At SeagleWorks (publishers of Mile-O-Meter), we respect your privacy and take privacy seriously. This Privacy Policy explains how we (collectively, the “Company,” “SeagleWorks,” “Mile-O-Meter” “Mileometer” “we,” “our,” “us”) collect, use, disclose, and safeguard your information when you use our App or Website (collectively, the “Services”). We recognize the importance of protecting personally identifiable information (“Personal Identifiable Information” or “PII”) collected about you and other visitors (collectively, “Users”) to our services. Mile-O-Meter recognizes that using our service is a choice you make, and you can change your mind at any time. If you need assistance with cancelling your subscription or deleting your account, please reach out to support@mileometer.app. This Policy applies to the Service, which includes the Mile-O-Meter mobile application, the website located at seagleworks.com/mileometer.app and its subdomains, and all of the websites and internet properties owned or operated by us, regardless of the medium by which the Site is accessed by Users (e.g., via a web or mobile browser). How the Service works (a) After you download the app from Play/App Store, the on-boarding screen steps you through account setup, subscription setup and guidance around collecting activity, and location data for trip detection. You can change the drive settings anytime later from within the mobile app. (b) The app runs in the background to detect the trip start/stop based on the movement of your mobile device, so there is no need to press a start or stop button. However, you do have the choice to turn off automatic trip detection and manually start/stop trip sessions. (c) There are several customization options available like classifying a trip as business or personal category or custom categories that you may wish to define (all of these may be modified or deleted). Also, you can define purpose, work schedule, venue, vehicle from the mobile app. When you need to share trips, for taxes or employer reimbursement, you can export and share it by email. (d) Automatic trip detection is dependent on factors you control (such as location services, activity service and battery usage) as well as third-party factors outside of your control (such as network connectivity). Best practices include enabling location services, activity service, avoiding force-quitting the app or pausing trip detection, staying up-to-date with the latest OS on your device, optimizing battery settings and staying logged in to the app. Collected Information Mile-O-Meter collects user name, email address and password as part of account registration. Mile-O-Meter collects activity, location information to provide you with trip information whenever you are logged in to the app and have activity and location services turned on and available. Additional information around how you interact with the app (what buttons are/aren't pushed, etc.) may be collected to provide troubleshooting and improve the user experience. If you do not want trip data collected, you can pause, log out of or delete the app. Logging out or deleting the app also stops the additional information described above from being collected. The information collected during your use of the Services includes the following: While you must input an email address, password, subscription and payment to create an account and use Mile-O-Meter services, providing the following information is optional: (a) Purpose (Predefined or Custom) (b) Venue (for easy identification of trip’s source and destination) (c) Category (Predefined or Custom) for tax deduction (d) Vehicle (e) Custom mileage rate and unit (km or mile) (f) Work Schedule - Auto-classification rules based on work hours defined by you (g) Export (h) Notes (i) Notifications (j) Share (with friends and loved ones) (k) Feedback (emails to support, support@mileometer.app) We do not offer our Service or promote the Service to, nor do we intentionally collect or retain PII from, children who are younger than 13 years of age. If we discover that we have inadvertently collected information from a child under 13 years of age, we will promptly take all reasonable measures to delete such information from our systems. Use of Information We internally use the information we collect as follows: (a) Lawful Purposes: (i) as necessary for the performance of our contract with Users (such as our Terms of Use), (ii) for our legitimate interests, so long as they are not overridden by Users’ own rights and interests, or (iii) as required by law. These purposes include: (b) Provision of Services. We may use collected information for the purposes for which you provided the information including, for example, to create and maintain an account for you or to respond to a question that you e-mail to us. We also use the collected information as necessary to provide the features and functionality of the Services to you and as reasonably necessary for our business operations. (c) Updates and Troubleshooting. We may also use the collected information to contact you regarding updates or modifications to the Services or to help troubleshoot problems, provide you with required notices in connection with disputes between you and another user or alert you to changes in our policies or agreements that may affect your use of the Services. (d) Personalized Content. We may use the collected information to personalize the content that you and others see based on personal characteristics or preferences. (e) Analytics and Improvements. We may also analyze collected information relating to your use of the Services in order to help us improve the Services and develop and improve other products and services. (f) Promotional Offers. We may use the collected information to provide you with promotional materials and offers. However, we will give you the ability to opt out of receiving such e-mails in accordance with applicable law. We will not provide your personally identifiable information to third parties for their own marketing purposes without your consent. (g) Combination. We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts—such as our communications with you via email, SMS text or phone, or your customer service records. Disclosure of Information We may disclose Users’ PII to third parties as described below. Otherwise, we do not sell PII and will not disclose Users’ PII to third parties without your permission. (a) To Our Affiliates: We may disclose your PII to affiliates, including companies within the SeagleWorks network of connected applications. (b) To Service Providers and Trusted Third Parties: We may disclose your PII to third party service providers and trusted third parties (including sponsors and marketing partners) that assist us in providing user support, communicating with Users, and promoting our services, as well as third party service providers that provide other services to us relating to our services and/or the Service. Explicit privacy and terms of use requirements of current third-party service providers are referenceable at Exhibit A. (c) Law Enforcement, Safety, and Legal Processes: We may disclose your PII to law enforcement or other government officials if it relates to a criminal investigation or alleged criminal activity. We may also disclose your PII: (i) if required or permitted to do so by law; (ii) for fraud protection and credit risk reduction purposes; (iii) in the good-faith belief that such action is necessary to protect our rights, interests, or property; (iv) in the good-faith belief that such action is necessary to protect your safety or the safety of others; or (v) to comply with a judicial proceeding, court order, subpoena, or other similar legal or administrative process. (d) Sale or Acquisition of Assets: If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if we are transferred to another company, we may disclose and/or transfer your PII as part of the transaction. If the surviving entity in that transaction is not us, the surviving company may use your PII pursuant to its own privacy policies, and those policies may be different from this Policy. Security The security and confidentiality of your PII is very important to us. We use commercially reasonable security measures to protect your PII on the Service. However, no data transmitted over or accessible through the internet can be guaranteed to be 100% secure. As a result, while we attempt to protect your PII, we cannot guarantee or warrant that your PII will be completely secure (i) from misappropriation by hackers or from other nefarious or criminal activities, or (ii) in the event of a failure of computer hardware, software, or a telecommunications networks. If you choose to report and share your trip data with a third party, it is no longer under our control or subject to our data security. This includes choosing to report via integrations available on the mobile platform, other future third party service integrations, sending a report via email or any time a report is downloaded. Children under 13 We do not knowingly collect information from children under 13 and the Services are not directed at children under 18. If you are a parent and believe your child under the age of 13 has used the Services and provided personally identifiable information to us through the Services, please write or email us at the address provided in Section 11 of this Policy and we will work to delete that Service account and any such personally identifiable information. Effective Date; Changes When we make any changes to our practices under this Policy, we will change the Effective Date. We will treat your continued use of the Services following such change as your acceptance of the changes. However, we will seek your affirmative consent prior to applying any material change to this Policy on how we use or disclose personally identifiable information to information we collected or received prior to the date of the change. Legal Rights GDPR Data Subject Rights If you are a data subject located in the European Economic Area (“EEA”), the GDPR grants you certain data privacy rights. Your rights include the: (a) Right to Access: You have the right to request a copy of your PII. (b) Right to Rectification: You have the right to request that we correct any mistakes in your PII. (c) Right to Erasure: You have the right request that we delete your PII. (d) Right to Restrict Processing: You have the right to restrict processing of your PII. (e) Right to Object to Processing: You have the right to object to our processing of your PII. (f) Right to Data Portability: You have the right to receive your PII in a structured, commonly used and machine-readable format. (g) Right to Not be Subject to Automated Individual Decision Making: You have the right not to be subject to a decision based solely on automated processing. To exercise your rights, please contact us at the Contact Information provided below. Please be aware that your rights are limited to the extent permitted by the GDPR. Withdraw Consent In the event that we process your PII pursuant to your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on said consent before its withdrawal. If you would like to withdraw your consent, please contact us at the Contact Information provided below. California Privacy Rights California’s “Shine the Light” law permits users of the Application that are California residents to request certain information regarding our disclosure of PII to third parties for their direct marketing purposes. To make such a request, please contact us at the Contact Information provided below. Under the California Consumer Privacy Act (“CCPA”) signed into law June 28, 2018 and entering into effect Jan. 1, 2020, California residents have certain rights and privileges. These rights include the: (a) Right to Access: the right to request disclosure of PII collected or sold. (b) Right to Deletion: the right to request deletion of PII collected from you. (c) Right to Opt Out: the right to opt-out of the sale of PII (if applicable)*. (d) Right to Non-Discrimination: the right to non-discrimination for exercising their CCPA rights. *We do not sell your PII to third parties and have no plans to do so in the future. We reserve the right to ask for information verifying your identity and residency prior to disclosing any information to you or acting on your request. Should we ask for verification, the information you provide to verify your identity and residency will be used only for that purpose, and all copies of this information in our possession will be destroyed when the process is complete. We strive to respond to your request within 45 days of receiving a verifiable consumer request however, we reserve the right to respond within 90 days when reasonably necessary. Data Storage – International Transfer Company uses facilities in the United States or Canada or other countries. Your information will be stored and processed in the United States or other countries where Company has facilities. By using the Services, you consent to the transfer of information outside of your state, province, country, even if your country has more rigorous data protection standards. Retention We retain your information for as long as your account is active or as reasonably necessary to maintain the Service, meet legal and accounting obligations, and for the other purposes described in this Privacy Policy. If you wish to close your account, and/or request to delete your PII, you can do so at any time by contacting support@mileometer.app Third Parties The Services may contain offers from third parties or links to third-party websites. This Policy does not apply to information that you may provide to or that may be collected by third parties. We encourage you to request such third parties to provide you with their applicable privacy policies and other terms and conditions before engaging with or making a purchase from such third parties. Furthermore, we make no representations or warranties about the privacy policies or practices of the Linked Sites, and the Company is not responsible for the privacy practices of those Linked Sites. We encourage you to be aware of when you leave the Service and read the privacy policies of Linked Services. Accessing, Updating, and Controlling Information All trips, classified or unclassified, can be viewed at the mobile app by going to the menu and tapping Trip. Account deletions can be requested via support at support@mileometer.app. Deletion requests will be honored within 30 days of receipt acknowledgement by our support team. All other data related to trips, venue, custom purposes, custom category, work schedule, vehicle, reports, and notes can be deleted via the mobile app. Otherwise, if you ever wish to access, update, change, or delete any other PII, or cancel your user account (if applicable), you may make such changes through your user account. You may as well reach us below for further assistance. To help us process your request, please provide sufficient information to allow us to identify and verify you in our records. We reserve the right to ask for additional information verifying your identity prior to disclosing any PII to you. Should we ask for verification, the information you provide will be used only for verification purposes, and all copies of the information will be destroyed when the process is complete. Subject: Privacy privacy@mileometer.app Contact Information If you have any questions about this Policy, please contact us via email at support@mileometer.app Exhibit A Third Party Service Providers / Subprocessors (a) MapTiler The Services use the MapTiler Maps Platform. Users’ PII is subject to MapTiler’s privacy policies and you consent to MapTiler’s collection of your PII as identified in the then current MapTilers Privacy Statement. We do not control MapTiler’s collection or use of any information, which occurs on the MapTiler’s Maps Platform. (b) Google The Services utilize Google Analytics to collect and use cookies and identifiers for mobile devices pursuant to your use of the Mile-O-Meter. This is used by Mile-O-Meter for monitoring and analyzing mobile app & website traffic and enables processing of data with Google subject to Google’s Privacy Policy or any other URL Google may provide from time to time. We do not control Google’s collection or use of any such information which occurs due to utilization of Google Analytics. (c) Play Store The Services use Google Play Store for subscription management and payment processing. User’s PII is subject to Google Play Store privacy policies and you consent to Google Play Store collection of your PII as identified in Google Play Store privacy statement. We do not control Google Play Store’s collection or use of any such information which occurs due to utilization of Google Play Store. (d) App Store The Services use Apple App Store for subscription management and payment processing. User’s PII is subject to Apples App Store privacy policies and you consent to Apple App Store collection of your PII as identified in Apple App Store privacy statement. We do not control Apple App Store’s collection or use of any such information which occurs due to utilization of Apple App Store. (e) RevenueCat The Services use RevenueCat for your subscription status and identifiers of mobile devices pursuant to your use of the Mile-O-Meter. This is used by Mile-O-Meter for monitoring and analyzing subscription management and enables processing of subscription data with RevenueCat subject to RevenueCat’s Privacy Policy. We do not control RevenueCat’s collection or use of any such information which occurs due to utilization of RevenueCat. Do not use the Services if you are not comfortable with MapTiler’s or Google Analytics’ or Apple App Store’s or Google Play Store’s or ReventCat’s terms of use and privacy policies.