PRIVACY POLICY

SellingPilot — Multi-Channel E-Commerce Hub Platform

Effective Date: June 1, 2026 | Operated by: Alkers Solutions Inc. d/b/a SellingPilot

OVERVIEW

This Privacy Policy explains how Alkers Solutions Inc. d/b/a SellingPilot ("SellingPilot," "we," "us," or "our") collects, uses, discloses, and protects personal information in connection with the SellingPilot platform and related services. This Policy applies to Sellers, Team Members, and visitors who access the Platform. It does not govern the personal information of end consumers whose data Sellers collect and control independently through their sales channels.

SECTION 1 — WHO WE ARE AND HOW TO CONTACT US

SellingPilot is operated by Alkers Solutions Inc., a Delaware corporation, with its principal place of business at 21688 Gateway Center Drive, Suite 300, Diamond Bar, CA 91765. SellingPilot operates as a software-as-a-service multi-channel e-commerce hub platform that enables e-commerce Sellers to manage product listings, inventory, logistics, customer engagement, order management, and sales analytics across connected third-party sales channels.

For all privacy-related inquiries, requests, or complaints, please contact:

Privacy Contact	Data Protection / Privacy Team, SellingPilot
Email	support@sellingpilot.com
Mailing Address	21688 Gateway Center Drive, Suite 300, Diamond Bar, CA 91765 (Attn: SellingPilot Privacy)

SECTION 2 — SCOPE AND APPLICABILITY

2.1 Who This Policy Covers

This Privacy Policy applies to:

• Sellers and their authorized Team Members who create accounts on or access the SellingPilot Platform;
• Prospective customers who interact with SellingPilot's marketing website, sales team, or support channels;
• Visitors to SellingPilot's website(s) and online properties.

This Privacy Policy does not apply to end consumers who purchase products from Sellers through third-party sales channels. Sellers independently control and are responsible for the personal data of their own customers. SellingPilot's role with respect to Seller customer data is governed by the Data Processing Addendum ("DPA"), not this Policy.

2.2 Relationship to the Terms of Use and SaaS Agreement

This Privacy Policy is incorporated by reference into SellingPilot's Terms of Use and SaaS Subscription Agreement. Capitalized terms used in this Policy but not defined herein have the meanings given to them in the Terms of Use or SaaS Subscription Agreement, as applicable.

SECTION 3 — INFORMATION WE COLLECT

3.1 Information You Provide Directly

We collect personal information that you provide to us when you:

• create a SellingPilot account (name, business name, email address, phone number, billing address, payment information);
• invite Team Members to your account (names and email addresses of invitees);
• connect third-party sales channels or logistics accounts (authentication credentials processed through API or similar secure mechanisms);
• contact us for support, submit a complaint, or communicate with our team;
• complete surveys, participate in promotions, or provide feedback.

3.2 Information Collected Automatically

When you use the Platform, we automatically collect:

• Device and access data: IP address, browser type and version, operating system, device identifiers, and hardware configuration;
• Usage data: pages visited, features accessed, actions taken within the Platform, session duration, and navigation paths;
• Log data: server access logs, error logs, API call logs, and system event records;
• Cookies and similar technologies: session cookies, persistent cookies, and similar tracking technologies as described in Section 3.4.

3.3 Information Received from Third Parties

In the course of providing the Platform's channel integration services, we receive information from:

• Third-party sales channels and marketplaces (e.g., Amazon, eBay, Walmart, Shopify): order data, inventory data, product listing data, and seller account status information transmitted via channel APIs. This data is received on behalf of and at the direction of the Seller;
• Third-party logistics providers and carriers: shipment status, tracking data, and fulfillment records;
• Payment processors: transaction status and confirmation data (we do not receive full payment card data);
• Identity verification and fraud prevention services: identity verification outcomes and risk signals.

3.4 Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve the Platform. These include:

• Strictly necessary cookies: required for the Platform to function (authentication, session management, security);
• Functional cookies: remember your preferences and settings;
• Analytics cookies: help us understand how the Platform is used (e.g., Google Analytics, similar tools);
• Marketing cookies: used to deliver relevant information about SellingPilot's services (not used for third-party advertising within the Platform).

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair Platform functionality. We do not sell data collected through cookies to third-party advertisers.

3.5 Information We Do Not Collect

SellingPilot does not collect, access, or store: (a) full payment card numbers or CVV codes (payment processing is handled by PCI-compliant third-party processors); (b) government-issued identification numbers unless required for identity verification with your consent; or (c) biometric data.

SECTION 4 — HOW WE USE YOUR INFORMATION

Category	Types of Information	Purpose of Use	Legal Basis
Account Management	Name, email, business info, payment details	Create and maintain your account; authenticate users; process billing	Contract performance
Platform Services	Channel data, order data, inventory data, listing data	Provide core platform features: listings, orders, inventory, analytics, logistics	Contract performance
Customer Support	Communications, account data, usage logs	Respond to inquiries, resolve disputes, provide technical support	Contract performance; Legitimate interests
Security & Fraud Prevention	IP address, device data, login activity, API logs	Detect and prevent unauthorized access, fraud, and abuse	Legitimate interests; Legal obligation
Platform Improvement	Aggregated/anonymized usage data	Improve features, fix bugs, optimize performance; industry benchmarking	Legitimate interests
Communications	Email address, account preferences	Send service notifications, security alerts, product updates, billing notices	Contract performance; Legitimate interests
Legal Compliance	Any relevant data	Comply with legal obligations, respond to lawful requests, enforce Terms	Legal obligation
Marketing (Optional)	Email address, platform usage (with consent)	Send promotional communications about SellingPilot features or offers (opt-in only)	Consent

We do not use personal information for automated decision-making that produces significant legal effects without human review.

SECTION 5 — HOW WE SHARE YOUR INFORMATION

5.1 Service Providers (Sub-Processors)

We share personal information with carefully selected third-party service providers who assist us in operating the Platform. These providers are permitted to use your information only to perform services on our behalf and are contractually bound to protect it. Categories of service providers include:

• Cloud infrastructure providers (hosting, storage, and computing services);
• Analytics providers (platform usage analytics — data is aggregated or pseudonymized);
• Payment processors (billing and subscription management — they receive payment data directly under their own PCI-DSS compliance programs);
• Customer support and communication tools;
• Identity verification and fraud prevention services;
• Email delivery and notification services.

A current list of key sub-processors is available upon request at support@sellingpilot.com

5.2 Third-Party Channels (At Your Direction)

When you connect a third-party sales channel or marketplace to the Platform, you authorize SellingPilot to transmit data to and receive data from that Channel on your behalf. Sharing of your data with Channels occurs at your direction and is necessary to provide the integration services you requested. Each Channel's use of data shared with it is governed by that Channel's own privacy policy and seller agreements, for which SellingPilot is not responsible.

5.3 Business Transfers

If SellingPilot is involved in a merger, acquisition, restructuring, or sale of all or substantially all of its assets, personal information held by SellingPilot may be transferred to the successor entity as part of that transaction. We will notify affected users of any such transfer via email or a prominent notice on the Platform, and the successor entity will be required to honor the commitments made in this Privacy Policy.

5.4 Legal Requirements

We may disclose personal information if required to do so by applicable law, regulation, legal process, or governmental request; to enforce our Terms of Use or other agreements; to protect the rights, property, or safety of SellingPilot, our users, or the public; or to detect, prevent, or address fraud, security, or technical issues.

5.5 Aggregate and Anonymized Data

We may share aggregated, anonymized, or de-identified data — which cannot reasonably be used to identify you — with third parties for industry benchmarking, research, marketing, or analytics purposes.

5.6 No Sale of Personal Information

SellingPilot does not sell, rent, or trade personal information to third parties for their own marketing or advertising purposes. This applies to our Platform and all services operated under the SellingPilot brand.

SECTION 6 — DATA RETENTION

6.1 Retention Periods

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. The following general retention guidelines apply:

• Account and registration data: retained for the duration of the active account relationship, plus three (3) years following account closure (for dispute resolution and legal compliance purposes);
• Billing and payment records: retained for seven (7) years from the date of the transaction (tax and financial record-keeping requirements);
• Order and transaction data processed on behalf of Sellers: retained for the duration of the Subscription Term plus thirty (30) days, as set out in the Terms of Use and DPA; thereafter deleted from live systems (backup systems within ninety (90) days);
• Support and communications records: retained for three (3) years from the date of the last interaction;
• Security and audit logs: retained for twelve (12) to twenty-four (24) months, depending on the type of log;
• Marketing consent records: retained until consent is withdrawn plus five (5) years for evidence of compliance.

6.2 Deletion and Anonymization

Upon expiry of the applicable retention period, personal information is securely deleted or anonymized so that it can no longer be associated with an identified or identifiable individual. We do not delete data that is the subject of a pending legal hold, regulatory investigation, or unresolved dispute.

SECTION 7 — INTERNATIONAL DATA TRANSFERS

SellingPilot operates primarily in the United States. If you access the Platform from outside the United States, your personal information will be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction.

For users in the European Economic Area (EEA), United Kingdom, or Switzerland, we transfer personal data to the United States and other countries on the basis of:

• Standard Contractual Clauses (SCCs) approved by the European Commission and equivalent UK mechanisms, incorporated into our Data Processing Addendum;
• Adequacy decisions issued by relevant data protection authorities, where applicable;
• Other lawful transfer mechanisms recognized under GDPR and equivalent laws.

Copies of applicable transfer mechanisms are available upon request at support@sellingpilot.com

SECTION 8 — YOUR PRIVACY RIGHTS

8.1 Rights Available to All Users

Subject to applicable law, you have the following rights with respect to your personal information:

• Right of Access: request a copy of the personal information we hold about you;
• Right to Rectification: request correction of inaccurate or incomplete personal information;
• Right to Erasure ("Right to be Forgotten"): request deletion of your personal information, subject to legal retention obligations;
• Right to Restriction: request that we restrict processing of your personal information in certain circumstances;
• Right to Data Portability: receive your personal information in a structured, commonly used, machine-readable format;
• Right to Object: object to processing of your personal information based on legitimate interests;
• Right to Withdraw Consent: where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

8.2 California Privacy Rights (CCPA / CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: request disclosure of the categories and specific pieces of personal information collected about you, the sources of collection, the purposes of use, and the categories of third parties with whom personal information is shared;
• Right to Delete: request deletion of personal information, subject to certain exceptions;
• Right to Correct: request correction of inaccurate personal information;
• Right to Opt-Out of Sale/Sharing: SellingPilot does not sell or share personal information for cross-context behavioral advertising. No opt-out is required, but you may submit a request confirming this at support@sellingpilot.com;
• Right to Limit Use of Sensitive Personal Information: request that SellingPilot limit the use of sensitive personal information to necessary purposes;
• Right to Non-Discrimination: you will not be discriminated against for exercising any of your privacy rights.

To submit a CCPA request, contact us at support@sellingpilot.com or by mail at the address in Section 1. We will verify your identity before processing a request. Authorized agents may submit requests on your behalf with written authorization.

8.3 EEA / UK / Swiss Data Subject Rights

If you are located in the EEA, United Kingdom, or Switzerland, you may exercise any of the rights listed in Section 8.1 by contacting support@sellingpilot.com. You also have the right to lodge a complaint with your local supervisory authority (e.g., your national Data Protection Authority or the UK ICO). We will respond to verified requests within thirty (30) days (extendable by a further sixty (60) days for complex requests, with notice).

8.4 How to Submit a Rights Request

To exercise any privacy right, please submit a request to support@sellingpilot.com with the subject line "Privacy Rights Request" and include: (a) your name and the email address associated with your SellingPilot account; (b) the specific right(s) you wish to exercise; and (c) sufficient detail to allow us to verify your identity and locate your information. We will not process requests we cannot verify.

SECTION 9 — DATA SECURITY

SellingPilot implements and maintains commercially reasonable administrative, physical, and technical security measures to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. Our security program includes:

• Encryption of personal data in transit (TLS 1.2 or higher) and at rest (AES-256 or equivalent);
• Access controls: role-based access, least-privilege principles, and multi-factor authentication for system access;
• Regular security assessments, penetration testing, and vulnerability management;
• Incident response procedures and data breach notification protocols;
• Employee security training and awareness programs;
• Vendor security assessments for sub-processors handling personal data.

No security system is impenetrable. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and applicable regulatory authorities as required by law — within seventy-two (72) hours of becoming aware of the breach under GDPR, and as promptly as practicable under applicable U.S. state breach notification laws.

SECTION 10 — SELLER DATA RESPONSIBILITIES

Sellers who use the Platform to process personal information of their own customers (end consumers) act as independent data controllers with respect to that consumer data. SellingPilot processes such customer data only as a data processor, acting on the Seller's instructions. The following responsibilities apply to Sellers:

• Sellers must have a valid legal basis for collecting and processing their customers' personal information through and in connection with the Platform;
• Sellers must provide appropriate privacy notices to their customers that accurately describe how their personal information is collected, used, and shared — including disclosure of the use of SellingPilot as a technology platform;
• Sellers must comply with all applicable data protection laws (including GDPR, CCPA, and equivalent laws) in connection with their use of customer data accessed through the Platform;
• Sellers must respond to data subject rights requests from their own customers and may not use SellingPilot's support channels to fulfill consumer rights requests on their customers' behalf;
• Sellers must not input into the Platform any customer personal data for which they do not have lawful authority to process.

SellingPilot's obligations as a data processor for Seller customer data are set out in the Data Processing Addendum, which is incorporated into the Terms of Use and SaaS Subscription Agreement by reference.

SECTION 11 — CHILDREN'S PRIVACY

The SellingPilot Platform is intended for use by business operators and is not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from children under 18. If you believe we have inadvertently collected information from a person under 18, please contact us immediately at support@sellingpilot.com and we will take steps to delete that information.

SECTION 12 — LINKS TO THIRD-PARTY SERVICES

The Platform integrates with and may contain links to third-party services, including sales channels, logistics providers, payment processors, and other external platforms. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party service you connect to or interact with through the Platform. SellingPilot is not responsible for the privacy practices of third-party services.

SECTION 13 — CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

• update the "Effective Date" at the top of this Policy;
• notify registered Sellers via email to the address associated with their account; and
• display a prominent notice within the Platform for a period of not less than thirty (30) days following the update.

Your continued use of the Platform after the effective date of any modification constitutes your acceptance of the updated Privacy Policy. If you do not agree to the updated Policy, you must cease use of the Platform.

SECTION 14 — CONTACT AND COMPLAINTS

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us at:

Email	support@sellingpilot.com
Mailing Address	SellingPilot Privacy, 21688 Gateway Center Drive, Suite 300, Diamond Bar, CA 91765
Response Time	We endeavor to respond to all privacy inquiries within 30 days

© 2026 Alkers Solutions Inc. d/b/a SellingPilot. All Rights Reserved. This Privacy Policy was last updated on June 1, 2026.