Thanks is a product of O.C. Tanner Company (www.thanks.com, www.myperks.in or www.kwench.com) a company incorporated in the State of Utah United States of America and its related bodies corporate located world-wide (together, 'O.C. Tanner') (“Web site/Platforms/Bots/Services/Applications") aim to protect your personal information and ensure that you continue to trust us with your personal data. This notice applies to the personal data that we collect for the purposes of providing you our valuable services and an enhanced user experience on our Platforms ("Notice").

This Notice is applicable to you if an account on our Platform was created on your behalf by your employer and if you share your personal information through your employer or directly with O.C. Tanner. Further, this notice is applicable to you in accordance with applicable local and international laws and regulations.

O.C. Tanner reserves the right to make changes to this Notice at any time, which shall be duly informed to you via notification on the Platforms. We encourage you to regularly review this Notice to ensure that you are aware of changes made to it from time to time.

WHAT DATA WE COLLECT

O.C. Tanner receives from your employer your personal data, including, inter alia, name, age, gender, date of birth, email, delivery address, telephone number, login user names, passwords, and your "Official Data", including, inter alia, department, designation, location, country, reporting manager, business unit, business/location human resource contact, date of joining, grade or level, cost center code, legal entity name, details of employer (collectively, "Personal Data" ) from the following sources for the purpose of providing you our valuable services and an enhanced user experience on our Platforms:

• (a) Documents and information voluntarily submitted by you to your employer or O.C. Tanner;
• (b) Your interactions with us through website, mobile applications or text messaging programs;
• (c) Our communications with your employer.

Further, O.C. Tanner may use certain technical information that does not permit the identification of an individual and which may be collected during your access or use of the Web sites, such as, log data, analytics code, IP address, version and identification number of the device, browser type, browser language, date and time of your requests, your profile, web sites/ links visited by you, search terms used (collectively, "Anonymous Data").

HOW WE STORE YOUR PERSONAL DATA

Your Personal Data shall be securely stored on servers hosted by reputed Internet Service Provider ("ISP") or Cloud Service Provider ("CSP") meeting the prescribed industry security standards. Such ISP or CSP shall be responsible to keep your Personal Data secure at all times and adopt such technical measures as may be required to meet your reasonable expectation of privacy. Currently, the Thanks data center is hosted with IBM Cloud, in Singapore Region.

WHY WE COLLECT AND PROCESS YOUR PERSONAL DATA

O.C. Tanner as a data processor collects and uses your Personal Data in accordance with the Work Statement of the Agreement, to help your employer engage its employees through various initiatives at work such as learning, recognition and rewards, wellness, collaboration, communication, social causes and such other initiatives that support/further the mission, goals, values and initiatives of your organization and provide other related services. For the above purpose only, O.C. Tanner may use your Personal Data:

• (a) to notify you regarding activities on the Platforms, updates related to various programs or initiatives that your employer may consider beneficial to its employees and matters incidental thereto.
• (b) to notify you about functionality and changes on our Web sites, new services and special offers that you may find of value.
• (c) to create and maintain your accounts with O.C. Tanner, including your transaction details on the Platforms that are associated with your account.

WHETHER WE MAKE MARKETING COMMUNICATIONS

Except as otherwise consented by you, O.C. Tanner does not sell or otherwise release your Personal Data to third parties to allow them to direct market their products and services to you, identify who you are or remember where you’ve been on the internet. However, O.C. Tanner may use your Personal Data and/or Anonymous Data to provide you with relevant marketing communications such as information about O.C. Tanner, its products and services, competitions and promotions based on your activities on our Platforms. In case you do not wish to receive such marketing information, please email us at help@thanks.com

WHEN WE CAN DISCLOSE/ SHARE YOUR PERSONAL DATA

O.C. Tanner shall not disclose your Personal Data to any third party for any reason whatsoever, without your express consent to that effect. However, your Personal Data may be disclosed to or shared with a third party without your consent under the following circumstances:

• - pursuant to a valid and subsisting order of a court or other judicial, quasi-judicial or government body under applicable laws or if, in O.C. Tanner’s good faith judgment, such legal disclosure is reasonably necessary to comply with legal processes or respond to any claims;

Further, O.C. Tanner may share your Personal Data with its trusted affiliates or related companies for the limited purposes of providing services on the Platforms, processing of your Personal Data, on need to know basis and subject to confidentiality obligations as may be contractually agreed to between such third party and O.C. Tanner.

HOW WE USE AND PROCESS YOUR PERSONAL DATA

O.C. Tanner takes all reasonable steps to ensure fair, lawful and transparent processing of your Personal Data. In furtherance of this objective, O.C. Tanner as a data processor will:

• (a) process your Personal Data (i) on the written instructions from your employer and (ii) for the limited purposes of provision of services;
• (b) process your data by itself or another sub processor with reasonable prior notification to your employer.
• (c) notify you and obtain your consent in case of usage of your Personal Data for any purpose other than the purposes consented for or stated in this Notice;
• (d) retain Personal Data only as long as it is necessary for rendering the services on the Platforms except when otherwise required under applicable laws;
• (e) meet legal requirements and your reasonable expectations of data privacy while processing your Personal Data;
• (f) use reasonable efforts and security measures (not below prevailing industry standards or standards prescribed by applicable law), including, a variety of security technologies and procedures to protect your Personal Data from any unauthorized access, use or disclosure;
• (g) ensure that written records of the data processing activities carried out on behalf of O.C. Tanner are maintained;
• (h) provide you all information related to processing of your Personal Data through your employer, for instance whether or not your Personal Data is being processed, where it is processed and for what purpose it is processed, upon receipt of a written request from you.

WHAT RIGHTS YOU CAN EXERCISE

• • Right of Access: You can access your Personal Data at all times during the subsistence of your account with O.C. Tanner. You are free to review and modify your Personal Data and correct inaccuracies, if any, in your Personal Data, from time to time, after you login to the Web sites. In case you are unable to access, correct, or update any of your Personal Data, you may send a request to your employer or to us at help@thanks.com. You can also request us/your employer to provide your Personal Data collected by us in a structured and commonly used format. Upon receipt of such request from your employer/approval from your employer, O.C. Tanner will provide your Personal Data request free of charge within one month from the date of such request, unless such request is manifestly unfounded or excessive. However, O.C. Tanner shall not be liable to retain or provide access to your Personal Data after three (3) months from the date of deactivation of your account with O.C. Tanner.
• • Right to withdraw consent: In the event you wish to withdraw your consent for usage of your Personal Data for any particular activity of O.C. Tanner and its affiliates at any time during the subsistence of your account with us, you can notify us/your employer in writing. Upon receipt of such instruction from your employer, O.C. Tanner shall not use or allow further dissemination of your Personal Data or part thereof, for the purpose mentioned therein
• • Right of Erasure: If you wish to remove all or any part of your Personal Data collected by O.C. Tanner, its affiliates or any of the related parties, you can raise a request by sending an email to help@thanks.com or to your employer. Your Personal Data will be erased by O.C. Tanner: (a) upon receipt of such request for erasure from you and subsequent approval of your employer for your request of erasure; (b) deactivation of your account with O.C. Tanner.

THIRD PARTY LINKS/ EXTERNAL LINKS

Our Web sites may contain links to content or other functionality provided by third parties which are outside our control and are not covered by this Notice. Accordingly, O.C. Tanner shall not be liable for any breach of your Personal Data which is attributable to the acts or omissions of such third parties.

BREACH NOTIFICATION

O.C. Tanner shall intimate any instances of data breach to your employer without any undue delay and, where feasible, within 48 hours or such lesser period as may prescribed by applicable law of becoming aware of such breach, failing which O.C. Tanner shall provide reasoned justification for the delay. Further, O.C. Tanner shall take all reasonable steps to curve such instances and take all corrective measure to minimize the impact of such data breach.

INTERNATIONAL TRANSFER OF DATA

In the process of providing access to the Web sites and processing your Personal Data, O.C. Tanner may transfer your Personal Data to affiliated entities or other third parties across countries or jurisdictions in the following circumstances: (a) where the transfer is necessary for the conclusion or performance of a contract concluded in your interest between your employer and O.C. Tanner; (b) where the transfer is occasional and necessary in relation to a contract or a legal claim, judicial or administrative procedure; (c) where such transfer is on the legitimate ground of public interest under applicable laws; or (d) in compliance with adequacy decisions, appropriate safeguards or other mechanisms provided under the applicable data protection regulations.

COMMUNICATION & GRIEVANCES

We will make all attempts to contact you only through email and ensure that your telephone number is used only for the limited purposes of providing the relevant services on the Platforms. In case you have any grievances regarding usages of your Personal Data, you can contact our Grievance Officer at help@thanks.com. Upon receipt of such complaint, O.C. Tanner will make all the reasonable efforts to address your concerns at the earliest.

CONSENT

By logging into the Website, you hereby acknowledge and confirm that:

• (a) you have read, reviewed and understood all the terms of this Notice and its implications and voluntarily agreed to provide your explicit consent for access and usages of your Personal Data for the purpose specified under this Notice;
• (b) you have been apprised of your right to withdraw your consent at all times during the subsistence of your account with O.C. Tanner without detriment.

EUROPEAN PRIVACY CONSIDERATION IN RESPECT TO EU DATA SUBJECTS

O.C. Tanner will process your data in accordance with EU-GDPR for the lawful purposes and for the purpose of the work statement of the Agreement with your employer.

HOW YOU CAN REACH US

Any queries or questions regarding the privacy notice and data protection may be submitted to us at help@thanks.com or to the O.C. Tanner Headquarters as follows:

O.C. Tanner Company
Attention: Data Privacy Officer
1930 South State Street
Salt Lake City, Utah 84115
Email: privacy@octanner.com
Phone: (1) (888) 708-7080

O.C. Tanner Company
1930 South State Street
Salt Lake City, Utah 84115 USA
Email: legal@octanner.com
Phone: (1) (888) 708-7080