NOA TECHNOLOGIES PRIVACY POLICY

EFFECTIVE DATE: 2017-01-01

We are committed to protecting your privacy. We created this Privacy Policy (“Policy”) to give you confidence as you use our hardware, mobile application, website, and any related services provided by us, whether used offline or online (collectively, the “Services”). This Policy covers how we collect, use, store, and share your information when you use our Service. The provisions of our Terms of Service (https://rider.noa.one/terms-of-service) apply to this Policy as well. All references to “we”, “us”, “our”, or “Noa” refer to Noa Technologies, Inc., a Delaware corporation, and its subsidiaries and affiliates. All references to “Customer”, “you”, “your”, or “user” refers to the end-user of the Services, as well as any corporation or other legal entity that uses the Services on whose behalf you accept the Terms of Service and this Policy. In the event that the Services are used by a corporation or other legal entity, you represent and warrant that you are authorized to, and hereby do, accept this the Terms of Service and this Policy on such corporation or other legal entity’s behalf. Do not hesitate to contact us at support@noa.one if you have any questions or want to discuss this Policy.

INFORMATION WE COLLECT AND HOW WE USE IT.

As specified in more detail below, we only collect information that is relevant to providing and improving the Services.

Required Information You Voluntarily Provide Us. When you sign up for an account through the Services, you will be required to provide us with various information that is, or may be, considered personally identifiable information, including your name, email address, and phone number. We use this information for the purpose of providing you with the core aspects of the Services.

Optional Information You Voluntarily Provide Us. In addition to the required information that you provide to us to create an account, there are various pieces of information you can, or may in the future be able to, choose to provide through the Services.

We may also collect and store communications that occur through the Services or outside of the Services between you and Noa, and communications that occur through the Services between you and other users of the Service.

In addition, now or in the future, we may provide functionality that will allow you to choose to provide us with access to additional information such as your photos and geolocation, and other data inputs related to your use of the Services. We also may, now or in the future, allow you to provide us with access to additional information and data through integrations with third party goods and services.

The various categories of information in this subsection is, or may be, considered personally identifiable information, and is used for the purpose of providing you with the Services’ expanded functionality. While the information described here is not required to use the Services, some aspects of the Services may not be available if you choose not to provide us with such information.

Information Collected Automatically As You Use The Services. In addition to the information that you provide to use voluntarily, we collect information automatically through the Services, such as how you use and interact with the Services, your IP address, your unique device identifier, and data on activities that you pursue through the Services, and other similar activities.

Cookies. After you have created an account, we use cookies to remember you as a user of the Services and to streamline the functionality of the Services. These are first party cookies, not third party cookies, meaning that the cookies are only used to track your activity on the Services, and not on third party sites or services.

Other Anonymous Data We Collect. When you use and visit the Services, we may also use third-party analytics providers to collect generic, anonymous information that does not identify you. We use this information to better understand how users interact with the Services and to improve your user experience while using the Services.

Do Not Track Signals. We do not track you or collect your information across third party websites or online services. Thus, we do not receive Do-Not-Track signals, or other similar signals. To the extent that we do receive any such signals, we will not comply with them as it is not an aspect of the functionality of our Services.

HOW WE SHARE YOUR INFORMATION.

We do not sell or share your personally identifiable information with advertisers. We also do not share your personally identifiable information with other third parties except to the extent that it is in furtherance of the Services, as described below.

Information Shared Through The Services With Entity Customers. A fundamental aspect of the Services is for Customers organized as legal entities to understand how individual Customers affiliated with the legal entity, or who are customers of the legal entity, use the Services. As such, we may share individual Customers’ information with affiliated legal entity Customers. For example, a company that uses the Services to understand how its employees move around the company’s campus using Noa’s Services will have access to relevant personally identifiable information about the employee’s use of the Services; and a Customer organized as a legal entity that licenses the technology integrated into the Services may have access to their customers’ relevant personally identifiable information as such customers use the Services.

Information You Choose To Share Through The Services.  In addition, you may, now or in the future, be able to choose to voluntarily share information collected through the Services to other users, to public forums, to social media channels, through email or other means of communication, and others. In addition, now or in the future, we may choose to add features to the Services that will allow you to share your personally identifiable information (and other data) with other users, third parties, and the public through social networking sites or through the Services.

Our Personnel And Vendors. To be able to effectively provide you with the Services, and to improve the functionality of the Services, we may disclose your information to our employees, contractors, agents, vendors, and other similar persons or entities, to the extent that such persons or entities have a need-to-know such information in furtherance of the Services. For example, we may disclose your information to the cellular network providers used to transfer data through the Services, as well as to vendors engaged in hosting services, customer service, and other aspects of providing the Services.

Sale of Company or Assets. In the event that we sell all or substantially all of our company or its assets, including the user information collected through our Services, we may transfer your information to the acquiring company and will provide you with notice of such transfer.

Other Third Parties. In addition to our practices described above, we may share your information if we have a good-faith belief that such action is necessary to (1) comply with the law (see the section below on “Government Requests”), (2) protect and defend our rights or property, or (3) prevent an emergency involving danger of death or serious physical injury to any person.

Choice. In addition, you may contact us at support@noa.one to request that we do not disclose your personal information to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as data processors), or to request that your personal information not be used for a purpose that is materially different from the purposes for which it was originally collected or for purposes subsequently authorized by you.

STORING YOUR INFORMATION.

Storage and Retention Of Your Information. We only store your personally identifiable information for as long as is required to provide you with the Services, or as long as necessary to comply with applicable law. We will strive to delete your personally identifiable information when you delete your account or when you delete specific pieces of information from your account through your settings. However, to continue to provide an effective service, we may store non-personally identifiable information perpetually and may anonymize your personally identifiable information and store that anonymized information perpetually. It is important to note that if you delete the Services from your device without deleting your account or the information in your account through the Services, we may not know that you intended to terminate the Services and we will continue to store your information as if you were an active user.

Security. We use commercially reasonable efforts to secure your information and to attempt to prevent the loss, misuse, and alteration of the information that we obtain from you. For example, we require our personnel and third party vendors to sign confidentiality agreements that extend to your personal information and we restrict access to your personal information to individuals within and outside of Noa who need access to such information to provide the Services. In addition, we use reasonable technical safeguards such as encryption, and online secured private access, to secure your personal information. However, loss, misuse, and alteration may occur despite our efforts to protect your information. We are not responsible to our users or to any third party due to any such loss, misuse, or alteration, except as required by applicable law.

GOVERNMENT REQUESTS. From time to time, we may receive requests from government agencies to obtain information about our users. In handling such government requests, we greatly value the privacy of your information, however, we reserve the right to turn over user information when we receive government requests about your data.

THIRD PARTY SERVICES AND PRACTICES ARE BEYOND OUR CONTROL. Our Services utilizes numerous third party services as part of the functionality of the Services, such as hosting services, analytics providers, and other vendors; and we may share your information with third parties to the extent explained in this Policy. We do not control such third parties. Thus, we make no guarantees about, and assume no responsibility for, the information, services, or data/privacy practices of third parties, except as required by applicable law. We encourage you to review the privacy practices of such third parties.

PRIVACY SHIELD – INTERNATIONAL DATA TRANSFERS. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

Noa participates in, and complies with, the EU-US Privacy Shield Principles regarding the collection, use, sharing, and retention of personal information from the European Union. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Our participation in Privacy Shield applies to all personal data that is subject to this Policy and is received from the European Union. We will comply with the Privacy Shield Principles in respect of such personal data.

To learn more about Privacy Shield, please visit: https://www.privacyshield.gov/. To view a list of companies that have certified that they adhere to the Privacy Shield principles, please visit: https://www.privacyshield.gov/list. If you have a Privacy Shield-related question or complaint, please contact us at legal@noa.one.

As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Privacy Shield Principles, we will seek to resolve it through JAMS, an independent alternative dispute resolution body based in the United States. You can learn more about JAMS at the following URL: https://www.jamsadr.com/.

In certain circumstances, you may have the right to invoke binding arbitration under Privacy Shield, as described in Annex I to the Privacy Shield Principles, which can be found at the following URL: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Privacy Shield participants, such as Noa, are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, we may be liable for the transfer of personal data that we receive and subsequently transfers to a third party, as described in the Privacy Shield Principles.

As described in this Policy, we may share information with third parties and may be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Finally, you may contact us at support@noa.one to request access to your personal information to be able to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Privacy Shield Principles.

CHANGES TO THIS POLICY. Noa reserves the right to change this Policy from time to time, with or without notice to you. If you continue to use the Services, you consent to the new Policy. Noa will always have the latest Policy posted on the Services.