Revised Febuary 19, 2021

Clear to Go Network Privacy Policy

This Privacy Policy describes the privacy practices of Clear to Go, Inc. and its affiliates (referred to collectively as "CTG," "us," "we" and "our") in relation to your use of our websites, web-based SMS applications, and the CLEAR TO GO! ™mobile applications along with any other resources (collectively, the "CTG Network"). CTG licenses the CTG Network to customer's ("Clients") that need automated security tools for screening and tracking personnel and guests at its facilities to best manage occupancy and compliance with federal, state, and local guidelines for safer operation of Client's facilities. The CTG Network collects information from users seeking entry and use of the Client's facility based on screening questions developed by Client's legal and compliance team. If the user meets Client's criteria, user can obtain an electronic security badge used in the Client's facility licensed on the CTG Network (collectively, the "Services").

This Privacy Policy does not apply to our affiliates or other websites and services that display a link to a different privacy policy. In the event that we expand the CTG Network through the acquisition of another enterprise or platform, that enterprise, company, or platform may operate under its own privacy policy accessible via a link on its properties unless we integrate its privacy practices with ours, at which point a link to this Privacy Policy will be displayed on those related properties.

We provide our Services as a resource intended to assist and support the safety and security of Client facilities by gathering and reporting user information to compart with the Client's specified security requirements intended to comply with federal, state, and local guidelines. You can choose whether you want to use the Services. If you do choose to use the Services, you must agree to the CTG Network Terms of Use which is an agreement between us and users of the Services and the CTG Network. By agreeing to the CTG Network Terms https://app.cleartogo.co/service/terms you confirm that you have read and understand this Privacy Policy which explains how we collect, disclose, transfer, secure, and use information about you in connection with your use of the Services and the CTG Network, as well as the rights and choices you have regarding such activities. If you do not want us to collect and use information about you as described in this Privacy Policy, then you should not use the Services. By using the Services, you acknowledge that we will store, use and otherwise process your information in the United States. Unless otherwise specified herein, or on the CTG Network, CTG is the controller of the personal information that we collect about you as described in this Privacy Policy.

CTG takes your privacy seriously and will never sell the personal or aggregated data that we collect from our users.

Information Collected

Information about your use of the Services is collected as follows:

• Registration. In order to use the Services, you may be required to register an account and provide certain personal information such as your name, email address, zip/postal code, profession, occupation, specialty and perhaps some information regarding your current activities and possible exposure to contagions or other pathogens. You may be required to update or supplement this personal information that you provided at registration at times through your account when requested by CTG customer service.
• Services Information. We automatically collect and store information about your use of the Services, such as your responses to questionnaires and particular content which may include personal health information. We also collect information about your device when you access the Services including IP address and browser information (including referring URL).
• Information from Third Party Sources. We may obtain additional information about you from third party sources to assist us in providing the Services. For example, we may use third party information to verify and update your registration information, for research purposes or to personalize the Services.
• Non-registered Users. You must register with the CTG Network to access the Services; however, you may be able to access certain limited Services without registering. Even if you have not registered, we collect information about your use of the Services through the use of cookies and other tracking technologies. The information we collect includes the referring website, if applicable, the type of browser you use, the material viewed, and the time and date that you accessed the Services.
• Data Collected Relating to Students, Schools, and School Districts. You may supply data on the CTG Network because you are required to do so by your educational institution or employer. CTG does not require you to provide such data. Any student using the Services are responsible for complying with the requirements and qualifications as permitted user, as determined by their educational institution or school district. You are responsible for ensuring the accuracy and completeness of all information supplied to CTG for use by your educational institution. Authorized persons may access, view, and correct personally identifiable information through use of the Service at any time. We may retain the data supplied by such authorized persons for as long as required by the applicable educational institution and/or applicable law, or as otherwise authorized by you.
• Device Tracking. In addition to the information collection and sharing practices detailed in this privacy policy, the CTG Network may employ common tracking technologies like browser cookies, analytical tools, device identifications, or other technologies. CTG also collects certain technical information about the devices used to access and use the CTG Network, such as user-agent, time stamps, hardware type, language and time zone settings, IP address, and operating system type and version. More specifically, the CLEAR TO GO! mobile application, when enabled, may track a user's latitude and longitude ("geofencing") within or around a Client's facility. See next bullet for details.
• Geofencing. Employers and organizations may enable geofencing of their physical locations. When using the Android or iOS app, and when background location is enabled, Clear To Go servers receive precise location data only when the device enters or leaves one of the geofenced locations. This information is used to understand when someone was present in the event of a health or security incident. It is not shared with any third party.

How Your Information May be Used

Information about you may be used for the following purposes:

• Provision of the Services. We may use the information collected about you to provide and improve the Services, and to develop new or related Services.
• User Profiles. We may associate information that we have collected about your use of the Services with your registration information and any other information we have about you, as described in this Privacy Policy, thereby creating a profile of you that we may update from time to time ("User Profile").
• K-12 Students. CTG will not make any individual data gathered from students using the Services publicly available. CTG will not use any behavioral information to provide targeted advertising to Student, nor any user. We will not collect, use, or share behavioral information for any purpose beyond the authorized educational or school purposes, or as authorized by the applicable education institution. CTG, however, does not limit an educational institution's use of the data that it is authorized to access in connection with engagement of Services on the CTG Network. In the event of an acquisition by another entity or merger, CTG will not provide a student's personal information to a successor entity unless the entity expressly agrees to the "Student Privacy Pledge" as set forth by the Future of Privacy Forum and the Software and Information Industry Association.
• Communications. By registering as a user of the CTG Network, you agree to the use of your registration information and other information collected about you as described in this Privacy Policy to communicate with you about the Services and provide other information that may be necessary to provide the Services. These communications may be conveyed through a variety of channels, subject to applicable law, including emails referencing third parties that support the CTG Network in delivery of the Services.
• Verification Purposes. We may use your information in conjunction with information from third parties to recognize you as a registered user when you visit one of our Client's Facilities or commercial properties, and to verify your identity and/or license or professional credentials for security and access purposes. We may require you to provide proof of your identity in addition to the CTG Badge on your mobile device, and if you are unable to do so to our reasonable satisfaction, we reserve the right to deny you access to the Services and any Client facility. While we take steps to verify that our users identify as the registered users, we make no guarantee as to their identity, professional credentials, or licensure status.
• Account Management. We may use your information to administer your account, respond to your inquiries, fulfill your requests, and send you administrative communications about the Services.
• Investigations. We may use your information to detect, investigate and defend against fraudulent or unlawful activity, violations of the CTG Terms of Use and to otherwise establish, exercise and defend our legal rights.

Sharing Your Information with Third Parties

Information about your use of the Services may be shared as follows:

• Clients. We disclose information that you provide CTG to the Client that has engaged the CTG Network to gather information for screening and tracking personnel, contractors, vendors, and guests at Client facilities to best manage occupancy and compliance with federal, state, and local guidelines for safer operation of such facilities.
• Service Providers. We work with third party service providers to help us provide the Services and otherwise assist us in the operation of the CTG Network, including in the areas of email management and deployment, storage of personal health information (PHI), analytics, marketing, market research, identity, license, and professional credential validation, content distribution, customer service, payment fulfillment, event logistics, website maintenance and data storage and security. We may provide these service providers with personal information about users of our Services so that they can fulfill their responsibilities to us and our Clients; however, we do require that they agree to limit their use of this personal information to the fulfillment of these responsibilities.
• User Profiles. Subject to applicable law, CTG may provide user profiles, and portions thereof, (excluding contact information and information about your participation in specific named activities or visitation to facilities) only to those third parties necessary to provide the Services provided on the CTG Network..
• Consent. We may disclose your personal information to a third party in a manner not addressed by this Privacy Policy only if we obtain your prior consent at such time.
• Aggregated Information. We may provide aggregated information about users of our Services to third parties as we deem appropriate to carry out the intents and purposes of the CTG Network. For example, CTG may tell a Client what percentage of registered users of the CTG Network presented with specific information or status at a particular facility, or what percentage of users in a market research survey selected a particular response to a survey question. This data is provided in a non-identifiable format and any third party must agree to only use such data in accordance with this Privacy Policy.
• Business Transfers and Affiliates. We may share your information with any member of our group of companies (meaning our subsidiaries, our ultimate holding company, and its subsidiaries) for their use for the purposes not inconsistent with this Privacy Policy, including to market to you through a variety of channels as described herein, subject to applicable law. In connection with a corporate change in control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale of assets or a bankruptcy, we reserve the right to transfer your personal information to the new party in control or the party acquiring assets. In the event of such a change, your personal information will continue to be treated in accordance with this Privacy Policy, as may be modified as described below.
• Legal Requirements. We may release personal information when we believe such release (i) is required to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order and to meet national security or law enforcement requirements; or (ii) is reasonable in response to a physical threat to you or others, to protect property or defend or assert legal rights of us or others.

Security of Information

We have implemented appropriate technical and organizational security measures to protect the personal information that we have under our control from unauthorized access, use, disclosure and accidental loss. When you enter personal information, we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology. You are solely responsible for maintaining the security and confidentiality of your account username and password. Unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

Choice and Control

• Account Information. You may update your registration information at any time through the Account Management feature available on each of our properties. You may also contact Customer Support at support@cleartogo.co and request that your registration information be updated or deleted. Note that if we delete your account, we may maintain certain de-identified information about you for internal business purposes including research, analytics and reporting.
• Cookies. Most browser software can be set to reject all cookies, including third party cookies, however, if you choose to reject our cookies, your ability to access and use the Services will be limited. Refer to our Cookies Policy for additional information about opting out of cookies.
• Email Communications. If you no longer wish to receive a particular type of email communication from us, you may unsubscribe by clicking the "unsubscribe" link located at the bottom of the email and following the instructions. Also, you may manage your newsletter subscriptions within the newsletter subscriptions area within your account settings. Note that certain email communications that we send to Users are service-related and as long as you are a User of the CTG Network, you may not unsubscribe from such emails.
• Push Notifications. We may send you push notifications from time-to-time to notify you of upcoming events or updates that we think may be relevant to you. If you no longer wish to receive these types of notifications, you may turn them off at the device level.
• California Residents. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. For more information relevant to our users who are California residents, please contact CTG customer service at support@cleartogo.co.

Note to Users Outside of the United States

CTG and its supporting third-party providers are located in the United States, as is a majority of the CTG Network's technical infrastructure including its data hosting facilities. In order to provide the Services to you, we likely will transfer your personal information outside of your country of residence including to the United States where it will be stored and processed in accordance with this Privacy Policy. We may transfer your information outside the United States to service providers with operations in other countries. By using the Services, you consent to such collection, storage and processing in the United States and elsewhere, though the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal information. Note that your personal information may be available to the United States government or its agencies under legal process made in the United States.

Children's Privacy

The CTG Network and the Services are designed and intended for use by users of all ages, some of which may be minors. Any usage by a minor must be in connection with an approved Client or educational institution or similar organization that has obtained all appropriate parental approvals regarding such minor's usage of the Services.

Privacy Policy Changes

We reserve the right to modify this Privacy Policy at any time and any changes will be effective upon posting of the modified Privacy Policy unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by email (sent to the email address of record in your account profile) and/or by means of a notice on our websites before the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.

Contacting Us

If you have general questions about your account or the Services, contact customer service at support@cleartogo.co. For questions about this Privacy Policy or how your personal information may be used when you use the Services, please contact our Privacy Office by email at support@cleartogo.co.

Please note that if you contact us to assist you, we may need to verify your identity before fulfilling your request.

Effective date : September 10, 2020