Privacy Notice for California Residents

This Privacy Notice for California Residents (this Notice ) supplements and is a part of the information contained in the RoveIQ Privacy Policy provided by smartLINK Ventures, Inc., a Delaware corporation dba RoveIQ ( RoveIQ , we , our or us ) and describes the types of information we may collect from you or that you may provide (i) when you visit https://www.roveiq.com/ (the Website ); and (ii) when you use any mobile and/or desktop applications we may provide, on or through a RoveIQ Smart Kiosk ( Kiosk ), mobile phones, the Website, a third-party platform, or otherwise (the Application(s) , and together with the Website, the Services ). Services include any any associated content, functionality or services provided by us on or through the Website or Application.

This Notice applies solely to all visitors, users, and others who reside in the State of California ( consumers or you ). We adopt this Notice to comply with the California Consumer Privacy Act of 2018, as may be amended from time to time ( CCPA ) and any terms defined in the CCPA have the same meaning when used in this Notice. Capitalized terms used but not defined in this Notice have the meanings given to them in the RoveIQ Privacy Policy or, if not defined there, then in the CCPA.

Information We Collect

We collect through our Services 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 ). Personal Information does not include:

Publicly available information from government records.

Deidentified or aggregated consumer information.

Information excluded from the CCPA’s scope, like:

Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected through our Services the following categories of Personal Information from its consumers within the last twelve (12) months:

Category

Examples

Collected

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

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

C. Protected classification characteristics under California or federal law.

Age (40 years or older), 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).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

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

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

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

K. Inferences drawn from other Personal Information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

We obtain through our Services 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 our Services.

As described in Section 4 (Information We Collect About You and How We Collect It) of the RoveIQ Privacy Policy.

Use of Personal Information

We may use, sell or disclose the Personal Information we collect for one or more of the following purposes:

To administer, operate, market, and maintain RoveIQ and the Services.

To market RoveIQ products or services.

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

To provide, support, personalize, and develop our Services, products, and other services.

To create, maintain, customize, and secure your account with us.

To create, maintain, customize, secure and provide you with notices about your account with us.

To provide you with information, products, or services that you request from us.

To process your requests, purchases, transactions, and payments and prevent transactional fraud.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

To personalize your Services experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Services, third-party sites, and via email or text message (with your consent, where required by law).

To help maintain the safety, security, and integrity of our Services, products and services, databases and other technology assets, and business.

For testing, research, analysis, and product development, including to develop and improve our Services, products, and services.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Services users is among the assets transferred.

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

To notify you about changes to our Services or any products or services we offer or provide though it.

To allow you to participate in interactive features on our Services.

For any other purpose with your consent.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose.

We share your Personal Information with the following categories of third parties:

Affiliates. To our subsidiaries and other affiliates companies that control, are controlled by, or are under common control with, us. These entities may use your information to make predictions about your interests and may provide you with special offers, promotional materials, advertisements and other materials.

Partners. To partners who provide products or services that may be of interest to you. These partners may use your information to make predictions about your interests and may provide you with special offers, promotional materials, advertisements and other materials.

Service Providers. To contractors, service providers, and other third parties we use to support our business, including companies that provide payment processing, shipping, web analytics, data processing, web hosting, technical support, advertising, email distribution and other services ( Service Providers ).

Buyers and Successors. 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 RoveIQ s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by RoveIQ about our Services users is among the assets transferred.

Advertisers. To third parties to market their products or services to you if you have not opted out of these disclosures.

Other Parties With Your Consent. With your consent.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records Personal Information categories.

Category K: Inferences drawn from other Personal Information.

Such disclosures of your Personal Information for a business purpose have been to the following categories of third parties:

Service Providers.

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold any of the following categories of Personal Information:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category E: Biometric information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category H: Sensory data.

Category I: Professional or employment-related information.

Category J: Non-public education information.

Category K: Inferences drawn from other personal information.

 

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see the Exercising Access, Data Portability, and Deletion Rights section below), 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.

The specific pieces of Personal Information we collected about you (also called a data portability request).

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.

We do not provide these access and data portability rights for B2B Personal Information.

Deletion Request Rights

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. Once we receive and confirm your verifiable consumer request (see the Exercising Access, Data Portability, and Deletion Rights section below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the 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 perform our contract with you.

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

Debug products to identify and repair errors that impair existing intended functionality. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 et. seq.).

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.

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

Comply with a legal obligation.

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

We do not provide these deletion rights for B2B Personal Information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to RoveIQ by either:

Email: [EMAIL]

Mailing Address:

smartLINK Ventures, Inc. dba RoveIQ

16 E 11th St. Newport, KY 41071

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, you may email [EMAIL] noting in the subject line of your email CCPA Designation of Authorized Agent .

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include, for example: Full name, email address, mailing address, date of birth and telephone number.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. For instructions on exercising sale opt-out rights with RoveIQ, see the Personal Information Sales Opt-Out and Opt-In Rights section below.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct RoveIQ to not sell your Personal Information at any time (the right to opt-out ). RoveIQ does not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the right to opt-in ) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. 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 visiting the following link: [HYPERLINKED URL with the title Do Not Sell My Personal Information ]

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales.

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and, if appropriate, comply with the request.

The Right to Limit Use of Sensitive Information

You have the right to limit our use of your Sensitive Data to only purposes necessary to perform the service or provide the goods that you request from use, with the exception of the following:

Collection or processing of sensitive personal data for security purposes;

Maintaining/servicing accounts; and

Undertaking activities to verify/maintain the quality of a service

 

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 that can 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.

Other California Privacy Rights

California’s Shine the Light law (Civil Code Section 1798.83) permits users of the Services that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [EMAIL].

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated privacy notice on our Services and update the Notice last modified date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which RoveIQ collects and uses your information described in this Notice and in the RoveIQ Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

 

Email: [EMAIL]

Mailing Address:

smartLINK Ventures, Inc. dba RoveIQ

16 E 11th St. Newport, KY 41071