Privacy Policy.
Your data, handled with care.

Orbee, Inc. and our affiliated companies ("we", "us", "our", or "Orbee") provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of our services. This Privacy Policy applies to all information that has been provided to us through our websites (collectively, our "Sites") or in the process of providing services (our "Services") to our customers and visitors.

This Privacy Policy may be updated from time to time. The most updated version of the Privacy Policy is available at [domain]/agreements.

We will notify you of any material changes by posting the new Privacy Policy wherever it may appear on our Sites, and give you notice that the Privacy Policy has been updated.

You should consult this policy regularly for any changes, and it is your responsibility to become aware of and understand them.

For the purposes of this policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

Notice to California Residents

Our use of your information is subject to the Orbee "Privacy Notice for California Residents". If you are a California resident, please refer to that document for information on how we collect and use your personal information, and your rights under California law.

Information, Collection, and Its Use

We collect information to provide and improve our Sites, our features, to administer accounts, and to provide our Services. This information can be personally identifiable, non-identifying, and include information relating to your device and activity, or of your own customers and their respective personal information. Please see the "What Kinds of Information We Collect" for more details on what we collect.

We collect this information when you use the Services. For example, we collect information before you start using our Services, including for account registration, to create, share, or request feedback, or message and communicate with us.

Depending on your privacy settings, we collect information about your computer and other devices you use to take part in the Services. We may associate device data to provide consistent Services, and to provide a secure environment for users. This can include collecting your device identifiers, location data, and IP address to verify registered users.

We collect information when you visit or use third-party websites that are associated with, or linked to our Sites and Services.

Depending on your permissions and third-party privacy policies, we may also receive information about you and your activities from our third-party partners, such as information a partner collects as part of jointly-offered services.

This Privacy Policy does not apply to collection or practices of third-parties that we do not own or control, including third-party providers used in connection with the Services. While we attempt to only work with third-parties that share our policies, we cannot take responsibility for the policies or practices of third-parties. If we work with any third-parties with data and information policies that are different than our own, we will notify you before those policies affect you. Regardless, we strongly encourage you to review third-party privacy policies before using their services or sharing your personal information.

What Kinds of Information Do We Collect?

Personally Identifiable Information

In the course of using the Services, we may ask you to provide us with, or grant us access to, or permission to obtain, certain personally identifiable information that can be used to contact or identify you or your customers. Personally identifiable information may include, but is not limited to, legal names, email addresses, mobile phone numbers, sex/gender, dates of birth, and billing or shipping address information (your "Personal Information").

We collect Personal Information in connection with your registration to form an account, and to participate in certain Services.

We may also use your Personal Information to contact you with newsletters, updates, marketing or promotional materials and other information that may be of interest to you. If at any time you decide you no longer wish to receive such communications from us, please unsubscribe from further messages from any "Unsubscribe" function we provide, update your Account's "Notifications" settings, or write to us at privacy@orbee.com.

We may also collect Personal Information about you, such as your name, email address and mobile number when you provide feedback on the Services.

If we collect Personal Information to provide a specific Service, we will only use that information to provide the Service, and will not share that information with any third-party, including our third-party providers, except as necessary to provide the Service or as you have agreed.

If you provide us with Personal Information about your customers, such as to provide Services for your customers, we will only use this information for the specific reasons they provided the information, and solely for the purposes of the Services.

We use Personal Information (in some cases, in conjunction with Non-Identifying Information defined below) to provide the Services, send information about the Sites or Services, and to respond to and administer inquiries and requests.

Non-Identifying Information

We may also collect other information as part of registration for, and use of, certain Services, such as your ZIP or postal code, geographical data, birth month or day (but not both), and individual preferences ("Non-Identifying Information").

Certain Non-Identifying Information would be considered a part of Personal Information if it were combined with other identifiers (for example, by combining a ZIP or postal code with a street address) in a way that enables a person to be identified. Those same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information, such as your viewing preferences.

We may use Non-Identifying Information for any lawful purpose, including by aggregating Non-Identifying Information from multiple users to provide better or more personalized user experiences, to improve the quality and value of the Services, and to analyze and understand how our Services are used.

Log Data

When you visit the Site, regardless of whether you are a registered user or a non-registered visitor, our servers automatically record information that your browser sends about your visit ("Log Data"). Log Data may include information such as your computer's or device's Internet Protocol ("IP") address, browser type, or the webpage you were visiting before you came to a Site, pages of our Sites that you visit, the time spent on those pages, information you search for on our Sites, access times and dates, and other statistics. We use this information to monitor and analyze use of our Sites and their technical administration, to increase Service functionality and user-friendliness, and to better tailor it to visitors' needs. For example, some of this information is collected so that when you visit our Sites, we will recognize you and serve information appropriate to your interests. We also use this information to verify that visitors meet the criteria required to process their requests. Log Data may be treated as Personal Information, but we may aggregate, analyze and evaluate such information for the same purposes as for Non-Identifying Information.

Cookies

Like many website operators, we may use "cookies" to collect information. A cookie is a small data file that we transfer to your device's hard disk for record-keeping purposes. We will use cookies for two purposes. First, we may utilize persistent cookies to save your registration ID and login password for future logins to the Sites. Second, we may utilize session ID cookies to enable certain features of the Services, to better understand how you interact with our Sites, or Services and to monitor aggregate usage by users and web traffic routing. Unlike persistent cookies, session cookies are deleted from your computer or device when you log off from your Account and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or certain functionalities of our Services.

Notice About Identity Theft & Phishing

Identity theft and the practice known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request or provide your Personal Information, including credit card information, login passwords, or identification numbers, such as your driver's license number or Social Security number, in any communication.

For more information about phishing, visit the Federal Trade Commission's website here: https://www.consumer.ftc.gov/articles/0003-phishing.

CalOPPA Disclosure & Tracking

We do not currently respond to web browser "Do Not Track" settings that allow you to opt-out of information collection.

Who Do We Share Your Information With?

The following list describes with whom we may share your information, including your Personal Information, and for what purposes. You may opt-out of any information disclosure by contacting us at privacy@orbee.com. If you choose to opt-out of any disclosure of your information, however, you may not be able to use all portions of the Site or certain functionalities of our Services.

Registered Users

When you register to join our Services, you must submit Personal Information to create an account. You can choose what other Personal Information you provide in connection with our Services that may be shared with other users. Providing this information is voluntary and you should only share as much as you would like to share with others.

Trusted Partners

We may share generic, aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with our trusted business partners, affiliates, or advertisers for industry analysis, demographic profiling and other similar commercial purposes. Any aggregated information shared in these contexts will not contain your Personal Information. We will only share your Personal Information with our business partners for specific purposes, and only after receiving your prior consent to whom and for what purposes the information is shared.

Third-Party Providers & Subcontractors

We engage and utilize third-party service providers, and other third-party companies and individuals to facilitate our Services, to provide certain Services on our behalf, such as payment processing services, maintenance services, and to assist us in analyzing how our Services are being used. These third-parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may access, read, preserve, or disclose any information about you to government or law enforcement officials or private third-parties as we, in our sole reasonable discretion, believe is necessary or appropriate to (a) respond to, or satisfy, applicable law, regulations, claims, court orders, and legal process (including but not limited to subpoenas); (b) follow and enforce our terms of Service, including this Privacy Policy, or to investigate any suspected violations; (c) detect, prevent, or address fraud, security, or technical issues; (d) to protect the property, rights, or safety of the public, us, our users, or any third-party; or (e) to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.

Parties to Business Transfers

We may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy, to third-parties.

No Other Uses

Except as expressly set out in this Privacy Policy, we will not share, sell, trade, or rent any of your Personal Information to any third-party for any purpose.

How to Change or Delete Your Information

We will retain your information for as long as you have an account, or as needed to provide a Service. All users may review, update, correct or delete their Personal Information.

If you would like us to terminate your account, to stop using your information, or otherwise makes changes to, or delete your information in our systems, please contact us at privacy@orbee.com, or use the functionalities we provide through our Sites to do so. We will use commercially reasonable efforts to honor your request as soon as possible.

However, we reserve the right to retain an archived copy, which is not accessible to third-parties, of your records and information as required by law, to maintain accurate business records, resolve disputes, or enforce our agreement with you.

How We Secure Your Information

We are very concerned with safeguarding your information. However, we are not in the business of providing information security, and cannot guarantee perfect security over your information. We do however employ commercially reasonable data collection, storage, processing practices, and security measures, such as using SSL encryption on some but not all systems to protect against unauthorized access, use, loss, alteration or destruction of your Personal Information.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on our Sites as soon as commercially practicable, and without unreasonable delay, so long as those disclosures are consistent with (a) the legitimate needs of law enforcement; or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Do not provide us with your information if you are concerned with its disclosure or its security, or any of our policies described in this Privacy Policy.

Notice to California Residents

If you are a resident of the State of California, U.S.A., your Personal Information is subject to the California Consumer Privacy Act (the "CCPA").

Our use of your information is fully intended to fully comply with the CCPA. Please consult our Orbee "Privacy Notice for California Residents" (the "CCPA Notice") for more information on additional rights and protections you have under the CCPA regarding your Personal Information.

If there is any conflict between the terms of this Privacy Policy and the CCPA Notice, the terms of the CCPA Notice will take precedence at all times.

Notice Regarding International Transfer of Information

Your information may be transferred to and maintained on computers and systems located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.

If you are located outside the United States and choose to provide information to us, you agree that your Personal Information will be transferred to the United States and processed there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links to Other Sites

Our Services may provide links to other websites. If you click on another third-party link, you will be directed to that third-party's website. The fact that we link to a third-party website is not an endorsement, authorization or representation of our affiliation with that third-party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Our Policy Towards Children

Protecting the privacy of children is especially important to us, and we strictly comply with the FTC's Children's Online Privacy Protection Rule ("COPPA"). Our Services are not directed to, or meant for persons under the age of 13. We do not knowingly collect or solicit personally identifiable information from children under 13, or allow them register accounts. If we become aware that a child under 13 has provided us with Personal Information, or any user has provided information of or about any person under the age of 13, we will delete such information from our systems. Do not submit any Personal Information to us if you are under the age of 13, or any information of, or about, persons under the age of 13.

If you are a parent or guardian and you become aware that your child has provided us with Personal Information without your consent, you should contact us immediately at privacy@orbee.com, or use the contact functionality we provide through your account or on the Site to request we delete your child's information.

Contact Us

If you have any questions regarding this Privacy Policy, or our practice and procedures about your information, please contact us at (855) 949-2049 or privacy@orbee.com, or use the contact links and functionalities we provide through your account or on our Sites.

This Orbee Privacy Notice for California Residents (this "Notice") applies to Orbee, Inc., and our affiliated companies ("we", "us", "our", or "Orbee").

If you are resident of California, our collection, handling, and processing of your personal information is subject to the California Consumer Privacy Act (or, "CCPA") in addition to other federal and state privacy laws. Our use of your information is fully intended to fully comply with the CCPA.

This Notice describes our privacy practices regarding the collection, use, disclosure, and sale of personal information of California residents, and what your rights are as consumer regarding your personal information.

This Notice applies to all personal information that you provide directly to us, or which our business partners may have collected about you and shared with us as their service provider.

This Notice does not apply to independently operated websites, applications, or services of third-parties, or their own practices.

We will update this Notice from time to time if there is a change in applicable law, or if there is a change to the way we treat your personal information.

We will notify you of any material changes to our policies by posting the updated Notice wherever it may appear on our websites, and give you notice that the Notice has been updated. At that time, we will change the date of this Notice and provide other required information.

Our contact information is included at the end of this Notice.

Capitalized terms which are not defined in this Notice have the same meanings in Privacy Policy, or the CCPA. If there is any conflict between the provisions of this Notice and those of our Privacy Policy, the terms of this Notice will control.

What Is Personal Information?

For the purposes of this Notice, "personal information" means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you as a person or your household.

Examples of personal information include your real name, nicknames or aliases, email addresses, Social Security number, driver's license number, or other similar identifiers. Personal information can also include commercial information about products you have purchased or are considering purchasing, and your browsing history and activity on websites on the Internet.

Personal information does not include publicly available information from government records, or information which about yourself or your household which is covered and regulated under other existing laws, such as personal information collected, processed, sold, or disclosed under the Gramm-Leach-Bliley Act, Fair Credit Reporting Act, Driver's Privacy Protection Act of 1994, or the California Financial Information Privacy Act.

Personal information does not include information about a consumer which has been de-identified or aggregated so that it cannot be associated or linked, whether directly or indirectly, to a consumer.

For the purposes of this Notice, a "consumer" is any natural person who resides in California. However, a consumer does not include persons who are job applicants, or act as employees, owners, directors, officers, or medical staff members of Orbee or any contractor or entity that does business with Orbee, or any persons whose information is collected and used for purposes of having an emergency contact or to administer benefits for any of those persons.

Categories of Personal Information We Collect

The types of personal information Orbee collects about consumers depends on the services we provide, and the different purposes we have for that information.

We share consumers' personal information with our own service providers and subcontractors that provide services to us and process personal information on our behalf.

We disclose personal information as needed to comply with applicable law, legal process, to cooperate with law enforcement, and to make and defend legal claims.

We may also share personal information about consumers with third parties in connection with the sale or transfer of some or all of our assets, including personal information, in connection with merger, acquisition, reorganization, sale of assets, or bankruptcy of Orbee.

The following are the categories of personal information we may have collected in the last 12 months, information we currently collect, and information we may collect in the future. Each category includes (1) plain language descriptions of the type of information we collect; (2) common examples of the information; (3) the sources from where or from whom the information was collected; (4) our business purposes for collecting the information; and (5) third parties who we share the information with.

Sales of Personal Information

We do not sell personal information that has been shared with us, nor have we sold any personal information in the past 12 months.

We do however share and disclose personal information with our own service providers and subcontractors as needed in order to perform services that consumers have authorized, and as our business partners have requested we provide.

In order to perform any requested services, we may have disclosed the following categories of personal information with our own service providers and subcontractors:

• Contact Information
• Online Activity
• Commercial Information
• Consumer Background Information

Under the Children's Online Privacy Protection Act and the CCPA, we do not collect any personal information from any person under the age of 16.

None of our services, or our use of any consumer's personal information is directed to, or meant for persons under the age of 16. We do not knowingly collect or solicit personal information from persons under 16 years of age. We will not collect, sell, or share any information about a consumer under the age of 16 without prior affirmative authorization.

Your Rights Under the CCPA

As a California resident, you may have certain rights under the CCPA regarding any personal information we may have collected about you. This section of the Notice explains those rights, and any exceptions that may apply to you.

If you are a California resident, please see the following section titled "Making a Verified Request" if you want to exercise any of your rights under the CCPA.

"Right to Know" Personal Information Collected, Disclosed, or Sold

You may have the right to request that Orbee provides you with information regarding what information we may have collected, used, disclosed, or sold in the previous 12 months. If you make such a request, and we can verify your identity, we will provide you the following:

• Specific pieces of personal information we collected about you in the previous 12 months
• Categories of personal information we collected about you in the previous 12 months
• Categories of personal information we either sold or disclosed for a business purpose in the previous 12 months
• Categories of third parties to whom your personal information was sold or disclosed in the previous 12 months

Please keep in mind that giving access to your personal information to the wrong person is a serious matter that we take very seriously.

Please also note that we may only collect personal information about consumers because we work with dealership businesses who have collected the information and requested that we, as service providers, process that information on their behalf according to their instructions. This includes using your personal information for services that you may have asked them to perform.

For those reasons, unless we have collected your personal information ourselves (and not just received them from a dealer business whom you have instructed or authorized to share your personal information with us), we may deny a request unless we either receive confirmation from a business dealer that a verified request has been made, or the dealer directly requests we do so upon verification. In those cases, we will explain why we cannot fulfill your request.

In any event, you will be required to verify your identity, and you may not make a verified request to know and access your personal information more than twice in any 12 month period.

If we cannot fulfill a request, we will provide the reason why in our response to you.

"Right to Request Deletion" of Personal Information

You may have the right to request that Orbee delete any personal information that we may have about you, subject to certain exceptions under the CCPA.

If you make a request to delete your personal information, and we can verify your identity, we will delete (and direct our service providers and subcontractors to delete) any personal information we may have about you.

We may deny a request to delete personal information when it is necessary for us to maintain the personal information, including for the following reasons:

• To complete a transaction for which the personal information was collected, provide a good or service which you requested, or as reasonably anticipated within the context of a business' ongoing business relationship with you, or otherwise perform a contract between the business and you
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity
• Debug to identify and repair errors that impair intended functionality
• Any other exceptions under the CCPA

If we deny a request to delete personal information, we will provide the reason why in our response to you.

When we fulfill a request to delete personal information, we will inform you how we deleted the personal information, which may be by de-identifying or aggregating the personal information.

"Right to Opt-Out" of the Sale of Personal Information

We do not sell personal information to third parties. If this changes in the future, we will give notice of updates to our Privacy Policy and this Notice, and you will have the right at any time to direct Orbee to stop selling some or all of your personal information to third parties.

The right to opt-out is separate from any direct marketing or advertising communications which dealer businesses request we send to you.

You do not need to submit a request to opt-out for any personal information which has been collected before this Notice goes into effect; you are considered to have automatically opted-out from the sale of any this personal information.

If you would like to opt-out of the sale of some or all of your personal information by dealer businesses to third parties, you should submit a verified request to the dealer who you collected your personal information.

If we are the service provider who assists any dealer business to fulfill a consumer's request to opt-out of the sale of personal information, we will provide you a webform for submitting your request, as well as instructions for any alternate methods for opting-out.

Similarly, if you have already opted-out of the sale of your personal information by a dealer business, and we are the service provider who assists a dealer business to fulfill a transaction where the sale of your personal information is required as a condition of completing the transaction, we will send you notice of this with instructions on how to opt-in.

Any authorized agents who make a request to opt-out on your behalf will be asked to submit written proof that you have authorized the agent to make the request.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of your privacy rights under the CCPA. If you are a California consumer, this means Orbee will not discriminate against you for exercising any of your rights described in this Notice.

This means that we will not deny you goods or services, charge you different prices or rates for goods or services (including by offering discounts or charging penalties), provide you with a different level of goods or services to you, 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.

We do not offer any financial incentives or differences in services for retaining your personal information.

Making a Verified Request

Effective January 1, 2020, if you are a California resident and would like to exercise any of your rights under the CCPA regarding your personal information, you may make a request by calling us at (855) 949-2049, or by emailing us at privacy@orbee.com.

Please keep in mind that we need to verify your identity before we can process any request. We will not process any request to know or access personal information, or to delete any personal information, unless we confirm that the personal information relates to you. Similarly, if we have a good-faith, reasonable, and documented belief that a request to opt-out is fraudulent, we may deny the request and explain the reason why.

To verify your identity, we will ask you to provide personal information so that we can match you with any records we may have collected. We will only use your personal information in connection with your request and to comply with your request.

You do not need to have an account with us in order to make a verified request, but if you do, we may require you to submit your request through your account.

In any case, in order to verify your identity, we will ask you provide, at a minimum: your full name; email address; and phone number or mailing address. In the alternative, we may ask you to verify your identity through an independent third-party service.

Depending on the nature of the request you make, or if we suspect fraudulent or malicious activity in connection with a request, we may ask you to provide additional information as part of our verification process.

We may deny your request if we cannot verify your identity and will inform you of that fact.

If we can verify your identity, we will respond to your request within 45 days. However, we may require an additional period of time to process a request in certain circumstances. If an extension of time is needed, we will let you know within 45 days after receiving your request and the reason why the extension is needed.

Authorized Agents

You have the option to designate an authorized agent to submit a verified request on your behalf. However, we will deny any request from any agent unless they have been registered with the California Secretary of State, have your written permission to make a request, or have a valid power of attorney pursuant to California Probate Code. We may require that you verify your identity with us directly, and we may need to contact you directly to verify the request.

If you are an agent of a California consumer, we will deny any request if you cannot submit written proof that you have been authorized to act on behalf of a consumer.

Contact Us

If you have any questions or concerns about this Notice, our privacy practices, want to make any request under this Notice, or if you are a consumer with a disability and would like to receive a copy of this Notice in an alternative format, please contact us by calling (855) 949-2049 or send us an email at privacy@orbee.com.