Privacy Notice

Welcome to Smart Lockers, Inc. (hereinafter referred to as “SmartLocker”, “Company”, “we”, “us”, “our”) privacy notice (the “Privacy Notice”).
SmartLocker respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you as to how we look after your personal data when you use our SmartLocker locker products, website, or software applications in connection SmartLocker services and other goods or services managed by Smart Lockers, Inc. (collectively our “Products”).

1. PRIVACY NOTICE PURPOSE:
• The purpose of this Privacy Notice is to notify you of the types of information we may collect through your use of our Products or through our clients as a step in our process to deploy our Products for your use. This Privacy Notice will also inform you of how we use your information, your options to control communications and security procedures we use to protect your information.

2. CONTACT DETAILS:
• If you have any questions or comments about this notice, the ways in which SmartLocker collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at privacymanager@SmartLocker.com.

3. CHANGES TO THE PRIVACY NOTICE
• This Privacy Notice version was last updated on June 16, 2020.

4. THE CATEGORIES OF DATA WE COLLECT
Personal information, personal data, or personally-identifiable information (PII) refers to information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (hereinafter referred to as “personal information”, “personal data” or “personally-identifiable information”). Personal data does not include anonymous data or deidentified information where your identity has been removed. In particular, we have collected, used, stored, and/or transferred the following categories of personal information from our consumers within the last twelve (12) months:
Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, package tracking number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, address, telephone number, employment.
Some personal information included in this category may overlap with other categories. YES
C. Protected classification characteristics under California or federal law. ADA data. YES
D. Commercial information. Records of package label data. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, package history, information on a consumer’s interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO
L. Profile Data Username, password, feedback, survey responses, SmartLocker Product usage data. YES

5. FAILURE TO PROVIDE PERSONAL DATA
• In some instances, where we need to collect personal data by law or under the terms of a contract with you and where such personal data is not provided, we may not be able to perform the services in connection with the Products or deploy Products effectively for your use. In such instances, we may have to cancel your request or the provisioning of Products and/or services to you. In such instances, we will notify you of our need to cancel.

6. HOW PERSONAL DATA IS COLLECTED
• We use different methods to collect personal data from and about you including through:
o SmartLocker API: clients whom contract with us to provide our Products (e.g., enterprise clients) to its customers (e.g., end users) can provide us personal information via API integrations.
o Other SmartLocker solutions: clients whom contract with us to provide our Products (e.g., enterprise clients) to its customers (e.g., end users) can provide us personal information via SmartLocker SFTP solutions, SmartLocker Web Applications, or provisioning CSV files.
o End users: end user consumers of SmartLocker Products may directly provide us personal data by completing forms or creating an account to use our Products.

7. HOW PERSONAL DATA IS USED
• We use or disclose the personal data we collect for one or more of the following purposes:
o To fulfill or meet the reason you or our client provided the information. For example, if you or our client share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
o To create, maintain, customize, and secure your account with us.
o To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
o To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
o To fulfil a contract obligation or service obligation to you or our client providing the personal data.
o To personalize or enhance your service experience.
o For testing, research, analysis, and product development, including to develop and improve our Products and services.
o As described to you when collecting your personal information or as otherwise set forth in the CCPA.
o To enforce the terms and conditions applicable to use of the Products.
o As we deem reasonably necessary to investigate, prevent or take other appropriate action in connection with fraudulent activities, potential illegal activities, potential safety risks, or to security of your data.
o Based on your request, using contact information you provide, to inform friends and family of your use of Products.
• 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.

8. PARTIES TO WHOM WE DISCLOSE PERSONAL DATA
• We may share your contact information with third parties we engage or other service providers in connection with provisioning services on our behalf in relation to aspects, features and/or services of the SmartLocker Product. We contract with service providers to provide business functions on our behalf such as sending and receiving notifications and recognizing package label information. We require service providers with access to personal information to use and protect personal information in accordance with the standards of this Privacy Notice.
• In the event that SmartLocker or a portion of its Smart Locker’s business is acquired by another entity, including in bankruptcy, your information may be transferred to the successor entity.
• Please note that SmartLocker does not sell your personal nonpublic information and the sharing of your information with service providers or third parties does not provide any compensation or consideration to SmartLocker.

9. DATA SECURITY
• SmartLocker complies with applicable laws regarding the implementation of appropriate security measures to safeguard your personal information. In addition, we limit access to your personal data to those employees, contractors, associates and third parties who have a need to know that information in order to provide Products or services related to the Products to you.
• We restrict access to nonpublic personal information about you to those associates who need to know that information.
• In the event a breach occurs, we have implemented procedures to address any suspected personal data breach and will notify you and any applicable regulator of such breach based on our legal obligations to do so.
• In some instances, for reasons beyond the control of SmartLocker, information transmitted over the Internet may end up with an unintended recipient. Under such scenarios, you are advised that such transmission may not be secure.

10. DATA RETENTION
• SmartLocker will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
• In some instances, we may anonymize your personal data so it can no longer be associated with you.

11. YOUR LEGAL RIGHTS AND CHOICES
• Under certain circumstances, you have rights under data protection laws in relation to your personal information, including the CCPA (for California Residents), such as the right to:
o request access to your personal data
o request correction of your personal data
o request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions.
o object to processing of your personal data
o request restriction of processing your personal data
o right to withdraw consent
o request that we disclose the categories of personal information we collected about you over the past 12 months
o request that we disclose the categories of sources for the personal information we collected about you over the past 12 months
• If you wish to exercise any of the rights set out above, please send a written request to privacymanager@SmartLocker.com
• In certain instances, your exercise of the rights above may result in your inability to use SmartLocker Products, services, and Product features.
• 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.
• We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation you your request to speed up our response.
• We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
o Complete the transaction for which we collected the personal information, provide a good or service or Product that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
o Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
o Debug products to identify and repair errors that impair existing intended functionality.
o Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
o Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
o 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.
o Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
o Comply with a legal obligation.
o Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• We endeavor to respond to a verifiable consumer request within forty-five (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.

12. 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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

13. 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 post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.