Privacy Policy

This Privacy Policy discloses the privacy practices applicable to personal information given by you to Safety NetAccess, Inc. (“SNA,” “we” or ”us”) via the website located at www.safetynetaccess.com (the “Site”) and all websites and services owned or operated by SNA or our partners and affiliates.

DATA COLLECTED & HOW WE MAY USE YOUR DATA; YOUR RIGHTS

We or our partners may collect and/or process personal information from you to assist with your requests, enhance your use of the Site and access to our services, or to communicate with you about our or our partners’ products and services. SNA is considered a “processor” of such information for applicable privacy laws on behalf of Choice Hotels International Services Corp., Inc. On occasion, SNA may collect additional personal information from users in optional survey forms. We will not disclose any of your personally identifiable information (“PII”) unless (a) you authorize us to do so, (b) we are legally obligated to disclose such information to protect our rights, or (c) as part of a transfer of all or substantially all of our assets in the event that SNA is sold to another entity.

SNA does collect information in aggregate form that we may, from time to time, provide to partners, customers and other third parties. If and when this is done, SNA will not include any PII. Only SNA employees or agents are provided access to your PII, and such employees and agents are obligated to maintain the confidentiality of such information. SNA also logs IP addresses, or the location of your computer on the Internet, for systems administration and troubleshooting purposes.

You have the right to access your personal information that we or our partners may collect and/or process, and we will comply with applicable laws regarding such disclosure. To access your personal information, contact us at (888) 636-5212 or at www.safetynetaccess.com/PrivacyPolicy.

SECURITY & LIABILITY

We will use commercially reasonable measures to protect the security and integrity of your personal information. While we have taken reasonable steps to limit the uses of information provided by you to those described in this Privacy Policy, we cannot guarantee that the information will remain permanently secure. We shall not be responsible for the loss or disclosure of your information due to errors in transmission or the unauthorized acts of third parties, unless caused by our gross negligence or willful misconduct. SNA is not responsible for the content or the privacy policies of websites to which SNA or related products or services may link.

If you would like us to remove your name, email address or other information from our database, you may notify us by calling (888) 636-5212 or completing the form at www.safetynetaccess.com/PrivacyPolicy and we will promptly remove all such information from our database.

LINKS TO OTHER SITES

We may provide links to Web sites, advertisers and resources outside of our Site for your informational purposes. You will be notified when you are about to link to a site other than one owned or operated by SNA. You acknowledge and agree that SNA is not responsible for the availability of such sites or resources, and SNA does not endorse and is not responsible or liable for any content, advertising, goods, services or other materials on, available through or provided by such sites or resources. These other sites may send their own cookies to you, collect data or solicit personal information from you. The privacy policies and terms of use of other sites may be significantly different from the Terms of Use and Privacy Policy on our Site. We are not

responsible for the privacy or other practices of such sites and cannot guarantee the security of any of your personal information that you provide or is collected by such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites.

COOKIES

Visitors to and users of SNA’s Web sites may be issued a “cookie,” which is a small text file placed on your hard drive to enable our systems to recognize your browser. This feature ensures that we can better serve you when you return to the SNA Site in the future. Cookies help to prevent you from repeatedly being asked to register or made to re-enter your password every time you visit the Site. Cookies are also used to authenticate your identity. No cookie delivered by SNA will interfere with the operation of your computer. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Because cookies will allow you to take full advantage of SNA’s products and services, we suggest that you leave them on.

CALIFORNIA RESIDENT RIGHTS

If you are a California resident and are accessing our services from a location within the state of California, you have the rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of personal information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy_support@safetynetaccess.com.

1. ACCESS

You have the right to request certain information about our collection and use of your personal information over the past twelve months. We will provide you with the following information:

· The categories of Personal Information that we have collected about you;

· The categories of sources from which that personal information was collected;

· The business or commercial purpose for collecting or selling your personal information;

· The categories of third parties with whom we have shared your personal information; and

· The specific pieces of personal information that we have collected about you.

If we have disclosed your personal information for a business purpose over the past twelve months, we will identify the categories of personal information shared with each category of third-party recipient.

2. DELETION

You have the right to request that we delete the personal information that we have collected from you. Under the CCPA, the right is subject to certain exceptions: for example, we may need to retain your personal information to provide you with the services or complete a transaction or other action you have requested, or to comply with our legal obligations. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

3. EXERCISING YOUR RIGHTS

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will use personal information provided in a Valid Request only to verify you and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods: · Email us at: privacy_support@safetynetaccess.com.

· Call us at (888) 636-5212.

· Submit a request using our Contact Us form.

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to do so, and we may request a copy of this written permission from your Authorized Agent when they make a request to exercise your rights on your behalf.

4. WE WILL NOT DISCRIMINATE AGAINST YOU FOR EXERCISING YOUR RIGHTS UNDER THE CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of personal information that we receive from you.

5. OTHER PRIVACY RIGHTS

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

MISCELLANEOUS

SNA cannot guarantee the identity of any other users with whom a user may interact in the course of using the Site or who may have access to a user’s data. Additionally, we cannot guarantee the authenticity of any data that users may provide about themselves.

We reserve the right to modify this policy at any time, and without prior notice, by posting an amended Privacy Policy and terms on this website. We encourage you to review this policy periodically for any updates. Your continued use of the Site following the posting of changes to these terms will mean you accept the Privacy Policy and any changes.

ZOOX TECHNOLOGIES

Your data will also be collected by our partner Zoox Technologies Inc. This information may include your IP address, name, city/state/country, email address, gender, other demographic information, information about when you connect to this wireless network, your browser type and version, your operating system, and other similar information. This information will be used for marketing purposes (including but not limited to promotional emails and website personalization) within the Zoox hotel network. The use and disclosure of personal information by Zoox is described in this document and in the Zoox Privacy Policy at www.zooxsmart.com/XXXXX.

If you have questions or comments about our Privacy Policy, please contact us at:

Safety NetAccess, Inc.

114 Gould Street

Needham, MA 02494

(888) 636-5212 privacy_support@safetynetaccess.com

Effective January 1, 2020

© 2020 Safety NetAccess, Inc. All rights reserved.