Privacy Policy - Redpoint Positioning

Redpoint Positioning Corporation (“Redpoint”) respects your right to privacy, and we want you to know how we collect, share, and use Personal Information provided on our website www.redpointpositioning.com and associated sites and provided to us in email or other electronic messaging. This Privacy Policy does not apply to information collected by Redpoint offline or through any other means unless otherwise specified. This Privacy Policy does not apply to content processed, stored or hosted by our customers using our Real-Time Location Service (RTLS) system in connection with an agreement with Redpoint. Nor does this Privacy Policy apply to information collected by any third party, including through any application or content that may link to or be accessible from our sites.

Please read this policy carefully to understand our policies regarding your Personal Information. By accessing or using this Website, you agree to this Privacy Policy.

Contents of the Privacy Policy

Who We Are

We are a technology company that provides solutions involving Real-Time Location Systems (RTLS). Redpoint's technology was built to address limitations of other real-time location systems like ease of installation, scalability, and inter-operability. Our platform provides unprecedented visibility into how people, equipment, and assets are moving in warehouses and industrial facilities in real-time, empowering managers with actionable data to improve safety, efficiency, and productivity and preparing companies to scale for future growth.

Personal Information Defined

As used in this Privacy Policy, “Personal Information” means information relating to an identified or identifiable natural person. Personal Information includes, among other things, your name, address, e-mail address, telephone number, and it may include your IP address.

Personal Information We Collect

Depending upon how you use our sites, our sites may collect your first and last name, job title, employer name, your work email, any applicable username and password, and other information you may provide to us. In certain circumstances, we may accept resumes and other employment related information from job applicants. Like most sites, we also collect browser-provided information including IP address, browser type, information about your location, and time/date stamps of visits.

How We Collect Personal Information

We collect Personal Information when you visit our websites and submit the information in an online form, send us email, send us inquiries, and register for events. As discussed above, browser-provided information and location information may also be collected when you visit our sites.

We may also obtain Personal Information from third parties with whom we have business relationships.

How We Use Your Personal Information

We may use Personal Information in the following instances:

To respond to your inquiries,
To provide you with content you have requested;
To administer our website and your account;
To understand what features of our sites are most popular;
To send you information that we believe may interest you;
To invite you to provide feedback on our website;
To consider you for employment, if you have applied for a position with us;
To fulfill agreements with third parties and/or business partners;
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, and development;
As deemed necessary to protect our legal rights and our property, to protect other users or any third party, or to prevent personal injury or loss; and
We may also request consent to use your Personal Information for other purposes, which we will communicate to you.

Service Providers: We may share Personal Information with third party suppliers, contractors and agents who perform services for us, such as marketing assistance and data analytics. Those third parties only have access to the Personal Information they need to provide services to us, or to you on our behalf.
To Protect Redpoint: We release Personal Information as we believe necessary and appropriate to law enforcement, tax, fraud prevention, credit risk agencies and other related organizations, and as required by applicable law or pursuant to a court, administrative, or similarorder.

Protection of Your Personal Information

We have implemented appropriate organizational, technical, and administrative measures to protect Personal Information within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Information from loss, misuse, interference, and unauthorized access, modification, and disclosure, please understand that no security procedures or protocols are ever guaranteed.

We securely destroy your Personal Information within a reasonable time after it is no longer needed for business purposes.

How to Update Your Personal Information

If you believe that Personal Information we have about you is incorrect, you can ask us to correct the Personal Information by Contacting Us.

How to Opt Out of Direct Marketing

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our emails or by Contacting Us.

Cookies

A “cookie” is a small text file that is stored on computers, tablets, mobile phones, and any device used to browse the Internet, capable of storing navigation information for statistical or functional purposes. Some cookies may be used to recognize the user viewing a particular website, make navigation easier, and customize the content. For example, cookies allow us to remember your actions and preferences so that you do not have to re-enter information each time you visit our site or navigate to another page.

You can set your browser to accept or reject the setting of all or certain cookies, or to request to be notified when a cookie is set. Each browser has specific configuration instructions. However, please

be aware that the blocking of cookies may have the effect that you will not be able to use all of our website’s functions.

Third Party Tracking and Online Advertising

Social Media: Our website may include social media features, such as LinkedIn, Twitter, WeChat, or other social media or related connections. These companies may recognize you and collect information about your visit to our website, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

Advertising: We partner with a third party ad network to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect information about your activities on our website and other websites to provide you targeted advertising based upon your interests.

We are not responsible for the collection, use, and disclosure policies and practices (including the data security practices) of other organizations, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with our website.

Analytics

Google Analytics: We use Google Analytics, a web analysis service of Google, Inc., to improve the user experience. Google Analytics helps us determine the number of visitors to our website and helps us understand how users find our site. Google Analytics may record your geographical location, device, internet browser, operating system, and IP address. If you do not want to be tracked by Google Analytics on our Website, you can opt out at https://tools.google.com/dlpage/gaoptout.

Other Websites

This Privacy Policy only applies to by Redpoint’s website and websites of our affiliates linking to this Privacy Policy. Our websites contain multiple links to other websites. Please be aware that we are not responsible for the privacy practices of those websites. When visiting other websites, you should read those sites’ privacy policies.

Children’s Privacy

We do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register on our website or send any Personal Information about yourself to us in any way. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that by Redpoint Positioning has obtained information about a child under the age of 13, please Contact Us.

“Do Not Track” Signals

Redpoint does not respond to “Do Not Track” (DNT) signals.

Mergers, Acquisitions, and Other Business Transactions

Redpoint may decide to sell, buy, merge, or otherwise reorganize our business. If that occurs, you will be notified via e-mail or a prominent notice on our websites of any ownership change and any changes in the use of your Personal Information. These types of transactions may involve the disclosure of Personal Information to prospective or actual purchasers, or receiving it from sellers. We seek appropriate protection for Personal Information in these types of transactions.

Changes to this Privacy Policy

We may need to update this Privacy Policy. We will alert you to material changes by, for example, placing a notice on our website and/or by sending you an e-mail (if you have registered your e-mail details with us) when we are required to do so by applicable law. You can see when this Privacy Policy was last updated by checking the date at the bottom of thispage.

Your California Privacy Rights.

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the California Supplemental Privacy Policy.

Users in the European Union, European Economic Area, and Switzerland.

Redpoint anticipates in the EU-US and Swiss-US Privacy Shield Framework regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom and Switzerland. The Privacy Shield team has determined that our organization’s Privacy Shield submission is complete; therefore, our organization will publish the Privacy Shield-consistent privacy policy including a statement that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield Principles, visit here.

Redpoint is the data controller of the Personal Information that you provide on our websites. You may contact Redpoint at [email protected] or by mail to Privacy Officer, Redpoint Positioning Corporation, 100 N. Washington St., 6th Floor, Boston, MA 02114.

Purposes of Processing and Legal Basis for Processing. As explained above, we process Personal Information in various ways depending upon your use of our websites. We process Personal Information on the following bases: (1) with your consent; (2) as necessary to perform a contract; and

as necessary for our legitimate interests in providing you with our products and services, enhancing our web services, conducting analytics, and delivering relevant advertising.

We may provide personal information to third parties to perform services on our behalf. If we transfer personal information received under the Privacy Shield to a third party, the third party's access, use, and disclosure of the personal data must also be in compliance with our Privacy Shield obligations, and we will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.

It may also be necessary for Redpoint to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other potential liabilities, including by enforcing the terms and conditions that govern the services we provide.

Your Rights Regarding Personal Information:

- Access and Confirmation. You have the right to ask us if we process PersonalInformation about you, and in some circumstances, to obtain a copy of your Personal Information.
- Deletion and Blocking. Under certain circumstances, you may have the right to have your Personal Information deleted or blocked without undue delay.
- Direct Marketing. You have the right to object to our processing of Personal Information for direct marketing purposes.
- Consent. To the extent we are processing Personal Information on the basis of your consent, you have the right to withdraw consent at any time.Data Portability. Under certain circumstances, to the extent we are processing your Personal Information on the basis of consent, or that it is necessary to perform a contract with you,

and the processing is carried out by automated means, you have the right to receive the Personal Information in a structured, commonly used and machine-readable format.

To exercise those rights, please contact us at Redpoint at [email protected] or by mail to Privacy Officer, Redpoint Positioning Corporation, 100 N. Washington St., 6th Floor, Boston, MA 02114.

Transfers. We are headquartered in the United States of America. Personal Information may be accessed by us or transferred to us in the United States. The European Commission has not determined that the United States ensures an adequate level of protection for Personal Information. By providing us with Personal Information, you consent to this transfer. We will protect the privacy and security of Personal Information according to this Privacy Policy, regardless of where it is processed or stored.

By providing us with Personal Information, you consent to the storage or processing of Personal Information in the United States and acknowledge that the Personal Information will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your Personal Information.

EU-US and Swiss Privacy Shield

Redpoint complies with the EU-US and Swiss-US Privacy Shield Frameworks set forth by the U.S. Department of Commerce which applies to the collection, use and retention of personal information transferred from the European Union, the United Kingdom and Switzerland to the United States. Redpoint has certified to the Department of Commerce that it complies with the Privacy Shield Principles. In the event that there is a conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall be controlling. For more information regarding the Privacy Shield program and to view Redpoint’s certification, please visit www.privacyshield.gov.

As set forth in the Privacy Shield Principles, Redpoint is accountable for personal information that it receives and subsequently transfers to third parties acting as an agent on its behalf. If third parties that process personal information on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we remain liable, unless Redpoint proves that it is not responsible for the event giving rise to the damage.

Should anyone feel that Redpoint has failed to comply with the Privacy Shield Principles concerning the handling of personal information, and if Redpoint has not been able to resolve that complaint itself, he/she may contact JAMS Privacy Shield Dispute Resolution.

As set forth in the Privacy Shield Principles, binding arbitration will also be made available to a complainant to address any complaints that have not been resolved through other mechanisms. Redpoint is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

How to Contact Us

Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your Personal Information, please do not hesitate to Contact Us.

This policy was last updated on 07/13/2020