Aperia Technologies, Inc.

PRIVACY POLICY

This Privacy Policy (“Policy”) describes how Aperia Technologies, Inc. and its related companies (“we” or “Company”) collect, use and share personal information of consumer users of the Halo Connect™ service (the “Service” or “Halo Connect”), this website (the “Site”), and other services provided by the Company (collectively, the “Services”). This Policy also applies to any of our other mobile applications or websites that post this Policy.  This Policy does not apply to websites that post different statements.

WHAT WE COLLECT

We obtain your personal information in a range of ways:

Information That You Provide.  We collect information you directly give us.  To use Halo Connect, you must set up a Halo Connect account and provide us with certain information such as username, password, user first and last name, user company/fleet, user title, user phone number, user email address, user address, vehicle ID number assigned by the fleet, and vehicle VIN.

We may also collect marketing and sales data such as your role, company name, interaction history, and preferences, as well as communications data such as emails, phone call summaries, and chat logs with Aperia representatives for support, onboarding, and business development purposes.

Information from Job Applicants. If you apply for a position at Aperia, we collect information such as your name, contact details, resume, employment and education history, and any other details you voluntarily provide. This may include sensitive data (e.g., for accessibility accommodations) where applicable.

Device and Vehicle Data.  The Halo Connect Service is comprised of sensors attached to the vehicle’s tires and Halo tire inflator, the Halo Connect Gateway that communicates data to the cloud, and a predictive tire maintenance software platform. The vehicle data are transmitted to Halo Connect’s servers through secured wireless telecommunications networks and stored on encrypted cloud servers, in accordance with the applicable providers’ respective privacy, data handling and data usage policies.

Information That Is Aggregated. “Aggregate data” are data we collect about a group or category of features, services or individuals, from which individual identities have been removed. For example, information about how you use a feature may be collected and combined with information about how others use the same feature, without any personal information included in the resulting data.

Information Automatically Collected.  We automatically log information about you and your computer. For example, when you visit Halo Connect, we log‎ your computer operating system type,‎ browser type,‎ browser language,‎ pages you viewed,‎ how long you spent on a page,‎ access times,‎ Internet protocol (IP) address, and information about your use of and actions on Halo Connect.

Cookies and Similar Technologies.   We use cookies and related tracking technologies (such as pixel tags, advertising IDs, and site analytics scripts) on our websites and applications to enhance your experience, remember your preferences, analyze site traffic, and deliver relevant content or advertising.

These technologies may be placed by us or our third-party service providers (e.g., analytics and advertising partners). You can control or limit the use of cookies through your browser settings or device permissions.

To learn more about the types of cookies we use, their purpose, retention periods, and how you can manage your preferences or opt out, please visit our full Cookie Policy.

Web Beacons We may use small digital images (known as web beacons or pixel tags) in our emails or websites. These tools help us understand whether messages were opened, track user engagement with our content, and measure the effectiveness of our marketing campaigns. Web beacons typically work in conjunction with cookies or other identifiers. For details, see our Cookie Policy.

Halo Connect Website.  We may also collect personal information from our website in the event you use its interactive features, including but not limited to responding to a job posting, participating in promotions or surveys, commenting on posts, and accessing white papers. Our websites may include social media features such as the Facebook “Like” and “Share” buttons as well as mini-programs that run on our website. These features may collect your IP address and which webpage you are visiting. The use of such features is governed by the privacy policies of the feature owner.   We may also ask for and collect personal information from individuals who register for or attend events that we sponsor.

Special Categories of Personal Data.  We generally do not collect special categories of personal data as defined under Article 9 of the GDPR. If, in limited circumstances (e.g., job applications), we do collect such data (e.g., health/disability status), we will only process it with your explicit consent (Article 9(2)(a)) or where processing is necessary under employment law obligations (Article 9(2)(b)).

USE OF PERSONAL INFORMATION

We may use your personal information as follows:

• To operate, maintain, and improve our sites, products, and services.
• To provide custom, personalized advertisements, content, and information.
• To monitor and analyze usage and trends, and to personalize and improve Halo Connect and your experiences when you use Halo Connect.
• To respond to comments and questions and provide customer service.
• To send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
• Where permitted by applicable law, to communicate about promotions, upcoming events, and other news about products and services offered by us and by our selected partners. You can opt out of marketing communications at any time by contacting us at info@aperiatech.com or following the unsubscribe or opt-out instructions included in our marketing communications.
• We extract vehicle data and aggregate it through our data warehouse. Aggregated data sets made available by Halo Connect do not contain personal information and cannot reasonably be used to identify an individual.

Legal Basis for Processing Personal information

We process your personal information based on the following legal bases under Article 6 of the General Data Protection Regulation (GDPR):

In circumstances where we rely on your consent to process the personal information, you have the right to withdraw your consent at any time.

SHARING OF PERSONAL INFORMATION

We may share personal information as follows:

• We may share personal information with your consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
• We may share personal information for legal, protection, and safety purposes.
  • We may share information to comply with laws.
  • We may share information to respond to lawful requests and legal processes.
  • We may share information to protect the rights and property of Aperia Technologies, Inc., our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
  • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
• We may share information, including personal information, with our third party service providers that we engage for providing hosting, for maintenance of our websites, applications, backup, storage, payment processing, analytics, and other services. We do not allow our service providers with whom we share personal information to use that information for marketing or any other purpose other than in connection with the services they provide to Halo Connect.
• We may share personal information if and when we negotiate a transaction involving the sale or transfer of all or a part of our business or assets. These transactions can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
• We may share aggregate data with interested third parties to assist them in understanding the interest and usage patterns for certain information, products, services, data, content, services, advertisements, promotions, and/or functionality on the Service.

CONSENT AND WITHDRAWAL

We rely on your consent for certain types of data processing, such as for receiving marketing emails or providing optional demographic data.

Consent is obtained through clearly labeled checkboxes or forms at the point of collection and is always granular (e.g., separate checkboxes for product updates vs. third-party promotions) and unbundled from other terms.

You may withdraw your consent at any time by:

• Clicking the “unsubscribe” link in marketing emails
• Updating your communication preferences in your account settings (where applicable)
• Contacting us at privacy@aperiatech.com

Withdrawing consent does not affect the lawfulness of any processing performed prior to withdrawal.

HOW DO WE STORE YOUR DATA?

We securely store your data in AWS’s Oregon region. We use standard security practices to authenticate API calls and requests, to rotate encryption keys, to backup all data, and to manage user privileges to prevent data security breaches.

WHAT ARE YOUR DATA PROTECTION RIGHTS?

We would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

• The right to access – You have the right to request copies of your personal information. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your personal information, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your personal information, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your personal information, under certain conditions.
• The right to data portability– You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you would like to exercise any of these rights, please contact us at privacy@aperiatech.com.

INTERNATIONAL TRANSFERS OF DATA

Halo Connect stores data on cloud servers located in North America. We may also store data on cloud servers located in other countries from time to time.  However, data (including personal information) may be transferred across national boundaries for load balancing, availability, or other reasons.  In the event we were to store personal information of residents of countries outside North America, we would amend this Privacy Policy to incorporate the requirements of such countries and the General Data Protection Regulation (“GDPR”).

If you reside in the EEA, please note that we may transmit some of your personal information to an international organization or a country where the data protection laws may not provide a level of protection equivalent to the laws in your jurisdiction. As required by applicable law, we will provide an adequate level of protection for your personal information using various means, including, where appropriate:

• relying on a formal decision by the European Commission that a certain country ensures an adequate level of protection for personal information;
• entering into appropriate data transfer agreements based on language approved by the European Commission, such as the Standard Contractual Clauses;
• implementing appropriate physical, technical and organizational security measures to protect personal information against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing; and
• taking other measures to provide an adequate level of data protection in accordance with applicable law.

Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.

Are We complying with GDPR?

We aim to comply with the GDPR by implementing the disclosures, safeguards, and procedures outlined in this policy.

We reserve the right to keep customer data for a period of time adequate to ensure compliance and respond to follow-up inquiries. Pursuant to regulatory, legal, and security requirements in Chapter 2 of the General Data Protection Regulation this timeline is determined based on the type of data, the security implications of storing the data, the legal requirements Company must meet with the data, and the privacy of the individual referenced in the data.

We take the security of our data very seriously and have a responsibility to the individuals we hold data on behalf of on our systems and servers. Please refer to the following headings below to review what kind of data we keep and the process to request, review, change, or remove data we hold.

Your Rights If An EU Subject

1.1 If you are EU subject, Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. Under certain circumstances, by law you have the right to:

1.1.1 Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.

1.1.2 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

1.1.3 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

1.1.4 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

1.1.5 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.

1.1.6 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

1.1.7 Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.

1.1.8 Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate interest in doing so.

1.1.9 Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).

1.2 Data Subject Access Requests If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us at privacy@aperiatech.com.

1.3 Verification. To protect your data, we may require you to verify your identity or provide additional information before fulfilling your request.

1.4 No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

1.5 What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

1.6 Time for response. We aim to respond to all data subject requests within 30 calendar days. If more time is needed due to complexity or volume, we will notify you within the original period and provide an expected timeline.

LINKS TO OTHER SITES.  The Site may contain links or references to certain third-party websites or referrals to certain third-parties’ products or services. These are provided for your convenience only, and we do not have control over the privacy or security practices and policies of third-party sites. If you choose to visit a third party’s website, or use its products or services, the third party’s privacy statement, and not this Policy, will govern your activities and ay information you disclose while interacting with the third party.

CHILDREN.  Consistent with the federal Children’s Online Privacy Protection Act of 1998 (COPPA), we do not knowingly collect personally identifiable information from anyone under the age of thirteen (13) without parental consent. Any person who provides their personal information to us through the Site represents that they are 13 years of age or older.  We ask for and store users’ date of birth to ensure they are 13 or older, but do not share that information unless the user chooses to share it on the user’s profile.  If you believe that we have collected information from an individual under the age of 13, please contact us so that we may take appropriate steps to address the issue.

SECURITY OF YOUR PERSONAL INFORMATION.  The security of your personal information is important to us.  We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received.  We implement technical and organizational measures such as encryption (AES-256), role-based access controls, logging, and annual security assessments to protect your personal information.  No company can fully prevent security risks, however.  Mistakes may happen. Bad actors may defeat even the best safeguards.

DATA RETENTION.   We will retain your information for as long as needed to provide you services and fulfill the purposes described in this Policy.

We will retain and use your information as required or permitted by applicable law, including to comply with our legal or business recordkeeping obligations

CONTACT INFORMATION.  We welcome your comments or questions about this privacy policy.  You may contact us at privacy@aperiatech.com or If you are an individual located in the European Union or United Kingdom, you may also contact our Data Protection Officer (DPO) at: dpo@aperiatech.com

CHANGES TO THIS PRIVACY POLICY.  We may occasionally update this Privacy Policy. When we do, we will also revise the “updated date” on the Privacy Policy and without prior notice to you to reflect changes in our personal information practices.  If we make material changes to this Policy, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information that you have provided to us, the new policy will not apply to information collected prior to the change unless we obtain your consent. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect. Your continued use of the Service constitutes your going forward agreement to this Privacy Policy and any updates.

This privacy policy was last updated on October 1, 2025

 APERIA TECHNOLOGIES, INC. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

Effective Date:  1/1/2020

Last Reviewed on:  3/25/2024

This Privacy Notice for California Residents supplements the information contained in Aperia Technologies, Inc.’s General Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”).  If you do not reside in the State of California, this notice does not apply to you.  We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended from time to time, including as modified by the California Privacy Rights Act of 2020 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice for California Residents.

Information We Collect

The information we collect is as outlined in our General Privacy Notice.  It is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal information”).  Our collection of Personal information is limited, given our products and services provided.  Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’ s scope, like:
• Health or medical information covered by the Health Insurance Portability and Accountability act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial date.

We have collected the following categories of Personal information from our consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you.  For example, from observing your actions on our website.
• From you through Halo Connect.
• Directly and indirectly from activity on our website (www.aperiatech.com). For example, from submissions through our website portal or website usage details collected automatically.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to prepare a price quote, to ask a question, or to set up a session, we will use that 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 you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• 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 or as otherwise set forth in the CCPA.
• 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 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.

Minors Under Age 16

We do not collect the personal information of consumers we know to be less than 16 years of age.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

• We have disclosed information in any yes categories above with our business partners who have entered into agreements with us.
• We disclose your personal information for a business purpose to the following categories of third parties:
  • Our affiliates.
  • Our service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your California Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

• KNOW what personal information we have collected about you and how we use and share it.

“Personal information” means information that identifies, relates to, or could reasonably be linked to a particular consumer or household.

• LIMIT the use and disclosure of sensitive personal information we collect about you.
• OPT-OUT of the sale of your personal information, and the right to opt-out of the sharing of your personal information for cross-context behavioral advertising.
• CORRECT inaccurate personal information that we have about you.
• EQUAL We will not discriminate against you for exercising your CCPA rights.
• DELETE personal information we have collected from you, and require that our service providers do the same (subject to some exceptions).

The Right to Limit Use of Your Sensitive Personal Information

You can direct us to only use your sensitive personal information (for example, your social security number, financial account information, or your precise geolocation data) for limited purposes, such as providing you with the services you requested.

The Right to Know

You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:

• The specific pieces of personal information we have collected about you;
• The categories of personal information we have collected about you;
• The categories of sources of the personal information we have collected about you;
• The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of personal information we have sold about you, and the categories of third parties to whom this information was sold; and
• The business or commercial purposes for collecting or selling personal information about you.

You can make a request to know up to twice a year, free of charge.

The Right to Request Deletion

You have the right to request the deletion of personal information that we have collected from you, and to require that the third parties we have shared it with also delete it, subject to certain exceptions in which we are required to retain such information, including compliance with other laws and court orders. We may maintain a confidential record of deletion requests solely for the purpose of preventing the personal information of a consumer who has submitted a deletion request from being sold, for compliance with laws or for other lawful purposes.

We may deny your deletion request if retaining the information is necessary for us or our service providers 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, 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 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.

The Right to Correct Inaccurate Personal Information.

You have the right to request that we correct inaccurate personal information we maintain about you.  Once we receive a verified request to correct your inaccurate personal information, we will use commercially reasonable efforts to correct it.

The Right to Opt-Out of Personal Information Sales and Sharing         

You as a resident of California or Nevada have the right to direct us not to sell or share personal information we have collected about you to third parties now or in the future.

The Right to Non- Discrimination        

You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

“Shine the Light”

We may sell or share information you provide to us to third parties.  However, Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties.

ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS

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. Once we receive and confirm your verifiable consumer request, 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.
• The specific pieces of personal information we collected about you (also called a data portability request).
• 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.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Visiting us at:
  • com
• Writing us at:
  • Aperia Technologies, Inc. ATTN:  support@aperiatech.com
• Calling us at:
  • 1-844-RUN-HALO

Only you or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• 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.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within (45) days of its receipt.  If we require more time (up to 90 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 the verifiable consumer request’s receipt.  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 CCPA rights.  Unless permitted by the CCPA, 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; or
• 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 Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-844-RUN-HALO

Website:  www.aperiatech.com

Email: Privacy@aperiatech.com

Postal Address: Aperia Technologies, Inc., ATTN:  Privacy Management,  3160 Corporate Pl, Hayward, CA 94545

Other U.S. State Law Privacy Rights

In addition to California, several other U.S. states—including Colorado, Connecticut, Delaware, Florida, Montana, Oregon, Texas, Utah, and Virginia—have enacted privacy laws providing consumers with rights related to their personal information. Depending on whether you are a resident of those states (“Consumer”), we provide you additional notices about our privacy practices and consumer rights relating to your personal information or personal data, as defined under those laws (“Personal Information”).

Depending on your state of residence, you may have rights including:

• To know what personal data we collect and how we use it
• To access and delete your data
• To opt out of targeted advertising or the sale of your personal information
• To correct inaccurate personal data

We process such requests in a manner consistent with applicable state laws. We provide this additional information to you if you are in one of these states.

1. Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data.  Please note, we do not believe we “sell” Personal Data as that term is defined under Nevada Revised Statutes chapter 603A (Security and Privacy of Personal Information.

2. Colorado Resident Rights

If you are a resident of Colorado, you have the right to opt-out of the sale of certain Personal Data to third-parties who intend to license or sell that Personal Data.  Please note, we do not believe we “sell” Personal Data as that term is defined under Colorado’s Privacy Act SB21-190.

If you are a Colorado resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf.  To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

3. Connecticut Resident Rights

If you are a resident of Connecticut, you have the right to opt-out of the sale of certain Personal Data to third-parties who intend to license or sell that Personal Data.  Please note, we do not believe we “sell” Personal Data as that term is defined under Connecticut’s Personal Data Privacy and Online Monitoring Act.

If you are a Connecticut resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf.  To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

4. Virginia Resident Rights

If you are a resident of Virginia, you have the right to opt-out of the sale of certain Personal Data to third-parties who intend to license or sell that Personal Data.  Please note, we do not believe we “sell” Personal Data as that term is defined under Virginia’s Chapter 53 Consumer Data Protection Act § 59.1-575.

5. Utah Resident Rights

If you are a resident of Utah, you have the right to opt-out of the sale of certain Personal Data to third-parties who intend to license or sell that Personal Data.  Please note, we do not believe we “sell” Personal Data as that term is defined under Utah’s Consumer Privacy Act SB 227.

6. Other States’ Resident Rights

In recent months, the following  additional states have enacted comprehensive data privacy laws:

• Iowa
• Indiana
• Tennessee
• Oregon
• Montana
• Texas
• Delaware
• Florida
• New Jersey
• New Hampshire

In most instances, we do not believe these laws apply to us, given number of customers in a particular state, the applicability of a particular state’s privacy laws, and other circumstances.  For example, Florida’s law only regulates companies that have more than $1 billion in gross annual revenues.  To the extent that these laws may operate, and you are a resident of such state, you have the right to opt-out of the sale of certain Data to third-parties who intend to license or sell that Personal Data.  Please note, we do not “sell” Personal Data as that term is defined by the various states’ privacy laws.

We may from time to time as additional states pass comprehensive privacy laws amend this policy, but are under no obligation to do so. Please see note below.

Global Privacy Control (GPC) and Do Not Track (DNT)

Our website and services honor browser-based privacy signals, including Global Privacy Control (GPC) and Do Not Track (DNT), where required or permitted by law. If your browser sends a GPC or DNT signal, we treat this as a valid request to opt out of the sale or sharing of your personal information to the extent applicable by law.

PRIVACY LAWS VARY FROM PLACE TO PLACE AND WE INTEND TO COMPLY

Privacy and data protection laws vary around the world and among the individual United States. Our obligations arising under the applicable world’s privacy laws, including U.S. federal and most state laws, are satisfied by our work and compliance with GDPR and CCPA.  In some jurisdictions, however, privacy laws grant you, the data subject, certain specific rights regarding your personal information. We refer to these types of privacy laws as data subject rights-based laws.  One example of such a law is the CCPA.

The nature and locations of our business activities may make us subject to the CCPA.  As such, when we collect personal information from data subjects protected by the CCPA, we may become subject to, and those data subjects may have rights under the CCPA.  We satisfy our CCPA notice obligations to those data subjects and further explain their rights in the California-specific portion of our Privacy Policy.

We do not believe we have an obligation under the rules of other state or international comprehensive privacy laws to provide notices specific to them. If you live in a jurisdiction with a particular comprehensive privacy law and believe that you have rights, you may contact us at the various means provided for in the Privacy Policy.

We take your privacy rights seriously and to protect your information.  We do not collect a significant amount of personal information, but as outlined in our Privacy Policy, we comply with GDPR and with CCPA.  Questions about how other comprehensive privacy laws apply to us can be directed to us through the contact means set forth in our Privacy Policy.