TracPoint Wireless, Inc. Privacy Policy

Effective Date: March 2021

This Privacy Policy applies to all visitors and users of the TracPoint Wireless, Inc. Website, as well as any and all TracPoint Wireless, Inc. mobile applications.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, consumer, household, or device ("Personal Information"). Personal Information does NOT include:

· Publicly available information from government records;

· Deidentified or aggregated consumer information;

· Health or medical information covered by the Health Insurance Portability and

Accountability Act of 1996 (HIPAA), clinical trial data, or other qualifying research data; or

· Personal Information covered by certain sector-specific privacy laws, including but not limited to the Fair Credit Reporting Act (FCRA) and the Gramm-Leach-Bliley Act (GLBA).

In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category Examples Collected

Identifiers. Internet Protocol addresses. YES

Personal A name, signature, Social Security number, NO

Information. physical characteristics or description, address,

telephone number, passport number, driver's license

or state identification card number, insurance policy

number, education, employment, employment history,

bank account number, credit card number, debit card

number, or any other financial information, medical

information, or health insurance information. Some

personal information included in this category may

overlap with other categories.

Protected Age (40 years or older), race, color, ancestry, national NO

classification origin, citizenship, religion or creed, marital status,

characteristics medical condition, physical or mental disability,

under sex (including gender, gender identity, gender expression,

federal law. pregnancy or childbirth and related medical conditions),

sexual orientation, veteran or military status, genetic

information (including familial genetic information).

Commercial Records of personal property, products or services NO

Information. purchased, obtained, or considered, or other

purchasing or consuming histories or tendencies.

Biometric Genetic, physiological, behavioral, and biological YES

Information. characteristics, or activity patterns used to extract a

template or other identifier or identifying information,

such as, fingerprints, faceprints, and voiceprints,

iris or retina scans, keystroke, gait, or other physical

patterns, and sleep, health, or exercise data.

Internet or Browsing history, information on a consumer's YES

other similar interaction with a Website and/or mobile

network application(s), or advertisement.

activity.

Geolocation Physical location or movements. YES

data.

Sensory Audio, electronic, visual, thermal, olfactory, NO

Data. or similar information.

Professional Current or past job history or performance NO

or evaluations.

employment-

information.

Non-public Education records directly related to a student NO

education maintained by an educational institution or party

information. acting on its behalf, such as grades, transcripts,

class lists, student schedules, student identification

codes, student financial information, or student

disciplinary records.

Inferences Profile reflecting a person's preferences, NO

drawn from characteristics, psychological trends,

other predispositions, behavior, attitudes, intelligence,

personal abilities, and aptitudes.

Information.

We obtain the categories of Personal Information listed above from the following categories of sources:

· Directly from you. For example, from forms you complete.

· Indirectly from you. For example, from observing your actions on our Website and/or mobile applications, internet service providers, data analytic providers, operating systems and platforms.

Cookies and Similar Technologies

In some instances, we may collect non-personal information through the use of cookies and other similar technologies. These technologies help us better understand and improve the usability and effectiveness of our Website and/or mobile applications by (i) telling us which parts of our Website and/or mobile applications you have visited and (ii) measuring the effectiveness of advertisements and Web searches. Acceptance of these technologies may allow us to access information about your browsing history [BM1] [LB2] which helps us to personalize your experience. While we do not treat this information as Personal Information, to the extent that Internet protocol (“IP”) addresses and the like are considered Personal Information by law, we will regard this information as Personal Information, as well. Indeed, the only Personal Information these technologies can gather is information that you have supplied yourself. To the extent that nonpersonal information and Personal Information are combined, we will treat that combined information as Personal Information. You may decline the use of these technologies, but doing so may negatively affect the functionality of our Website and/or mobile applications.

Use of Personal Information

We may use, or disclose the Personal Information we collect for one or more of the following purposes:

· To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns;

· To provide, support, personalize, and develop our Website and/or mobile applications, products, and services;

· To create, maintain, customize, and secure your account with us;

· To process your requests, purchases, transactions, and payments and prevent transactional fraud;

· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;

· To personalize your Website and/or mobile applications experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website and/or mobile applications, third-party sites, and via email or text message (with your consent, where required by law);

· To help maintain the safety, security, and integrity of our Website and/or mobile applications, products and services, databases and other technology assets, and business;

· For testing, research, analysis, and product development, including to develop and improve our Website and/or mobile applications, products, and services;

· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;

· As described to you when collecting your Personal Information; and/or

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website and/or mobile applications users/consumers is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below.

Personal Information Category Category of Third-Party Recipients

Business Purpose Disclosures Sales

A: Identifiers. To service our clients. None.

B: Personal Information. None. None.

C: Protected classification None. None.

characteristics under California

or federal law.

D: Commercial information. None. None.

E: Biometric information. To service our clients. None.

F: Internet or other similar To service our clients. None.

network activity.

G: Geolocation data. To service our clients. None.

H: Sensory data. None. None.

I: Professional or None. None.

employment-related

information.

J: Non-public education None. None.

information.

K: Inferences drawn from other None. None.

personal information.

Your Rights and Choices

You have specific rights regarding your Personal Information. This section describes your rights and explains how to exercise those rights.[BM3] [LB4]

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

· The categories of Personal Information we collected about you.

· The categories of sources for the Personal Information we collected about you.

· Our business or commercial purpose for collecting or selling that Personal Information.

· The categories of third parties with whom we share that Personal Information.

· If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

· sales, identifying the Personal Information categories that each category of recipient purchased; and

· disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

· The specific pieces of Personal Information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for B2B Personal Information.

Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for B2B Personal Information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

· Calling us at 800-404-4450 or

· Emailing us at privacy@tracpoint.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information. To designate an authorized agent, you can call or email us as described above.

You may also make a request to know or delete on behalf of your child by calling or emailing us as described above.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and

· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please call us at 800-404-4450.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by applicable law, we will not:

· Deny you goods or services.

· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

· Provide you a different level or quality of goods or services.

· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Website and/or mobile applications and update the notice's effective date. Your continued use of our Website and/or mobile applications following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which TracPoint, Inc. collects and uses your information described in this Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under applicable date privacy laws, please do not hesitate to contact us at:

Phone: 800-404-4450

Website: https://www.tracpoint.com/contactus

Email: privacy@tracpoint.com

Postal Address:

TracPoint, Inc.

Attn: President

100 Cummings Center, Suite 244-C

Beverly, MA 01915

If you need to access this Policy in an alternative format due to having a disability, please contact us at privacy@tracpoint.com or 800-404-4450.

[BM1]We only track when customer is in app…. We don’t tack anything beyond that

[LB2]Understood, but this would still be considered a collection of personal information.

[BM3]We do not sell any personal information. Can remove this

[LB4]Understood, but do you share any information you collect with your clients? If so, this section should stay.