Machine Learning Systems Inc., a subsidiary of Commercial Fund Inc., (“TheDrugClub.com”) is committed to protecting the privacy of your information. This Privacy Statement describes our information practices for our publicly-accessible websites, including our use of cookies to collect data about your use of our websites. For information about our privacy policies governing your use of TheDrugClub.com’s account portal and associated platform services (“Services”), please consult our separate TheDrugClub.com Services Privacy Policy.

Machine Learning Systems Inc (“TheDrugClub.com”) takes your privacy very seriously and has created this Privacy Policy in order to disclose its use of consumer data collected about you. You may contact TheDrugClub.com at 3921 Alton Rd. Suite 143, Miami Beach, FL 33140.

By using the TheDrugClub.com website, or submitting information to us by other means, you are subjecting your information to the practices outlined in this Privacy Policy. This Privacy Policy covers TheDrugClub.com’s treatment of personal information that we collect when you are on TheDrugClub.com’s website and when you use TheDrugClub.com’s services. This policy does not apply to the practices of third parties that TheDrugClub.com does not own or control, including websites that we may link to, or to individuals that TheDrugClub.com does not employ or manage.

PRIVACY POLICY UPDATES

Due to the Internet’s rapidly evolving nature, TheDrugClub.com may need to update this Privacy Policy from time to time. If so, TheDrugClub.com will post its updated Privacy Policy on our website located at www.TheDrugClub.com — TheDrugClub.com encourages you to review this Privacy Policy regularly for any changes. Your continued use of this site and/or continued provision of personally identifiable information to TheDrugClub.com will be subject to the then current Privacy Policy.

INFORMATION COLLECTION

TheDrugClub.com may collect or receive information about you when you register or submit information, including, but not limited to, username, password, first and last name, phone number, cellular carrier, device type, email address, street address, gender, occupation, interests, resume and contents thereof, job search history, and any other data included in a submitted profile, resume, or search. TheDrugClub.com also collects information on the pages you access and other information you may volunteer, such as survey information, ratings, reviews, questions, and answers. TheDrugClub.com may also record actions taken on our site including, but not limited to, clicks, page views, IP address, and search queries. TheDrugClub.com may store this information in its equipment or the equipment of third party technology providers.

USE OF INFORMATION

• TheDrugClub.com, or companies we partner with, may contact you based on your interests. TheDrugClub.com site may require you to provide TheDrugClub.com with contact information (such as your name, phone number and email address) and demographic information. TheDrugClub.com may use your contact information to (a) send you offer alerts; (b) create an account; or (c) send you information about TheDrugClub.com and promotional material from some of TheDrugClub.com’s partners. Your contact information is also used to contact you when necessary. TheDrugClub.com may use demographic and/or profile data, including but not limited to search history, to tailor your experience on TheDrugClub.com’s site, show you content that TheDrugClub.com thinks you may be interested in, and display content according to your preferences.
• To the extent you upload data, TheDrugClub.com may make the dataset and other personal information contained therein available to third parties, including but not limited to employers and search engines. This means that the personal information contained in your data can be viewed by third parties and you may receive unsolicited contact from third parties unaffiliated with TheDrugClub.com. TheDrugClub.com will make reasonable effort to safeguard the use of your personal information by third parties in accordance with this Privacy Policy. TheDrugClub.com reserves the right to disclose any information as required by law. We may use other companies as necessary to perform services necessary to our operations. In the course of providing these services, those companies may have access to your personal information in accordance with this Privacy Policy. Every effort will be made to safeguard your privacy when it may be accessed by other companies, including but not limited to technology providers; however, TheDrugClub.com will not be liable for any damages that may result from the misuse of your personal information by these companies.TheDrugClub.com may use your IP address to administer our site. Your IP address may also be used to help identify you, your location, and to gather broad demographic information. Nothing shall restrict TheDrugClub.com from maintaining your data following your termination of your use of TheDrugClub.com’s site. TheDrugClub.com may delete your user data at TheDrugClub.com’s sole discretion.

WEBSITES COVERED

In this Privacy Statement, “we,” “us,” “our,” or “TheDrugClub.com” refers to Machine Learning Systems Inc. and our affiliates, which includes any person or entity that controls TheDrugClub.com, is controlled by TheDrugClub.com, or is under common control with TheDrugClub.com (such as a subsidiary, parent company, or employee). Other sites include TPRsms.com; motorcyclefinancial.com; banklocale.com.

PARTNERS

 TheDrugClub.com is an online community and not a medical service. We have partnered with industry leading fulfillment partners to find our members with the very best services available. Those partners include:

— Prescription Fulfillment Partner: APS, Board of Pharmacy License: 0230000002,

— Telemedicine Fulfillment Partner: MyTelemedicine, Inc., 610 Elm St. Suite 710, McKinney, Texas 75069

— Discount Pharmacy Partner: PharmacyRxCard LLC.,

pharmacyrxcard.com

EMAIL COMMUNICATIONS

TheDrugClub.com respects your email preferences and will never provide your email address to a third party without your permission, except as may be prescribed elsewhere in this Privacy Policy. If you provide us your email address, TheDrugClub.com may email you offer alerts, account notifications, news, offers, surveys, promotions, and other communications. If you do not want to receive particular types of email messages from TheDrugClub.com, follow the unsubscribe instructions contained in the email message to notify us of our preferences, or click here.

CHILDREN’S PRIVACY

TheDrugClub.com’s site is not intended for and may not be used by children under the age of 13. TheDrugClub.com is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities. TheDrugClub.com does not knowingly collect personally identifiable information from children under the age of 13, nor does TheDrugClub.com target its services or site to children under the age of 13. We recommend that minors between the ages of 13 and 17 ask and receive permission from their parent or guardian prior to using TheDrugClub.com or sending information about themselves or anyone else over the Internet.

PROTECT YOURSELF

TheDrugClub.com uses automated processes and third party aggregators to collect and present information that has been created by third parties, so we cannot verify the accuracy or legitimacy of all offers or postings displayed in our services. We strongly encourage you to exercise caution when providing information about yourself to others online, including when you use data enrichment and marketing services found through TheDrugClub.com.

COOKIES

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. TheDrugClub.com may use cookies to keep track of your session and advertising delivery. TheDrugClub.com or our partners may also use cookies to deliver content specific to your interests and to save a password associated with a user profile. We use third-party advertising companies to serve ads when you visit our site. These companies may use third-party cookies to record information (excluding your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you on others websites. You can learn more here. You can opt-out of this type of advertising here.

THIRD PARTY COOKIES

From time-to-time, TheDrugClub.com engages third parties to track and analyze nonpersonally identifiable usage and volume statistical information from Visitors and Customers who visit our Sites. TheDrugClub.com also uses other third-party cookies to track the performance of our advertisements.

WEB BEACONS

TheDrugClub.com uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of our Sites and your interactions with emails that we have sent you. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you have viewed a particular Website tied to the Web beacon. For example, TheDrugClub.com sometimes places Web beacons in marketing emails that notify us when you click on the link in the email that directs you to one of our TheDrugClub.com Sites. TheDrugClub.com uses Web beacons to operate and improve our Sites and email communications.

LINKS TO THIRD PARTY SITES

The TheDrugClub.com site may provide links to external websites. Such links do not constitute an endorsement by TheDrugClub.com of those external websites. You acknowledge that TheDrugClub.com is providing these links to you only as a convenience, and further agree that TheDrugClub.com is not responsible for the content of such external websites. Your use of external websites is subject to the terms of use and privacy policies located on the external websites.

ASSIGNMENT

If there is a change of control in TheDrugClub.com’s business (whether by merger, sale, or otherwise) or if there is an asset sale, the user information, including personal information, could be sold as part of that transaction and your personally identifying information potentially could be used by the purchaser. However, if that business materially changes this statement or the information handling practices as described in this Privacy Policy, you will be notified by email and/or through a notice posted on the site, and you may opt-out of the use of your existing information in a new manner. This Privacy Policy inures to the benefit of any successors or assigns of TheDrugClub.com or the assets of TheDrugClub.com.

CONDITIONS OF USE

If you decide to use TheDrugClub.com’s site or services, your use and any possible dispute over privacy is subject to this Privacy Policy. If you have questions about this Privacy Policy, you can contact us.