobile service provider, etc.) to bill you for using
such premium features.

Using the Software

You have to provide email account information to our Software in order to use it. Some jurisdictions consider this to be Personally Identifiable Information. To provide the features of the Software, your email is
transmitted in secure fashion to our servers from the Software strictly for purposes of categorization. However, we cannot view your emails nor do we retain copies of your emails for any reason. However, just like any email sent to or by you, hackers may attempt to intercept emails en route
to our servers. We cannot prevent such activity.

Computer Information Collected

When you use our Software, Two Roads automatically collects certain computer information by the interaction of your mobile phone with our Software. Such information is typically considered Non Personal Information. Two Roads also collects the following:

Cookies

Our Website uses “Cookies” to identify the areas of our Website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to personalize the
Content that you see on our Website. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our Website correctly or at all. We never
place Personally Identifiable Information in Cookies.

Web Beacons

We may also use a technology called, web beacons, to collect general information about your use of our Website and your use of special promotions or newsletters. The information we collect by Web Beacons allows us to statistically monitor the number of people that open our emails. Our Web Beacons are not used to track your activity outside of our Website or Software. We do not link Non Personal Information from Web Beacons to Personally Identifiable Information without your permission.

Automatic Information

We automatically receive information from your web browser or mobile device when you use our Website and Software. This information includes the name of the website from which you entered our Website, your
Internet or mobile service provider, web browser type, type of mobile device, and computer or mobile operating system. We use all of this information to analyze trends among our Users to help improve our
Website and Software.

How We Use Your Information

Two Roads uses the information we receive from you as follows:

Customizing Our Software and Your User Experience

Two Roads may use the Personally Identifiable information you provide to us along with any computer information we receive to customize our Software and your user experience with our Software.

Two Roads does not actually see your emails. Our Software automatically processes your emails for categorization purposes only, without any human interaction or viewing of your emails. Two Roads does not collect or otherwise retain your emails in any fashion. The interaction of our Software with our servers is strictly done to categorize your emails and therefore customize your user experience with our Software.

Communications and Email Alerts

When Two Roads communicates with you about our Software, we will use the email address you provided when registering as a Member. We may also send you service alerts regarding your use of our Software. Finally, we
may also send you emails with promotional information about Two Roads, unless you have opted out of receiving such information. You can change contact preferences at any time through your account. While you can
opt-out of promotional messages, you cannot opt-out of receiving service alerts.

Sharing Information with Affiliates and Other Third PartiesTwo Roads does not sell, rent, or otherwise provide your Personally

Identifiable Information to third parties for marketing purposes. We may provide your Personally Identifiable Information to affiliates that provide services to Two Roads with regards to our Software (i.e. payment
processors, Software hosting companies, etc.); such affiliates will only receive information necessary to provide the respective services and will be bound by confidentiality agreements limiting the use of such information.

Community Discussion Boards

Our Website may offer the capability for Members to communicate with each other through online community discussion boards. Two Roads does not filter or monitor what is posted on such discussion boards. If you chose to post on these discussion boards, you should use care when exposing any Personally Identifiable Information as such information is not protected by our Privacy Policy nor are we liable should you choose to disclose Personally Identifiable Information through such postings.

Legally Required Releases of Information

Two Roads may be legally required to disclose your Personally Identifiable Information, if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal action or claims from third parties including you and/or other Members; and/or (e) necessary to protect the legal rights, personal/real property, or personal safety of Two Roads, our Users, employees, and affiliates.

Disclosures to Successors

If Two Roads is acquired or merges, in whole or in part, with another business that would become responsible for providing the Software to you, we retain the right to transfer your Personally Identifiable Information to
the new business. The new business would retain the right to use your Personally Identifiable Information according to the terms of this Privacy Policy as well as to any changes to this Privacy Policy as instituted by the new business.

Changing Your Information

You may change your Personally Identifiable Information at any time using the Account & Settings Tab on our Software.

Protecting Your Child’s Privacy

We follow the United States’ Children’s Online Privacy Protection Act (COPPA). Our Software is not designed for use by a Child. We do not knowingly collect Personally Identifiable Information from a Child. You acknowledge that we cannot accurately verify the age of our Users nor do we have any liability to do so. If you are parent or legal guardian who suspects their Child is attempting to use our Software, please contact
us immediately to remove your Child’s information. We will ask you to provide identification to confirm that you are indeed the Child’s parent or legal guardian. If you are under the age of 18, please get your parent or
legal guardian’s permission before attempting to use our Software.

Links to Other Websites

Our Website may contain links to other websites. You agree that Two Roads has no control over such websites and that such websites are NOT subject to this Privacy Policy. These websites may have their own privacy policies and other legal documents. It is your sole responsibility to verify the privacy policies and other legal documents of such websites to see how they treat your personal information. You acknowledge that your use and access of these websites is solely at your own risk.

Our Email Policy

Two Roads and our affiliates fully comply with national laws regarding SPAM. You can always opt out of receipt of further email correspondence from Two Roads and/or our affiliates. We agree that we will not sell, rent,
or trade your email address to any unaffiliated third-party without your permission.

Our Security Policy

Two Roads has constructed our Software using industry standard encryption and authentication tools to protect your Personally Identifiable Information. When we collect your Personally Identifiable Information through our Software, we encrypt this information and attempt to prevent unauthorized access to it by using industry standard technologies, such as encryption software, routers and firewalls. Unfortunately, due to
the nature of the Internet, we cannot completely guarantee that your Personally Identifiable Information is completely protected.

Payment Sources

You may be required to provide a payment source (i.e. credit card, in- app billing to your mobile service provider, etc.) when you register as a Member. You acknowledge that we don’t store your payment source information directly on our servers and use industry standard application billing procedures which use third parties to process your payment source. You understand and agree that we do not control these third
parties nor can we be liable for their actions. If you see what you believe to be fraudulent transactions regarding our Software, please contact us immediately. We will make reasonable efforts to work with you and
relevant authorities to help resolve such issues.

Privacy Policy Updates

Two Roads reserves the right to modify this Privacy Policy at any time. You should review this Privacy Policy frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page. We will also change the “Last Updated” date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies.

Questions About Our Privacy Practices or This Privacy Policy

If you have any questions about our Privacy Practices or this Policy, please contact us.