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1. DTiQ Privacy Policy Scope

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This Privacy Policy applies to anyone who interacts with DTiQ through its Website, mobile applications, products, and services (collectively, our “Services”) and to the personal information of users of our Services except as described below.

This Privacy Policy does not apply to information collected by or provided in connection with an application for employment, ongoing employment, or former employment with DTiQ. If you are a DTiQ employee or applicant for employment in the United States, please see the DTiQ Employee and Applicant Privacy Policy for information about how DTiQ collects, uses, processes, discloses, and retains employment information not covered by this policy.

This Privacy Policy applies to information collected from consumers or processed in DTiQ’s capacity as a Controller under applicable data protection laws. Data collected, used, or shared in DTiQ’s capacity as a service provider is governed by relevant contracts or Service Agreements and the data Controller’s privacy policy, and is outside of the scope of this Privacy Policy.

This Privacy Policy does not apply to the practices of third parties that we do not own or control (such as third-party websites that you may access from our Website), or to individuals that DTiQ does not employ or manage. We have no control over or responsibility regarding the information collected from you by others, such as third-party websites that you access through links on our Website. Instead, such information practices are governed by those entities’ privacy policies. Please review the privacy policies of any third-party websites for information on how those entities collect and use your information.

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2. Controller and contact details

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DTiQ Technologies, Inc, 111 Speen Street #550, Framingham, MA 01701 is responsible for this platform and the controller of the personal data collected during your use of the Website.

You can reach our data protection officer by sending an email to dpo@dtiq.com.

For residents of the EU and UK, the representative of DTiQ pursuant to Art. 27 of the GDPR is: DAPR sp. z o.o., ul. Zurawia 47, 00-680, Warsaw, Poland. Mikolaj Otmianowski; kontakt@dapr.pl.

If you have any questions regarding this Privacy Policy or the processing of your personal data, you are welcome to contact our data protection officer by e-mail under the subject matter “Data protection”.

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3. Definitions

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• “personal data” means any information reasonably relating to an identified or identifiable natural person or household; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors, including but not limited to “personal data” as defined by the GDPR and “personal information” as defined by the CCPA;

• “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

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4. Processing of personal data when using Services for informational purposes

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When you use Services for informational purposes without registering or submitting a form, your internet connection data provided from your browser to our server are processed. When using our Services for informational purposes including accessing our Website, we process the following categories of data:

• IP address

• Date and time of visit

• URLs of pages visited

• Number of pages visited

• Last activity date and time

• Referral website and information

• Type, language, and version of browser

• Device ID

This information is processed to allow the use of our Website (e.g. by adapting our Website to the requirements of your device). The legal basis for data processing is Art. 6 (1) 1 (b) GDPR as we require the automatically-collected data for an effective provision of our Website and Art. 6 (1) 1 (f) GDPR as the recording of the data serves our legitimate interest in ensuring the stability and security of the Website.

Data Retention: We retain usage data for as long as necessary to provide you with the Services and comply with other legal obligations.

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5. Processing of personal data when contacting us

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If you contact us, we process the data provided by you which may include the following categories of data, depending on your interaction with us:

• your name,

• e-mail address,

• address,

• telephone number,

• company name.

When we collect information from our vendors, subcontractors, and from our clients in DTiQ’s role as a controller, we may collect the following information, in addition to the categories listed above:

• tax id number,

• social security number,

• banking information,

• credit card information,

• Licensing Certifications (business and/or state or local certifications),

• Liability Insurance Policy Information

We process this information in order to respond to your inquiry, for example when you require support services or if you have specific questions concerning our services, in accordance with Art. 6 (1) 1 (b) GDPR. The provision of data is voluntary, however, the failure to do so may prevent us from accurately responding to your questions, depending on the respective inquiry.

Data Retention: Personal data provided by you on our Website or via other means will be stored in our service database and retained for the period necessary to fulfill our business or contractual obligations to you in accordance with Art. 6 (1) (b) of the GDPR, unless a longer retention period is required by law.

DTiQ processes personal data when you Book a Demo, Book a Consultation, subscribe to our Newsletter or contact us for additional information. By submitting a form through DTiQ’s Website to Book a Demo, Book a Consultation, sign-up for additional information subscribe to our Newsletter or any other purpose, you are consenting to the terms and conditions of DTiQ’s Privacy Policy and the storing and processing of your personal data for the purposes of satisfying your request in accordance with the terms of this Privacy Policy.

If you are our client and have subscribed to our Newsletter, this information may be combined with other data processed under section 7 below for the purposes of improving our services.

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6. Processing of personal data when providing Services to our business subscribers

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DTiQ also provides video surveillance, Point of Sale (“POS”), analytics tools, and loss prevention services to our business subscribers. In doing so, DTiQ processes video recordings from restaurants, retail stores, and other locations (“video data”) based on our business subscribers’ placement and use of video cameras. We process video data by providing our business subscribers with platforms where they can review and replay those video recordings and by providing certain data analytics to improve business subscriber performance, including verifying transactions, enforcing cash handling processes, ensuring prompt speed-of-service, enforcing food handling policies, and ensuring that emergency exits remain unobstructed. While video data capture images, DTiQ does not use video data to identify individuals and does not analyze or store biometric information. DTiQ’s subscribers are responsible for making any disclosures or obtaining any necessary consent in connection with using DTiQ services to collect video data.

DTiQ also collects transaction data from POS devices in business subscriber locations which may include employee names and email addresses.

DTiQ also collects information when it provides loss prevention services to our business subscribers. The information we collect may include employee names and contact information, as well as notes from conversations with employees which may identify other employees or consumers based on their role in the incident under review.

Data Retention: Personal data collected when providing services to our business subscribers will be stored in our service platform and retained for the period necessary to fulfill the business or contractual obligations to our subscribers in accordance with Art. 6 (1) (b) of the GDPR, unless a longer retention period is required by law.

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7. Sensitive Personal Information

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DTiQ may process the following categories of Sensitive Personal Information when you use our Services or are a vendor providing services to DTiQ:

• Social security number;

• Driver’s license and non-driver identification number;

• State identification card number;

• Passport number; and/or

• Financial account (routing and account number), debit card or credit card number in combination with expiration date.

As noted in the Scope Section of this Privacy Policy (Section 1), data DTiQ collects in its role as service provider is governed by agreements with the controller and the controller’s privacy policy.

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8. Cookies

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We use cookies on the Website. Cookies are text files that are saved on your browser. These text files can be read by websites and help to identify your preferences or your device and are mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Some cookies serve to store preferences and are deleted again after the end of the browser session, i.e. after closing the browser, so-called session cookies. Other cookies serve to better adapt the website to user needs and remain on the end device, so-called permanent or persistent cookies. Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change our default settings. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer.

When you are on our Website, a cookie consent banner will appear that will allow you to consent to or opt out of one or more categories of cookies. In addition, you can set your browser settings to allow cookies only in individual cases, limit the acceptance of cookies to certain cases or generally exclude them and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of the Website may be restricted.

If you want to delete any cookies already on your computer, please refer to your browser vendor’s instructions by clicking “Help” in your browser menu. You can also find out more about cookies and how to delete and control them on www.aboutcookies.org or click “Help” in your browser menu.

Below is an explanation of various categories of cookies we use as of the date of this privacy policy:

Strictly Necessary Cookies

Strictly necessary cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Performance Cookies

Performance cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.

Functional Cookies

Functional cookies enable the Website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Targeting Cookies

Targeting cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Social Media Cookies

Social Media cookies are set by a range of social media services that we have added to the Website to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

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9. Social Plugins

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DTiQ may integrate with social sharing site features or other related tools which direct you to content DTiQ posts on the social sharing site and/or allow you to share actions you take on our Website with the other apps, sites or media, and vice versa. For example, you may click on a Facebook icon on our Services and be directed to the DTiQ Facebook page hosted on Facebook’s servers. These features may also enable the sharing of information with your friends or the public, depending on the settings you establish with the social sharing site. For example, you may click on the Facebook “like” button on our Services, which publishes to your Facebook account that you “like” one of the pictures or profiles featured on our Services. Your interaction with these features are governed by the privacy policy of the relevant social sharing site. These features may collect your IP address and which page you are visiting on our Services and may set a cookie to enable the feature to function properly. We have no control or influence over the data collected from you by the social sharing sites upon your interaction with these features or those sites, and we cannot control use of any information or content you choose to make available publicly. Please refer to the privacy policies of the social sharing sites for more information. You can locate information about the privacy practices of the social sharing sites our Services integrate with here:

Facebook: https://www.facebook.com/privacy/policy/

Twitter: http://twitter.com/privacy

LinkedIn: http://www.linkedin.com/legal/privacy-policy

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10. Disclosure of personal data to third parties

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Except in the cases mentioned in this Privacy Policy, your personal data will not be disclosed to third parties. Personal data may be disclosed to third parties who act on our behalf to process the personal data in accordance with its original purposes, such as hosting our platform, fulfilling the services offered, evaluating the user behavior of our Website, or technical support. These third parties are contractually obligated to use personal data only for the agreed purpose or not to disclose your personal data to other parties without permission unless required by law. If other categories of recipients of personal data arise as a result of future data collection, we will inform you of this at the time this information is collected for this purpose.

We use service providers such as HubSpot and SalesForce to assist with Advertisement, Promotions and Newsletter services and to assist with services and notifications on the Website. Any such companies must agree to maintain the confidentiality of any personal information we may provide to them and are contractually obligated not to disclose or use it for any other purpose. Such companies may also collect personal information directly from you in providing their services, and they will have the right to provide that personal information to us. Such companies may not use your private information for purposes other than providing services through or on behalf of DTiQ.

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11. Data Transfers

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It is sometimes necessary to transfer your personal data described above to countries outside the EU and the EEA (so-called third countries), e.g. the USA.Please note that data processed in third countries may be subject to foreign laws and are accessible to local governments, courts and law enforcement and supervisory authorities. However, when your personal data is transferred to third countries, we will take appropriate measures to secure your data appropriately.

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12. Data security

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Taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk for your rights and freedoms, we take appropriate technical and organizational measures in accordance with Art. 32 GDPR to ensure a level of protection appropriate to the risk. However, no website, network, or system can be absolutely protected against intentional or malicious intrusion attempts despite taking appropriate and reasonable precautions. Furthermore, DTiQ does not control the devices, computer or network through which you access the Website or over which you may choose to send personal information or other information to us, and therefore cannot prevent potential interceptions or compromises to your information while in transit. DTiQ makes no guarantee as to the security, integrity or confidentiality of any information transmitted to or from the Website. DTiQ is committed to safeguarding your information to the best of its ability but cannot guarantee the security of electronic communications or transmission made over the Internet.

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13. Your rights – European Union

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You have the following rights:

• the right of access regarding personal data concerning you being processed by us;
• the right to rectification of inaccurate personal data;
• the right to the erasure of personal data concerning you (‘right to be forgotten’);
• the right to restriction of processing of personal data;
• the right to receive the personal data concerning you in a structured, commonly used and machine-readable format where the processing is based on consent or with regard to a contractual relationship with you (‘right to data portability’);
• the right not to be subject to a decision based solely on automated processing;
• the right to lodge a complaint with the competent supervisory authority.
• Right to object

Furthermore, you have the right to object to the processing of personal data concerning you

• where personal data are processed for direct marketing purposes; or
• where the processing of personal data is based on Art. 6 (1) 1 (f) GDPR on grounds relating to your particular situation.

You can exercise these rights by e-mail to our data protection officer or by post to the address listed above.

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14. Your rights – California residents

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DTiQ has in place policies and procedures to facilitate the exercise of privacy rights available to California residents. If you are a California resident please use this link to access specific disclosures required for California residents and to exercise rights afforded California residents. [add link to Additional Disclosures to California Residents].

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15. Privacy Rights Information for Residents of Other States

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Residents of other states may also be guaranteed certain privacy rights, depending on where they live. Residents of certain states including Virginia and Nevada may be entitled to exercise some or all of the following rights depending on certain limitations. To submit a request to exercise your rights, please contact us using any of the methods in the “Contact Us” Section. Any request to exercise your rights must include your name, state of residence, the right or rights you would like to exercise, and a means of contacting you.

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Virginia Resident Rights

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The Virginia Data Protection Act becomes effective on January 1, 2023, after which time Virginia residents may be entitled to the following rights:

• The right to opt out of the processing of personal data for purposes of targeted advertising, the sale of personal data, and profiling that creates legal or other significant results;
• The right to confirm whether DTiQ processes personal data and to access the personal data DTiQ has about you;
• The right to correct inaccuracies in the personal data DTiQ has about you, taking into account the nature of the personal data and the purposes of the processing of the personal data;
• The right to request deletion of the personal data we hold about you, subject to certain limitations;
• The right to obtain a copy of the personal data DTiQ holds about you in a portable, readily usable, and easily transmittable format; and
• The right to appeal our denial of any request you make under this section. To exercise your right to appeal, please submit appeals request via the information in the

Contact Us section below. Within sixty (60) days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may contact the Virginia Office of the Attorney General by:

Contacting Online:

https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint

Calling:

If calling from Virginia, call the Consumer Protection Hotline at 1-800-552-9963.If calling from the Richmond area or from outside Virginia, call the Consumer Protection Hotline at 1-804-786-2042.

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Nevada Resident Rights

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Note that DTiQ does not sell personal data as defined under Nevada law.

Nevada residents have the right to submit a verified request directing us not to sell their personal data. If you are a Nevada resident and would like to submit such a request, please send your request to dpo@dtiq.com.

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Children

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Our Website is not directed to children. We do not knowingly collect or solicit personal data from children under the age of 16 through our Website. If you are under 16, do not attempt to register for or use any of our Services, including our Sites, and do not provide us any personal information about yourself. If we become aware that we have collected personal data from a child under the age of 16, we will promptly delete the information from our records. If you are a parent or guardian and you are aware that your child has violated this Privacy Policy and provided us with personal information, please contact us using the information in the Contact Us section below.

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Contact Us

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Please direct any questions you may have about this Privacy Policy to any one of the following:

By mail:

DTiQ Technologies, Inc.
Attn: Legal Department – Privacy
111 Speen Street, Suite 550
Framingham, Massachusetts 01701

By e-mail:

‍dpo@dtiq.com

By Phone:

888-260-0256

By Webform:
‍Click Here

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18. Difficulty Accessing Our Privacy Policy

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Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.

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19. Changes to this Privacy Policy

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This Privacy Policy may be updated from time to time and without prior notice to you, and any changes will be effective immediately upon the posting of the revised Privacy Policy.This Privacy Policy was last updated in June 2023