PRIVACY POLICY

BOOK EDDY

Effective Date: 7/1/25

Prosperous I.M. Inc. and its subsidiaries and affiliates
(collectively, “us” or “we”) understand that your privacy is important to you.

We are committed to respecting your privacy and protecting
your personal data, which is any information that is capable of identifying you
as an individual person. This Privacy Policy describes how we handle and
protect your personal data in connection with Prosperous I.M. Inc. business
activities, like conferences and events, and client services, and on websites,
applications, and communications that post a link to this Privacy Policy
(collectively, “the Sites”), in our capacity as data controllers.

Please see our Terms of use for more information about our
online terms and policies in general.

Information we collect: We collect personal data in the
course of its business activities, including in connection with some client
services. We also collect personal data on certain areas of the Sites when you
register for our offerings, create a user profile, register for Prosperous I.M.
Inc. newsletters and alerts, participate in our alumni activities, sign up for
conferences and events, and/or participate in public user posting areas (such
as bulletin boards, discussion forums and surveys). The personal data collected
varies and may include information that you provide, such as your name, mailing
address, e-mail address, telephone number, fax number, credit card information,
and background information required to apply for a job.

We may also automatically collect information about the
devices you use to interact with our Sites. The information we automatically
collect may include IP address, device identifier, web browser, and browsing
information collected through cookies, web beacons, pixels, clear gifs, and
other similar technologies (collectively “Cookies and Other Tracking
Technologies”) on our Sites. We may also automatically collect information
about how you use the Sites, such as what you have searched for and viewed on the
Sites. The information automatically collected may be associated with a unique
identifier as well as with any other personal data you have provided.

Prosperous I.M. Inc may also collect personal data about you
from third parties, such as data brokers or aggregators, in the course of its
business activities including in connection with some client services. This
includes demographic, professional and other information that is publicly
available online, including information you choose to make public through
social media platforms and other public online forums. We may combine this data
with existing information we have about you or use it independently, for the
purposes of our benchmarking and data analytics activities (e.g., analysis of
recruiting practices across an industry, detecting fraud patterns in connection
with financial transactions, foot traffic in retail environments). We will
always seek to confirm that the third party has provided transparent
information about its use of this data, including its disclosure to third
parties like Prosperous I.M. Inc. in compliance with applicable law.

Use of information Prosperous I.M. Inc uses your personal
data to fulfill your requests for information, process your requests to
participate in conferences and events, personalize content that you view or
receive on the Sites, evaluate and improve our services, distribute newsletters
and alerts to you, analyze the Sites’ performance and functioning, publish your
letters to the editor or comments, prevent fraud, enforce our terms of use,
comply with all applicable laws and corporate reporting obligations, enforce
Prosperous I.M. Inc’s agreements, and accomplish other purposes you may
initiate or request.

In some situations, the collection of personal data may be
required for the operation of the Sites, or we may use it in the course of our
business activities, including in connection with some client services, for
example, to provide certain services or products such as our benchmarking
products. We may combine and/or analyze personal data to evaluate and offer
content and services most relevant to you. We may keep any of your personal
data on file and use it to contact you.

Prosperous I.M. Inc and its service providers may use first
and third party Cookies and Other Tracking Technologies, including web pixels
to manage our Sites and our services and collect analytics about how you use
them.

Prosperous I.M. Inc and its service providers may collect information about
whether you open or click any links in the knowledge, research or event
communications that we send to you. The information provided throughout this
Privacy Policy about cookies also applies to these other tracking technologies.
Please refer to our Cookie Policy for more details regarding our use of Cookies
and Other Tracking Technologies.

Our Sites do not track you by collecting personal data about
your online activities over time and across third party websites or online
services. Accordingly, we do not alter our data collection and use practices in
response to “do not track” signals transmitted from web browsers.

Use of information collected via mobile devices in
connection with our mobile applications, Prosperous I.M. Inc may use third
party service providers to analyze user activity to fix errors, monitor usage,
and improve the performance of the mobile applications. For example, Prosperous
I.M. Inc. receives reports on some of our mobile applications’ aggregate usage
and browsing patterns, including information about the type of device used,
articles accessed, and other events occurring within our apps. Prosperous I.M.
Inc. also receives reports on certain errors occurring within mobile
applications.

Prosperous I.M. Inc

The legal basis by which we process your personal data,

Our processing of your personal data for the purposes
mentioned above is based in part on our legitimate interests in promoting and
protecting Prosperous I.M. Inc, building and maintaining relationships.
recruitment, and providing our services; in part, on your consent, for example
if you create a user profile, or register for our newsletters or alerts, or for
business purposes that support web operations such as understanding and
enhancing the quality of your experience on our web-sites; in part, to comply
with the law, when certain information is necessary to satisfy our legal or
regulatory obligations.

Disclosure of personal data: data recipients and
international data transfers Personal data collected in the course of
Prosperous I.M. Inc business activities, including in connection with some
client services, as well as on the Sites may be transferred from time to time
to Prosperous I.M. Inc subsidiaries and affiliates and their personnel across
our global organization, as well as to our third party service providers
located throughout the world, including in countries where the local law may
grant you fewer rights than you have in your own country. Additionally, the
Sites may be viewed and hosted by Prosperous I.M. Inc and our third-party
service providers anywhere in the world. Where required by law, we have put in
place legal mechanisms designed to ensure adequate data protection of your
personal data that is processed by Prosperous I.M. Inc subsidiaries, affiliates
and third-party service providers, including the transfer of your personal data
to countries other than the one in which you reside. If you would like more
information about these legal mechanisms. By using any of the Sites and
providing information on any of them, you voluntarily consent to such
trans-border transfer and hosting of such information. Prosperous I.M. Inc will
not intentionally disclose or transfer (and will take reasonable steps to prevent
the unauthorized or accidental disclosure of) your personal data to third
parties without your consent or as otherwise permitted by law, whether for such
third parties’ own marketing purposes or otherwise, except as follows.
Prosperous I.M. Inc may provide access to your personal data to third party
service providers engaged by Prosperous I.M. Inc. to provide services related
to the Sites as well as related to Prosperous I.M. Inc business activities,
including in connection with some client services, in the manner agreed upon in
our client services agreements. We maintain processes designed to ensure that
any processing of personal data by third party service providers is consistent
with this Privacy Policy and protects the confidentiality, availability, and
integrity of your personal data.

We also may share your personal data with third party
service providers who perform services and functions on our behalf to support
our interactions with you, including, for example, processing recruitment
materials, administering surveys or contests, or communicating with you.

In addition, we may disclose information about you:

If we are required to do so by law or legal process; to law
enforcement authorities or other government officials; When we believe
disclosure is necessary or appropriate to prevent physical harm or financial
loss or in connection with an investigation of suspected or actual illegal activity,
if disclosure is necessary to protect the vital interests of a person.

To enforce our Terms of use; to protect our property, services and legal rights; to prevent fraud against Prosperous I.M. Inc., our subsidiaries, affiliates and/or business partners; to support auditing, compliance, and corporate governance functions; or to comply with any and all applicable laws.

In addition, we may disclose or transfer your personal data
in the event of a reorganization, merger, sale, joint venture, assignment, or
other transfer or disposition of all or any portion of our business.

User forums

You should be aware that whenever you publicly disclose
information online, that information could be collected and used by others. Prosperous
I.M. Inc. is not responsible for any action or policies of any third parties
who collect information that users publicly disclose in any such forums on the
Sites.

Link to third party sites

Prosperous I.M. Inc. may provide links to third party
websites or information as a service to our users. If you use these links, you
will leave the Sites. Such links do not constitute or imply an endorsement,
sponsorship, or recommendation by Prosperous I.M. Inc. of the third party, the third-party
website, or the information contained therein, and Prosperous I.M. Inc. shall
not be responsible or liable for your use thereof. Such use shall be subject to
the terms of use and privacy policies applicable to those sites.

Social Networking

The Sites may allow you to sign into and associate your
social network accounts including, but not limited to, Twitter, LinkedIn,
Facebook, Instagram and YouTube, with Prosperous I.M. Inc.. The Sites also may
allow you to log in to a Prosperous I.M. Inc. account using certain social
network account credentials.

By associating your social network account with Prosperous
I.M. Inc. or logging in to a Prosperous I.M. Inc. account using your social
network account credentials, you give us permission to access information that
you have made available in your public profile for that social network account.
The information available in your public profile varies based on the social
network and your settings, but may include your email address, real name,
profile picture, gender, and location. We use the information we receive from
your social network account in accordance with the social network’s terms of
use and this Privacy Policy. Please refer to the privacy settings in your
social network account for information about what data is shared with Prosperous
I.M. Inc. and other connected applications and to manage the data that is
shared through your account, including information about your activities using
our Sites.

If you would like to disconnect a social media account from
us, refer to the settings of that social network account and its provider.

Security

Prosperous I.M. Inc. has implemented generally accepted
standards of technology and operational security to protect personal data from
loss, misuse, alteration, or destruction. Only authorized Prosperous I.M. Inc.
personnel and third-party service providers are provided access to personal
data, and these employees and service providers are required to treat this
information as confidential. Despite these precautions however, Prosperous I.M.
Inc. cannot guarantee that unauthorized persons will not obtain access to your
personal data.

Data Retention

Prosperous I.M. Inc. retains personal data, as necessary,
for the duration of the relevant business relationship.

We may also retain personal data for longer than the
duration of the business relationship should we need to retain it to protect
ourselves against legal claims, use it for analysis or historical
record-keeping, or comply with our information management policies and
schedules. If you request that we delete your personal data, Prosperous I.M.
Inc. will make reasonable attempts to delete all instances of the information
in their entirety. For requests for access, corrections, or deletion, please
refer to the “Your Rights” section of this Privacy Policy.

Children

The Sites are not designed for or directed at children 16
years of age or younger, and Prosperous I.M. Inc. does not intentionally
collect or maintain personal data about anyone under this age.

Your rights

Where granted by applicable law, you may have the right to
request access to the personal data that we have collected about you for the
purposes of reviewing, modifying, or requesting deletion of the data. You may
also have the right to request a copy of the personal data that we have
collected about you and to have any inaccuracies in that data corrected. In
certain circumstances, you may also request that we cease processing your
personal data.

If you would like to make a request to access, review, or
correct the personal data we have collected about you, or to discuss how we
process your personal data, please contact us at

support@prosperousim.com. To help protect your privacy and security, we will
take reasonable steps to verify your identity, such as requiring a password and
user ID, before granting access to your personal data. We will make reasonable
attempts to promptly investigate, comply with, or otherwise respond to your
requests as may be required by applicable law. Different laws may prevent us
from providing access to your personal data or otherwise fully complying with
your request depending upon the circumstances and the request, such as for
example, where producing your information may reveal the identity of someone
else. We reserve the right to charge an appropriate fee for complying with your
request where allowed by applicable law, and/or deny your requests where they
may be manifestly unfounded, and/or excessive, or otherwise objectionable or
unwarranted under applicable law.

In addition, and where granted by local law, you have the
legal right to lodge a complaint with a competent data protection authority.

Unsubscribe

If you have registered for Prosperous I.M. Inc. newsletter
or alerts, or you receive invitations to survey or events from Prosperous I.M.
Inc. and you prefer not to receive future email communications from us, please
review the communications settings in your profile on

prosperousim.com

, or
prosperoussmallbusiness.com follow the instructions on the page of the Site
where you have provided such information, subscribed or registered or write to

support@prosperousim.com

to
unsubscribe from all Prosperous I.M. Inc. communications.

Your California privacy rights

If you are a California resident under the age of 18, and a
registered user of any of the Sites where this Privacy Policy is posted,
California Business and Professions Code Section 22581 permits you to request
and obtain removal of content or information you have publicly posted. To make
such a request, please send an email with a detailed description of the
specific content or information to

support@prosperousim.com. Please be aware that such a request does not ensure
complete or comprehensive removal of the content or information you have posted
and that there may be circumstances in which the law does not require or allow
removal even if requested.

As required by the California Consumer Privacy Act (CCPA),
this Privacy Policy describes the categories of personal data collected,
processed, and disclosed by Prosperous I.M. Inc., the categories of sources for
that data, and the business or commercial purposes for which that data is
collected, processed, and disclosed.

In addition, under California law, you may have the right
(up to two times in any 12-month period) to request more information about Prosperous
I.M. Inc.’s collection, use, disclosure, and sale of personal data about you
including:

The categories of personal data about you that we have
collected in the preceding 12 months and the categories of sources of that
information, The categories of sources from which we have collected that
information in the preceding 12 months, The commercial or business reason(s) we
have collected, used, disclosed, or sold that information, and The categories
of third parties to whom we have disclosed or sold that information in the
preceding 12 months.

In addition, upon receipt of a verifiable request from you
establishing your identity, you may have the right to know about the specific
pieces of personal data that we have collected about you and/or shared with
third parties in the preceding 12 months.

You may also have the right to request deletion of personal
data about you that we have collected or maintained, which we will honor
subject to certain limitations set forth in California law.

If you are a California consumer and you or your authorized
agent would like to exercise your privacy rights, please contact us at

support@prosperousim. When we process your request, we require you to provide
certain personal data about you in order to verify your identity in accordance
with requirements under CCPA. This may include your first and last name, email
address, physical address, telephone number, and information about your
relationship with us or other information needed to verify your identity. Prosperous
I.M. Inc. will not discriminate against you based on your exercise of any of
these rights.

Consent; changes to Privacy Policy

By using the Sites, you consent to the collection, use, and
storage of your personal data by us in the manner described in this Privacy
Policy and elsewhere on the Sites. We reserve the right to make changes to this
Privacy Policy from time to time. We will alert you to any such changes by
updating this Privacy Policy. If we make material changes to this Privacy
Policy that increase our rights to use personal data that we have previously
collected about you, we will obtain your consent either through an email to
your registered email address or by prominently posting information about the
changes on our Sites.

Please contact us at:

Prosperous I.M. Inc. Legal Department

180 E. Burgess Rd Suite D.