WORLDLY HOLDINGS INC.

GLOBAL PRIVACY POLICY

Last Updated: May 15, 2023

This Privacy Policy describes how Worldly Holdings Inc. (formerly Higg Inc.) and our subsidiaries and affiliated companies, (collectively, “Worldly,” “we,” or “us”), collect, use, and disclose information about you. Prior to May 15, 2023, Worldly was known as Higg Inc. (“Higg”). This policy replaces and supersedes the privacy policy previously posted by Higg on its websites.

Worldly primarily collects information and data about businesses, such as their environmental management systems or their energy usage. Worldly collects enterprise data, and generally does not collect, process, or use consumer personal data or information.

This Privacy Policy applies to information we collect when you access or use our websites: https://worldly.io/; https://app.worldly.io;  https://learn.worldly.io; https://suppport.worldly.io;  https://worldly.invoicing.co/; and https://howtohigg.org  (collectively, the “Website”), our Platform, available at https//portal.worldly.io  (the “Platform”), your account on our Platform  (“Account”), any web-based tools, services, and data made available to you by Worldly on the Website, Platform, and other online products and services that link to this Privacy Policy, or when you otherwise interact with us, such as through our customer support channels or on social media pages (collectively, our “Services”).

We may change this Privacy Policy from time to time. If we make changes, we will revise the date at the top of this policy. We may also provide you with additional notice (such as by adding a statement to the Services or sending you a notification), such as in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

The California Consumer Privacy Act, as amended by the California Privacy Rights Act, does not presently apply to Worldly.

CONTENTS

• Collection of Information
• Use of Information
• Sharing of Information
• Transfer of Information to the United States and Other Countries
• Your Choices
• Additional Disclosures for Individuals in Europe
• Contact Us

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you register for an Account, store information in your Account, fill out a form, contribute to an assessment, submit or post content through our Services, apply for a job with us, participate in a survey, request customer support, or otherwise communicate with us. The types of information about you that we collect include your name, postal and email addresses, job title and function, phone number, resume information, Account username and password, and any other information you choose to provide.

For purposes of China’s Data Security Law, we also may collect information about business or employer sustainability practices, including resource usage, labor practices, pollution output, and more.

Information We Collect Automatically

We automatically collect certain information about your interactions with us or our Services, including:

• Activity Information: We collect information about your activity on our Services, such as your subscription value and subscription renewal dates.
• Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, and browser type. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
• Information Collected by Cookies and Similar Tracking Technologies: We (and those who perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy and the Your Choices section below.

Information We Collect from Other Sources

We obtain information from other sources in addition to the information you provide when you set up your Account. For example, we may collect information from job postings, third-party researchers, and marketing tools. This information may include, for example, your name, email address, physical address, company name, company description, website, job title, phone number, address, revenue information, interactions with our marketing campaigns, such as click-throughs, customer support agents, and customer relationship managers, such as chats, or information contained in your resume, in a LinkedIn account or profile, or submitted to a third-party researcher or customer relationship manager.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are interested in certain products based on your browsing behavior.

USE OF INFORMATION

We use the information we collect to provide, maintain, and improve the Services and the other interactions we have with you.  We also use the information we collect to:

• Provide, maintain, improve, and develop new products and services, including to debug and repair errors in our Services.
• Personalize your experience with us.
• Send you technical notices, security alerts, support messages and other transactional or relationship messages.
• Communicate with you about products, services, and events offered by Worldly and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time).
• Provide and administer surveys.
• Monitor and analyze trends, usage, and activities in connection with our Services.
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards.
• Build multi-touch attribution for customers who go through marketing, sales, and customer portals or infrastructure.
• Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of Worldly and others through use of internal applications and software. Certain of the tools used for this purpose utilize behavioral tracking and automated decision-making.
• Comply with our legal, regulatory and financial obligations.
• Create de-identified, anonymized, or aggregated information for limited internal purposes, provided the personal information is not disclosed to another third party.
• Conduct research and development activities.
• Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

• We share personal information with vendors and service providers that access personal information to perform work for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, human resources, employment applications, and marketing and advertising.
• We share personal information with third party social media platforms, like YouTube or LinkedIn.
• If you share content or information on our Services or through the Portal, we may share that information with other users of our Services.
• If you choose to use integrations we offer on our Services, we may share certain information with the integration partners.
• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Worldly, our users, the public, or others.
• We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Personal information is shared between and among Worldly and our current and future parents, affiliates, partners, and subsidiaries and other companies under common control and ownership. For example, we share personal information with the Sustainable Apparel Coalition (SAC), the Apparel Impact Institute (AII), Reset Carbon, and the Social & Labor Convergence Program (SLCP). For information on how those organizations or entities collect, process, use, or share personal information, please visit their websites directly.
• We share personal information with your consent or at your direction.
• We also share aggregated or de-identified information that cannot reasonably be used to identify you.

HOW WE RESPOND TO DO NOT TRACK SIGNALS

We respond to Do Not Track requests for certain geolocations.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Worldly is headquartered in the United States, and we offer services and engage vendors in the United States and across the world, including in China, India, Switzerland, the United Kingdom, the European Economic Area, and many more locations. Therefore, we and those that perform work for us may transfer your personal information to, or store, process, or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction.

Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, or executing the European Commission’s Standard Contractual Clauses or the United Kingdom’s International Data Transfer Addendum. Where relevant, you may request a copy of these Standard Contractual Clauses or Addenda by contacting us using the contact information below.

YOUR CHOICES

Account Information

You may update and correct certain Account information at any time by logging into your Account or emailing us at support@worldly.io. If you close your Account and wish to delete your Account information, please contact us at support@worldly.io. For more information concerning Account information and deletion, please see the Data Retention section below.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. For more information about cookies and how to disable them, see our Cookie Policy.

Communications Preferences

You may opt out of receiving promotional emails from Worldly by following the instructions in those communications or by emailing us at privacy@worldly.io. If you opt out, we may still send you non-promotional emails, such as those about your Account or our ongoing business relationship.

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on one or more of the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and Services you requested).
• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and Services, conduct data analytics, and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consents).
• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Retention

We retain personal data associated with your Account. If you close or have closed your Account, you may request that we delete your personal data by contacting us at privacy@worldly.io. Please note that we may retain certain information associated with your Account as required by law or for legitimate business purposes.

Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us at privacy@worldly.io.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

CONTACT US

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

Email: privacy@worldly.io

Physical Address:  2041 East St PMB 833, Concord, CA 94520 | Attention: Privacy

For more information about the privacy practices and policies of our licensor, the Sustainable Apparel Coalition, please see its Privacy Policy.