PRIVACY POLICY FOR TRAXGEO

Last updated: 5/2/2022

This Privacy Policy for TRAXGEO, Inc. (doing business as TRAXGEO) ("TRAXGEO,'’ "we" "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you: · Download and use our mobile application (Offender Mobile App), or any other application of ours that links to this Privacy Policy; · Engage with us in other related ways, including any payments, communication, or events. Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@traxgeo.com.
TABLE OF CONTENTS

WHAT INFORMATION DO WE COLLECT?

HOW DO WE PROCESS YOUR INFORMATION?

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

HOW LONG DO WE KEEP YOUR INFORMATION?

HOW DO WE KEEP YOUR INFORMATION SAFE?

WHAT ARE YOUR PRIVACY RIGHTS?

CONTROLS FOR DO-NOT-TRACK FEATURES

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

DO WE MAKE UPDATES TO THIS POLICY?

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us We collect personal information that you voluntarily provide to us when you register on the Services, when you participate in activities on the Services, or otherwise when you contact us. Account information: When you log in to your Offender Mobile App account, we collect your email address. We use this information for account identification and communication about the account status. Location information: When you run the Offender Mobile App mobile app on your device, we collect location data through GPS, Wi-Fi, or cellular triangulation. We use this information to provide location tracking service on our web site. We maintain this data only so long as is reasonable to provide our service. Payment information: We do not store your payment card details. When you make a payment to the Supervising Agency, that information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council. PCI-DSS requirements help ensure the secure handling of payment information:

§ Stripe

Their Privacy Policy can be viewed at https://stripe.com/privacy

HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including to facilitate account authentication and otherwise manage user accounts; to provide, improve, and administer our Services, communicate with you; for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share and disclose your personal information in following situations: · Compliance with laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). · Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company. · Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in the United States. If you are accessing our Services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in the United States and other countries. If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this Policy will require us keeping your personal information for longer than the period of time in which users have an account with us. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

WHAT ARE YOUR PRIVACY RIGHTS?

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html. Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS POLICY?" below. However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. Account Information If you would at any time like to review or change the information in your account, you can contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases, provided that you have discontinued using Offender Mobile App at the day of such request. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements. If you have questions or comments about your privacy rights, you may email us at info@traxgeo.com.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed Io third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e g., backups, etc.).

DO WE MAKE UPDATES TO THIS POLICY?

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Policy, you may email us at info@traxgeo.com or by post to: TRAXGEO, Inc. 600 Congress Ave., Austin, TX 78701 USA

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you. change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email us at info@traxgeo.com.