INTRODUCTION

VectorNav Technologies, LLC (referred to as "VectorNav", "we", "us" or "our" in this privacy statement) respects your privacy and is committed to protecting your Personal Data (as defined below). VectorNav, headquartered in Dallas, Texas, United States is the controller and responsible for this website and any Personal Data that is provided via this website.

"Personal Data", or personal information, means any information about a living individual from which that person can be identified, whether directly or indirectly. It does not include data where the identity has been completely removed (anonymous data).

This privacy statement describes how VectorNav collects, uses, and discloses your Personal Data that we receive from you when you visit this website (https://www.vectornav.com), or which we otherwise receive or collect from you in the course of, or in connection with, our business operations, including if you were to visit our premises and leave details.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy statement aims to give you information on how VectorNav may collect and process your Personal Data, including any data you may provide through this website if you place an order for a product or raise enquiries with us, through the website itself, by telephone and/or by email.

This privacy statement is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy statement together with any other privacy statement or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. This privacy statement supplements other notices and privacy policies and is not intended to override them.

CONTACT DETAILS

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Full name of legal entity: VectorNav Technologies, LLC

Email address: support@vectornav.com

Postal address: 10501 Markison Road, Dallas, TX 75238 USA

Telephone number: +1-512-772-3615

EUROPEAN REPRESENTATIVES

As VectorNav is based in the United States, it has appointed the following European Representatives:

Representative in EU European Union ("EU")

Instant EU GDPR Representative Ltd

Contact address: 69 Esker Woods Drive, Lucan, Co. Dublin, Ireland

Tel: +353 01 554970

Email: support@gdprteam.freshdesk.com

Representative in United Kingdom ("UK")

Instant EU GDPR Representative Ltd

Contact address: 20 – 22 Wenlock Road, London, N1 7GU

Tel: +441772 217800

Email: support@gdprteam.freshdesk.com

You can direct any questions or complaints about the use or disclosure of your Personal Data to us by contacting us as set out above. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data as soon as possible. If you are located in the UK or EU and are dissatisfied with the resolution of your complaint, you may contact the Information Commissioner’s Office in the UK or relevant EU data protection authority in your jurisdiction for further information and assistance.

CHANGES TO THE PRIVACY STATEMENT AND YOUR DUTY TO INFORM US OF CHANGES

VectorNav may update this privacy statement from time to time, and we reserve the right to do so to comply with applicable data protection laws. This version of our privacy statement was last updated on 4 August 2020.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if any of your Personal Data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

The type of Personal Data we collect about you will depend upon the nature of your relationship with us (e.g. whether you are a customer, prospective customer, job candidate, service provider, representative or visitor to our website or office, or you are meeting us at a trade or sales event).

We may collect, use, store and transfer different kinds of Personal Data about you or your employees, which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title and date of birth.
• Contact Data includes billing address, delivery address, email address, telephone numbers and fax numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about any payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol ("IP") address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, any purchases or orders made by you (i.e. purchase history), your feedback and any survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Recruitment Data includes:
• Contact details (including names, postal addresses, email addresses and telephone numbers);
• The information provided on through our third party recruitment software platform, Workable and on our application form, including name, title, address, telephone number, personal email address, date of birth, employment history, qualifications, interests (if requested), CVs/resumes, nationality and immigration status;
• Details of your referees; and
• For successful candidates only, a copy of your driver’s license, passport, or other suitable identification documentation.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences except where you apply for employment through Workable and you will be notified of how we use this information at that point.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with quotation or products or services or process your job application and employment offer). In this case, we may have to cancel a product or service you have with us, or not progress your job application, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect your Personal Data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial and Recruitment Data by filling in forms or by corresponding with us by post, phone, email, through our website or otherwise. This includes Personal Data you provide when you:
• purchase or enquire about our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you;
• give us some feedback;
• apply for a job or respond to a recruitment drive; or
• interact with us at trade fairs and/or conferences.
• When you visit our recruitment portal (https://www.vectornav.com/about/careers). We use the platform "Workable" to track, evaluate and hire job candidates. Please see Workable’s data privacy statement here https://www.workable.com/privacy.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies and other similar technologies.
• Third parties or publicly available sources. We will receive Personal Data about you from various third parties as set out below:
• Technical Data from the following parties:

(a) analytics providers such as Google based both inside and outside the UK/EU;

(b) advertising networks such as Geo-Matching (https://geo-matching.com/) based inside the UK/EU; and

(c) search information providers such as Google and Yahoo! based both inside and outside the UK/EU.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Telerik (https://www.telerik.com) based outside the EU.
• Recruitment Data from hiring platforms, such as Workable which is based in the UK, EU and US.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform the contract for the sale and purchase of goods, whether express or implied, we are about to enter into or have entered into with you, or to take steps at your request prior to entering into a contract with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we may use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using that data. Please contact us using the details set out above if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

• Legitimate interest means the interest of VectorNav in conducting and managing its and its affiliates businesses to enable it and its affiliates operate their business and operations in a commercially viable and effective way and to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where we consider any negative impact on you (unless we have your consent or are otherwise required or permitted to by law) overrides our commercial interests. Where required by law, upon request from you, we will provide you with further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities.
• Performance of a contract means processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

MARKETING

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us and our third party marketing support partner, Constant Contact Inc. (https://www.constantcontact.com) based in the US, if you have requested information from us or purchased products or services from us, consented to receiving such communications or where we are pursuing a legitimate interest and have a lawful right to do so and, in each case, you have not opted out of receiving that marketing (limited to similar products or services you purchased from us).

Where required by law, we will obtain your consent before we share your Personal Data with any third party such as Constant Contact Inc. for marketing purposes. A copy of Constant Contact Inc.’s privacy policy can be accessed here: https://www.endurance.com/privacy/privacy.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser, or use the check boxes in our Cookie Notice, to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

CHANGE OF PURPOSE

VectorNav will only use your Personal Data in ways that are compatible with the purpose that we collected it for, to comply with our legal requirements or for purposes you later authorise.

Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorise, where required by law, we will notify you, explain the legal basis which allows us to do so, and provide you with the opportunity to opt out.

Please note that we may process your Personal Data without your knowledge or consent, where this is required or permitted by applicable law or regulations.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may share your Personal Data with the following categories of recipients:

• Third party representatives, including those third party representatives set out at https://www.vectornav.com/company/global-sales.
• Service providers, including our recruitment hiring platform Workable, website support companies, , for example, Telerik and marketing support from Constant Contact Inc.
• Professional advisers, including bankers, auditors, legal counsel and insurers.
• Regulators and other authorities.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.

Where we are required by law, and have the ability, to do so, we require third parties to respect the security of your Personal Data and to treat it in accordance with the law. Where required by law, we do not allow our third party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

VectorNav is headquartered in the United States. As a result, if you are located in the UK or EU, your Personal Data may be transferred outside the European Economic Area ("EEA") or the UK.

This website is hosted in the United States. Personal Data that is voluntarily provided on or via this website may be maintained or accessed in servers or files located in the United States, which the EEA has not deemed to provide "adequate" privacy safeguards. If you do not wish to having your Personal Data processed and stored in the United States, please do not provide it to VectorNav.

Our third party representatives and service providers are based in the United States, outside the EEA or the UK, so their processing of your Personal Data may involve a transfer of data outside the EEA or the UK.

Whenever we transfer your Personal Data out of the EEA or the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
• Where we use certain service providers, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA or the UK.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. Where required by law, they will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

VectorNav maintains reasonable procedures to help ensure that your Personal Data is reliable for its intended use, accurate, complete, and current.

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period if there is a legitimate business reason or in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

If you are located in the UK or EU, under certain circumstances, you have rights under data protection laws in relation to your Personal Data. These rights include:

• Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it affects your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact Adam Brogden at support@optindigo.com.

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

[Version Dated: August 2020]