AIRSAGE INC. PRIVACY POLICY

Effective: August 25, 2021

Your privacy is important to AirSage. AirSage, Inc. (“AirSage”, “we”, “us” or “our”) respects the privacy of our website visitors and our customers (“you” or “your”). This Privacy Policy (and as amended from time to time as posted on our website here ) covers the information AirSage may or does collect, use, and share when you visit our airsage.com website (“Website”) or use our services. Your use of AirSage’s Location Intelligence Services (“LIS”) and our website (“Website”), mobile app (“Mobile App”), and web app (“Web App”) (collectively, “Services”), is subject to our Privacy Policy. Please take a moment to familiarize yourself with our privacy practices. Your use of the Website and our Services is at all times subject to our Terms of Service (available here ) (“Terms”), which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

Policy Changes. We reserve the right to make changes to this Privacy Policy. Our current Privacy Policy will always be on our Website and any updates will be effective upon posting. You are responsible for periodically checking this Website for updates. Certain areas of our Website or our Mobile App may require you to acknowledge your consent via a pop-up message and/or click-through box requiring your agreement to the amended Privacy Policy before you can proceed to that Website area or to use the Mobile App. For any significant change affecting your Personal Information (defined below), we may notify you of such change. If you disagree with any change, you must stop using our Services; otherwise, we will consider your continued use to be acceptance of any change.

Information this privacy policy covers. This Privacy Policy covers our treatment of personally identifiable information. Such information may include name, mailing address, email address, telephone number, and other information which identifies you as a specific individual (“Personal Information”). For this Privacy Policy the definition of “Personal Information” is the definition under the state, country, or other law applicable to the person whose data is collected. For California residents, “Personal Information” shall have the definition as set forth in the California Consumer Privacy Act (“CCPA”).

Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (the foregoing in this sentence being referred to as “De-Identified Personal Information”).

We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. No one under age 18 should provide any Personal Information to or on the Services. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.

Personal Information we collect. We collect several categories of Personal Information from and about you, namely, Personal Information we collect:

HOW WE COLLECT PERSONAL INFORMATION

Information You Provide to Us. The information we collect on or through our Website or Mobile App may include:

• Information that you provide by filling in forms on our Website or Mobile App. This includes information provided at the time of registering to use our Website or Mobile App, subscribing to or purchasing our Services, e-newsletters, posting material (where permitted), or requesting further Services. We may also ask you for information when you report a problem with our Website or Services.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website and Mobile app, we may use automatic data collection technologies to collect certain aggregated or anonymized information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.
• Your location while using the Mobile app.
• We do not allow personalized third-party behavioral tracking, though we may use De-Identified Personal Information to track users’ click or browsing patterns.

The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website or Mobile app and to deliver a better and more personalized service, including, but not limited to, by enabling us to: (a) estimate our audience/visitor size and usage patterns; (b) store information about your preferences, allowing us to customize and improve our Website or Mobile app; (c) speed up your searches; and/or, (d) recognize you when you return to our Website.

Cookie Notice/Policy. The technologies we use for this automatic data collection may include cookies, web beacons, pixel tracking, GIF, and/or IP address. Each of these is discussed below.

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer (Internet Explorer, Firefox, Safari or Google Chrome).

Different types of cookies which have different purposes are used on our Website.

Essential Cookies. These cookies are essential to allow you to browse our Website and use its functions.

Performance Cookies. These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Websites from their site and whether your visit has led to the use or purchase of a product or Service from our Website, including the references for the product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.

Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our goods, services, and other offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing and research.

GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.

IP Address. Our servers automatically record certain log file information reported from your browser when you access the Services. These server logs may include information such as which pages of the Service you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Services. These log files are generally deleted periodically. All of this information is stored only in aggregated form and is not personally identifiable.

Google
Google Analytics. We use, and some of our third-party service providers may use, Google Analytics (click for link to Google’s website) or other analytics service to help us understand use of our Services. Such service providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.

Google Maps/Google Earth. We also use Google Maps (including the Google Maps API(s)) and/or Google Earth, which may, among other things, request access to your geolocation, and both of which are subject to their own terms of use and privacy policy.

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.

LIS Information. We automatically receive certain types of information whenever you use our Services, including information about your mobile phone, computer, and online activities. For example, when you access our Website or Mobile app, we may automatically collect your devices’ and computer’s IP address, the date and time of your access, the type of browser you use, information about your computer’s or mobile device’s operating system, your location and the specific services accessed. Information we may collect when we provide you LIS includes the time and date of your access of the LIS, the duration of your session, how much studies you request or open during a session and study details, the informational pages you visit. We may also analyze and compile information on patterns of usage of the LIS. We may use this information to improve our Services. Some of this information is automatically collected through systems or tracking tools such as cookies, tracking pixels, and web beacons, as described above.

When you register for Services, contact us, or participate in an online survey or poll, we will collect information from you (like name, title, e-mail address, telephone number, etc.). When using our Services, you may also be asked for additional information to help identify you.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:

• To present our Website and its contents to you.
• To present our Mobile app and its contents to you.
• To provide you with the Services that you have requested.
• To provide you with information on products or Services that you request from us.
• To provide you with notices about your account, including expiration and renewal notices.
• To send you emails, text, and newsletters with information on products, services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you our company, and other information.
• To respond to your questions or other requests.
• To contact you with regard to the Website or Mobile app and to send important notices, such as communications about our Services, your account or changes to our terms, conditions, and policies.
• To process any applications, changes to your account information.
• To process other information or Personal Information that you submit through this Website or Mobile app.
• To notify you about changes to our Website, Mobile app, our policies, terms, or any products or Services we offer or provide though it.
• To allow you to participate in interactive features on our Website or Mobile app.
• To ask for ratings and reviews of our Website, Mobile app, Services, and/or products.
• To provide access to restricted parts of our Website or Mobile app.
• To request your participation in surveys, or other initiatives which help us to gather information used to develop and enhance our products and Services.
• To serve relevant information to you when you visit our Website, Mobile app, or other third-party sites (including social media platforms).
• To enhance and improve our products and Services, for example, by performing internal research, analyzing user trends, and measuring demographics and interests.
• To improve our content and deliver information to you that is targeted to your interests.
  For internal purposes, such as Website, Mobile app, and system administration or internal audits and reviews.
• For analyzing how any of the Services are used, diagnosing Service or technical problems, maintaining security, and personalizing content.
• To operate, maintain, and provide to you the features and functionality of the Services.
• To provide statistics about the usage of the Website or Mobile app and other related information to reputable third parties, but these statistics will not include information which will allow you to be identified.
• To notify you of data privacy incidents or provide you with legally required information.
• To provide marketing material or advertisements from AirSage or its partners to you, but you will be able to opt-out of these communications.
• To fulfill any other purpose for which you provide it.
• In any other way we may describe when you provide the information.

We may use your Personal Information you provide us and which we obtain from other sources to better understand your interests so we can try to predict what other products, services, and information you might be most interested in. This practice is called “profiling”, which involves making automated decisions about you based on this information in order to better enable us to tailor our interactions with you to make them more relevant and interesting.

HOW WE SHARE YOUR INFORMATION
We do not sell (as that term is defined in the CCPA) Your personal information, period.

We may disclose your Personal Information, in whole or in part, with third parties for the purpose of providing or improving the Services to you, who perform services on our behalf, or for marketing purposes. We may or do disclose Personal Information to the following types of third parties, and for one or more the following purposes:

• Hosting providers for the secure storage and transmission of your data
• Learning technology and online event providers for the delivery and improvement of web events and learning programs and the tracking of your progress
• Identity management providers for authentication purposes
• Database software providers for the management and tracking of your data
• Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
• Third party service providers who send communications on our behalf regarding our products and Services
• Technology providers who assist in the development and management of our Website or our Mobile App
• Advertising partners, including social media providers, for the delivery of targeted advertisements

Disclosures to Service Providers. We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide: outbound and/or inbound communications, data analytics, marketing assistance, managing customer information. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).

Disclosure of De-Identified Personal Information. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services, working with those third parties to do research, including for marketing purposes, and to improve our Services and provide new services, and for any other purpose we deem appropriate.

Required Disclosures. Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process, or subpoena, including to respond to any government or regulatory request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, contracted vendors, or affinity partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) enforce our Terms (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations; (e) assist government enforcement agencies or to meet national security requirements; (f) to protect the security or integrity of our Website, our Mobile App, our Services, or any software we provide related thereto; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others.

We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.

It is likely that the identity and categories of such third parties will change during the life of your account. We require that our third-party service providers only use your Personal Information as necessary to provide the requested services to us and each service provider is subject to a set of terms consistent with the applicable portions of this Privacy Policy.

Your Consent to Disclosure/Transfer/Sale of Your Personal Information. You consent to our disclosure of your Personal Information and other information to a potential or actual buyer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) of any or all of our rights to your Personal Information and your consents, in whole or in part, and other information, with or without notice to you and without your further consent.

DATA TRANSFER/ACCESS OUTSIDE OF THE UNITED STATES

We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

DATA SECURITY

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of service providers who have special access rights to our systems, and who are required to keep the information confidential. We do not collect or store full credit card numbers. Our Website and Mobile App software are scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website and Mobile App safer.

Our agents, contractors, and partners who require access to your Personal Information in order to provide services to us or to you on our behalf are also required to keep the information confidential in a manner consistent with this Privacy Policy and are not permitted to disclose the information to third parties or use the information for any purpose other than to carry out the services they are performing for us.

The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Website, Mobile App, or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. If your email account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We’ll never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or used with our Services.

DATA RETENTION

The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will keep your Personal Information for as long as your user account is active, or as long as you are a customer or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.

Following termination or deactivation of your user account, we may retain your profile information and all information posted to public areas of the Website. Following termination or deactivation of your user account, we may retain your Personal Information and other data, but will maintain it as confidential according to the Terms, this Privacy Policy, and as required by applicable law. We have the right to delete all of your Personal Information and other data after termination of your user account without notice to you. We may retain De-Identified Personal Information for as long as we deem appropriate.

ACCESSING USER INFORMATION

Through your user account settings on the Website or Mobile App, you may access and, in some cases, edit, or delete certain information you’ve provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us. We will try to update your Personal Information as we become aware of changes; however, we will be able to serve you best if you update your Personal Information or notify us of any changes to (or errors in) your Personal Information. You can update your Personal Information through our Web App or by contacting us (see below).