Connexion Telematics Ltd., (“Connexion” or “We”) respects your privacy and are committed to protecting it through our implementation of this policy. This Privacy Policy (the “Policy”) outlines the type of information we may collect from you or that you may provide when you use store.connexionltd.com or app.cxztrac.com  (each a “Website”) and how we use that information, as well as our practices for collecting, using, maintaining, protecting, and disclosing various information. Certain jurisdictions afford their residents unique rights with respect to Personal Information (defined below) and Sensitive Personal Information (defined in applicable laws, rules, and regulations); where applicable, those rights are identified below. This Policy applies to information we collect:

• On the Website
• In electronic communications, such as e-mail and text messages, between you and this Website
• Through any third-party application by which you access data on this Website

It does not apply to information collected by:  

• Us offline or through any other means, including on any other website operated by Connexion or an entity affiliated with Connexion.
• Any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. This Privacy Policy aims to give you information on how Connexion collects and processes your Personal Information (defined below) through your use of this Website, including any data you may provide through this Website when you sign up to our newsletter, or purchase a product or service.   If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using the Website, you agree to this Policy. This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy from time to time for updates.   You may contact us regarding this policy at: Email: enquiries@ec2-44-233-51-49.us-west-2.compute.amazonaws.com Website: www.connexionltd.com/privacy   Information We Collect & How We Collect It. We collect several types of information from and about users of our Website, including information:  

• By which you may be personally identified, such as name, postal address, e-mail address or telephone number (“Personal Information”)
• That is about you but individually does not identify you
• About your internet connection, the equipment you use to access our Website, and your usage details
• About your computer and internet connection, including your IP address, operating system, and browser type.

We collect this information:  

• Directly from you when you provide it to us.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

Information You Provide To Us. The information we collect on or through the Website may include:  

• Information that you provide by filling in forms on the Website.
• Records and copies of your correspondence to us and ours to you.
• Details of transactions facilitated by the Website.

Information We Collect Using Automatic Data Collection Technologies. As you interact with the Website and other websites, we may use automatic data collection technologies to collect certain information about you, your hardware, your software, your interaction with the Website, and other data, including:

• Details of your visits to the Website, including your location, what pages you visit and links you follow, the length of time spent on each page, and other data regarding your interaction with the Website.
• Information about your device and internet connection, such as what browser you are using and the IP address from which you’re accessing the Website.

The information we collect automatically is not in and of itself Personal Information or Sensitive Personal Information, but we may synthesize it with Personal Information either collected by us from you as described in this Policy or obtained from third parties. This integration of information helps us to improve the service we offer by:  

• Knowing more about our audience, including usage patterns.
• Customizing the Website so that it is easier for you to use.
• Enhancing our searches so they are more responsive to you.
• Recognizing you when you return to the Website.

The technologies we may use for automatic data collection include cookies, web beacons, and tracking pixels. In addition, third parties may serve some content on the Website and may use  automatic data collection technologies to facilitate the service or services they provide. These third parties may collect information associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.   California residents may have additional rights regarding our use of automatic data collection technologies. Please see the section below regarding California Privacy Rights for more information.   Use of Your Information. The information we collect helps us to improve the Website and to deliver a better and more personalized service by enabling us to:

• To register you as a new user
• To process and deliver your services, manage payments, fees, and charges
• To manage our relationship with you
• To administer and protect our Website
• To deliver relevant Website content to you
• To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences
• To estimate our audience size and usage patterns, and other analytics
• To improve the performance of the Website
• To recognize you when you return to the Website
• To carry out any obligations and enforce any rights arising from any agreements entered into between you and us, including for billing and collection
• To notify you about any changes to the Website or any products or services we offer through it
• To send marketing communications to you
• To take other actions which we may describe when you provide the pertinent information
• For any other purpose with your consent

Disclosure of Your Information. We may disclose aggregated information about our users in general, and information which does not identify any individual, without restriction. We may disclose Personal Information that we collect or that you provide to us as described in this Policy:  

• To our subsidiaries and affiliates
• To contractors, service providers, and other third parties we use to support our business
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Connexion’s assets
• To fulfill the purpose for which you provide it
• For any other purpose disclosed by us when you provide the information
• With your consent
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request
• To enforce or apply our Terms of Use http://ec2-44-233-51-49.us-west-2.compute.amazonaws.com/terms-of-use/ and other agreements, including for billing and collection purposes
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Connexion’s employees and associates, our customers, or any other individual or entity

Your Information; Your Choices. We make every effort to provide you with as many choices as possible regarding use of the Personal Information and sensitive Personal Information you provide to us. We have identified the following processes to provide you with control over your information:  

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.

• Disclosure of Your Information for Third-Party Advertising. We do not share your Personal Information with unaffiliated or non-agent third parties for promotional purposes. In the event this changes, should you wish to opt out from such disclosure, you may contact us using the methods identified in this Policy at any time.

• Promotional Offers from the Company. If you do not wish to have your Personal Information used by the Company to promote our own or third parties’ products or services, you can opt-out by replying to a marketing email with “unsubscribe” in the subject line, clicking “unsubscribe” in the marketing email itself, or by contacting us using the methods identified in this Policy at any time.

California residents may have additional rights regarding use of Personal Information. Please see the section below regarding California Privacy Rights for more information.   Accessing and Modifying Your Information.   If you have or maintain an account profile, you can review and change any information associated with that profile.   You may send us an email at enquiries@ec2-44-233-51-49.us-west-2.compute.amazonaws.com to request access to, to correct, or to delete, any Personal Information you have provided to us. We may not be able to delete your Personal Information without also deleting any account associated with your Personal Information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement, or cause remaining information to be incorrect.   Policy Towards Minors. Our Website is not intended for children under 13 years of age. No one under the age of 13 may provide any information to or on the Website. We do not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, do not use or provide any information on this Website or on or through any of its features/register on the Website. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at enquiries@ec2-44-233-51-49.us-west-2.compute.amazonaws.com.   Changes to this Privacy Policy. We will update any changes in how we treat your Personal Information on this page with a date on which such update was published. It is your responsibility to visit this page from time to time and to make sure you fully understand how we treat your Personal Information. Your continued use of the Website following the posting of changes constitutes your acceptance of such changes.   California Specific Information   This component of the Privacy Policy applies solely to California residents, though some of the rights in this section are similar to rights of users residing in other jurisdictions (such as the European Union) as well:  

• “Personal Information” includes 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. “Personal Information” does not include:
  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach-Bliley Act (“GLBA”), and California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994.

The Website has collected the following categories of Personal Information from consumers within the past twelve months. If we have collected it, we may share it for a business purpose as set forth below pursuant to written agreements between us and the recipient which set for the specific conditions and uses for such information. We do not sell your Personal Information.  

Category	Examples	Collected	Business Purpose Disclosures	Sales
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes	To affiliates to use solely in furtherance of our objective for obtaining the information and for no other purpose.	None
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes	To affiliates to use solely in furtherance of our objective for obtaining the information and for no other purpose.	None
C. Protected classification characteristics under California or federal law.	Age (if over 40), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes	To affiliates to use solely in furtherance of our objective for obtaining the information and for no other purpose.	None
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	To affiliates to use solely in furtherance of our objective for obtaining the information and for no other purpose.	None
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	None	None
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes	To affiliates to use solely in furtherance of our objective for obtaining the information and for no other purpose.	None
G. Geolocation data.	Physical location or movements.	Yes	To affiliates to use solely in furtherance of our objective for obtaining the information and for no other purpose.	None
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes	To affiliates to use solely in furtherance of our objective for obtaining the information and for no other purpose.	None
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No	None	None
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	None	None
K. Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No	None	None

• We obtain the categories of Personal Information listed above from the following categories of sources:
  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on the Website.
  • From third parties. For example, if you are applying for a job and authorize us to obtain Personal Information about you from a third party.

• Your Rights and Choices. The California Consumer Privacy Act (“CCPA”) provides California residents specific rights regarding your Personal Information. This section describes those rights and explains how we will work with you to exercise those rights.

• Right to Know and Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the preceding 12 months (your “Right to Know”). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • Sales, identifying the Personal Information categories that each category of recipient purchased; and
  • Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
• The specific pieces of Personal Information we collected about you.
  • Right to Delete. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (your “Right to Delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain certain information applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected your Personal Information, provide a good or service 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 fulfill any contractual obligations we have to you.

2. Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or preserve information so that law enforcement agencies may prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another user to exercise their free speech rights, or exercise another right provided for by any local, state, or federal law, rule, or regulation.

5. 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.

6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

7. Comply with a legal obligation.

8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Alternatively, we may delete your Personal Information from our database so that your Personal Information is not searchable, but maintain the original document containing your Personal Information if we, in our sole discretion, determine that it is necessary for us to do so in order for us to comply with legal or contractual obligations.   We will delete or deidentify Personal Information not subject to one of the above exceptions from our records and will direct our service providers to take similar action.  

• How to Exercise Right to Know and Right to Delete. You may exercise the rights summarized above by contacting us at privacy@ec2-44-233-51-49.us-west-2.compute.amazonaws.com. Only you, or someone legally authorized to act on your behalf, may exercise your Right to Know and/or Right to Delete. You may exercise your minor (under the age of 18) child’s Right to Know and/or Right to Delete. You may only submit two Right to Know requests in any twelve-month period. Each request must: (i) provide sufficient information to enable us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

• Right to Opt-Out or Opt-In. We currently do not sell Personal Information. However, if you are age 16 or older, you have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-Out”). We do not sell the Personal Information of consumers we actually know are less than 16 years old. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing us at enquiries@ec2-44-233-51-49.us-west-2.compute.amazonaws.com.

• 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.
  • However, we may offer you certain financial incentives permitted by the CCPA which may result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.