­­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.

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.  Halo Connect Services makes use of cookies to understand how you use our site and improve your experience. Cookies are small text files downloaded by your Internet browser and stored on the device you use to access the Site (e.g., your desktop computer, tablet or smartphone). Depending on their purpose, cookies log user-related information such as your preferences, authentication information, security parameters, data concerning the device you use to access the Site and statistical information regarding your use of the Site. When you visit the Site, your Internet browser transmits the cookies including the contained information back to the servers they were initially downloaded from. The analysis and processing of the information allows us to ensure the functionality of the Site, personalize your online experience and improve and optimize the structure and content of the Site.

Web Beacons.  We may log information using digital images called Web beacons on our Service or in our emails. We use Web beacons to manage cookies, count visits, and to learn what marketing works and what does not.  We also use Web beacons to tell if you open or act on our emails.

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.

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

The legal bases for our processing your personal information are (a) our obtaining your consent for the processing of your personal information for one or more specific purposes, and (b) the fact that such processing is necessary for us to render the Service for which you registered and not overridden by your data protection interests or fundamental rights and freedoms. We may also process your personal information where we have a legal obligation to collect and process personal information or where the processing is necessary to protect your vital interests or that of another natural person.

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.

UNSUBSCRIBE/OPT-OUT

You can opt out of receiving our newsletter or marketing emails by following the instructions at the bottom of each communication or at any time by e-mailing.

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 of 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 (2010/87/EC and/or 2004/915/EC);
• 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.

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.  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 series 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 record keeping obligation, resolve disputes, and enforce our agreements.

CONTACT INFORMATION.  We welcome your comments or questions about this privacy policy.  You may also contact us atprivacy@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 July 31, 2019.