Promaster Electronic Privacy Policy

Effective Date: May 1, 2023

Promaster Electronic links everything, anytime, and everywhere. We value your privacy as much as you do and are dedicated to safeguarding it. This Privacy Policy outlines our approach to collecting, using, disclosing, transferring, storing, and protecting personal information obtained through our products and services while also detailing your available choices.

Please note that this policy is applicable to Promaster Electronic LLC ("Promaster Electronic," "we," "us," or "our") websites, mobile apps (AutoSky+), help centers, and other related services we offer ("Services"). It also pertains to AutoSky physical devices (e.g., GPS trackers) and other items such as Labels ("Products").

Before utilizing our Products and/or Services, make sure to read and understand this Policy, as it explains how we gather, store, use, and disclose your personal information.

The information collected by Promaster Electronic depends on which Products or Services you use and how you use them.

Please note that not providing the required information when asked may result in your inability to fully use our Products and/or Services.

When you create or modify an AutoSky or AutoSky+ account, update your preferences, purchase and/or activate a Product, contact us (including through social media), participate in an online survey, or otherwise interact with Promaster Electronic's Products and Services, we may collect various types of information, including:

Account Information. Your username, email address, real name, nicknames, date of birth, phone number, password, shipping and billing addresses, and activated Products. You may also opt to provide a photo to be associated with your AutoSky+ account.

Party Information. When you create a party in your AutoSky+ app and invite a friend or family member to join your Party, we collect their name, email address, mobile phone number, and a photo, if provided.

Payment and Transaction Information. When you order a Product or activate a subscription, you'll need to provide an email address, a first and last name, and/or a shipping address. The relevant billing and/or payment processor processes any payment information provided. We may also collect information such as the Product version or subscription service you're using, the date and time you activated your account, the length of your subscription, data related to any subscription cancellation request, and any in-app purchases you make.

Other Account Information. You may also customize your in-app map by labeling Places or Geofences (e.g., "work" and "home") to easily identify your favorite locations and receive alerts when Party members or GPS trackers leave and arrive at those boundaries.

Other Information You Provide to Us. Information you offer in response to surveys about our Products or Services; any details about your friends that you provide through our referral services; any information or content you voluntarily submit or post to Promaster Electronic websites or blogs; comments you post on our Facebook page (or other social media pages); information you provide when seeking help from us, such as your name, email address, phone number, mailing address, and records (including call recordings) and technical information related to the issues you encounter.

We may gather additional information when you use our Products and Services, such as:

Device Information. Details about your device, hardware and software, like mobile device identifiers, IP address, or browser information (including browser type and language preference).

Location and Movement Information. We collect your location and motion data through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available on your mobile device, as well as motion information like altitude, heading, and speed.

Driving Event Information. We may gather sensory and motion data from your mobile device, including gyroscope, accelerometer, compass, and Bluetooth (including details related to your motion activity, such as cycling, walking, running, or driving, and information about your speed, acceleration, and deceleration).

Messages and Member Content. We collect information when you message other Party members using our Services, provide feedback to Promaster Electronic, create a blog post or comment, or tag Promaster Electronic, AutoSky+, or AutoSky in a social media post, along with any photos or videos you send via in-app messaging to other Party members.

Certain data we collect may be considered sensitive under relevant law. We process such information for disclosed purposes as allowed by and in compliance with applicable law, to the extent we collect sensitive personal information.

We may obtain information about you from other sources, including third-party services that you connect to any Promaster Electronic account or third-party services and organizations that supplement information provided by you. For instance:

When you opt to connect or engage with our Services through a third-party social networking service ("Social Network"), like Liking us on Facebook or posting a comment on our Facebook page, we may collect information that you have already made public on your Social Network account.

We may employ social plugins, widgets, and other features (each a "Social Feature") provided by and/or accessing third-party Social Networks. These Social Features allow these Social Networks to place cookies on your browser and gather specific information, which may be linked to your personal Social Network account, such as your name, Social Network user identification number, username, location, gender, birth date, email, profile picture, and your contacts on the Social Network.

When you visit our websites, use our apps, read our emails, or otherwise engage with us, we may automatically collect certain device information using a variety of technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, "Tracking Technologies"). We may combine this information with other personal data we collect about you. We employ these Tracking Technologies to gather usage and device information, such as:

Details about the computer, tablet, smartphone, or other device you use, for example, your device's phone number (if applicable), IP address, browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID allowing us to uniquely identify your browser, mobile device or your account (e.g., a UDID, IDFA, Google Ad ID, Windows Advertising ID, or other persistent device identifier or Ad ID), battery life, whether the device is connected to WiFi, and other similar information. With your permission, we may also access your photo or camera roll.

We also utilize Analytics, Advertising, and Anti-Fraud technologies in our Products and Services. These technologies may employ the same cookies or similar mechanisms as described below.

Cookies are pieces of code that allow for personalization of our website experience by saving your information such as user ID and other preferences, if your browser is set to accept cookies. A cookie is a small data file that we transfer to your device’s hard disk (e.g., computer or smartphone) for record-keeping purposes.

Web beacons (also known as web bugs, pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user's device, web beacons are typically embedded invisibly on web pages (or in an email).

We may collect analytics data or use third-party analytics tools such as Google Analytics, which may use Tracking Technologies, to help us measure traffic and usage trends for our websites, Products, and Services. The types of data that analytics technologies may capture include:

● Referral/exit pages;

● How frequently you access our Services;

● Whether you open emails or click the links contained in emails;

● Whether you access our Services from multiple devices;

● The features you use;

● The links you click;

● The ads you view and click on;

● Purchase transaction information;

● Your location when you access or interact with our Products and Services;

● Technical related information about your computer or device and operating and/or network systems (such as IP Address and device ID);

● Information about your engagement with certain features and usage statistics; and

● Other similar actions.

We may collect and share your personal information, including your unique identifiers or Advertising IDs and other data such as app events, with third-party ad networks, social media companies, including without limitation, to inform and improve tailored advertising, attribution, analytics, or research purposes.

These advertising partners collect and use information such as:

● Clickstream information;

● Timestamp;

● Hashed email address;

● Device ID or AdID; and

● Your use of third-party applications.

These third-party partners may combine this information with information they collect directly through Tracking Technologies or that they receive from other third parties. These third-party partners may use the information they have gathered independently according to their own privacy policies.

You have the right to object to and opt-out of certain third-party tracking and advertising. Where you have consented to Promaster Electronic’s processing of your information, you may withdraw that consent at any time and opt-out of certain processing activities, such as targeted marketing communications. Even if you opt-out, we may still collect and use information regarding your activities on our Sites and/or information from the advertisements on third-party websites for non-interest-based advertising purposes, such as to determine the effectiveness of the advertisements.

We may use and disclose your information to service providers to provide, maintain, and improve our Products and Services, to develop new products and features, to determine which new products or services may be of interest to you, and to promote our Products and Services.

We retain the information we collect for as long as necessary to provide our Products and Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.

We may also remove identifiers, anonymize, or compile the information we gather, or collect it in a manner that does not directly recognize you. We may utilize and share such data as needed for our business objectives and as permitted by relevant law.

The particular reasons for our collection, preservation, utilization, and processing of your information are detailed in this Section III (How We Utilize Your Information).

A. Administrative Objectives

We may utilize your information for our administrative objectives, which include:

● Providing you with our Products and Services;

● Gauging interest in Promaster Electronic's Products and Services;

● Creating new products and services;

● Ensuring the integrity and security, as well as conducting internal quality control and optimization of our Products and Services;

● Validating individual identities;

● Communicating about individual accounts and activities involving Promaster Electronic's Products, Services, and systems;

● Modifying any Promaster Electronic policies;

● Sending messages to the email address you supply to verify your Account;

● For purposes such as account management, customer service, or system maintenance, including informational, transactional, marketing, and operational activities;

● Processing payments for purchased products or services;

● Handling applications and transactions;

● Preventing potentially prohibited or illegal activities; and

● Enforcing our Terms of Use and this Privacy Policy.

B. Promoting Promaster Electronic Products and Services

Promaster Electronic may use information, and individuals who provide personal information may periodically receive emails, newsletters, mailings, or phone calls from us, as permitted by applicable law, for marketing purposes such as:

● Providing information about Promaster Electronic or our business partners' products and services that may interest you;

● Informing you of upcoming special offers/events that may be of interest;

● Conducting individual or market research;

● Carrying out research and marketing analytics;

● Engaging in online behavioral advertising;

● Customizing content, advertisements, and offers that may interest you;

● Introducing new content, features, Products, or Services; and

● For other purposes disclosed when you provide your information, or with your consent.

C. Research and Development

We may use information to generate non-directly identifiable information, which we may use independently or combined with information from other sources, in order to:

● Optimize the delivery of our existing Products and Services;

● Develop new Products and Services;

● Conduct research and internal analysis;

● For example, Promaster Electronic may occasionally conduct research (online and offline) via surveys. We may enlist third-party service providers to administer these surveys on our behalf (all survey responses are voluntary). Survey responses may be used to:

● Determine our Products and Services' effectiveness,

● Conduct various types of communications, advertising campaigns, and/or promotional activities,

● Learn more about our members and potential members and their individual and collective needs.

If an individual participates in a survey, their information will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analytics purposes.

D. Connecting with Social Media

Using these Social Features allows the supplemental information provided to help us verify the information you've given to Promaster Electronic and enhance our ability to supply information about our business, products, and services.

These Social Features are solely operated by the respective Social Networks and their service providers. We recommend carefully reading their privacy policies before using them. We have no control over or access to the information collected, stored, or used by these Social Networks, and their information practices are not covered by this Privacy Policy.

E. Automatically Collected Information via Tracking Technology

We use information collected through Tracking Technologies (e.g., cookies and web beacons) to:

● Remember information, so you don't have to re-enter it during your visit or the next time you visit our website or use our Services;

● Authenticate your access;

● Track your in-app preferences or choices;

● Display a personalized browsing history;

● Provide customized content and information, including targeted content and advertising;

● Record your device's location and movements;

● Identify and contact you across multiple devices;

● Monitor the effectiveness of our Services and marketing campaigns;

● Observe aggregate metrics such as the total number of visitors, members, traffic, and demographic patterns;

● Provide specialized technical assistance (diagnosing or resolving technological issues reported by our members or engineers linked to specific IP addresses or User IDs);

● Detect and prevent fraudulent or harmful actions;

● Automatically update our mobile application on your system and associated devices; and

● Plan and improve our Services in general.

We share your information with select third parties and our subsidiaries, as detailed below. However, we will not disclose your personal information to independent third parties, other than in the circumstances mentioned in this Privacy Policy, without obtaining your prior consent. Your information may also be used and disclosed for our protection and the protection of others, in order to prevent fraud, misappropriation, infringement, identity theft, and other illegal activities or misuse of our Products and Services. This information may be shared within Promaster Electronic, with our subsidiaries, and with third parties in an anonymized or aggregated form to prevent identification.

Depending on the enabled tools and features, AutoSky+ Parties may share personal information, including your:

● Full name;

● Precise location;

● Mobile location history;

● GPS trackers' precise location on your account.

We may share personal information (including contact information, location, movement data, mobile device details, application analytics, technical and analytical data, and driving event data) with third-party partners that offer certain features and services you choose to use through or in connection with our Products or Services, subject to their availability in your country or region. Some examples include:

● Crash Detection and Emergency Dispatch Services;

● Identity theft protection;

● Driving analytics services.

Any voluntarily submitted information or content to Promaster Electronic, AutoSky, or AutoSky+ websites, blogs, community forums, or comments posted on our Facebook page (or other social media pages) will be publicly available. We may post your reviews and comments online on our website or mobile app, or link them to third-party websites. We are not responsible for any information you choose to provide on social media pages, or any content or communications you receive as a result of sharing such information. To request removal of your information from our website or blogs, please contact us at social@promasterelectronic.com.

We may disclose your personal information to vendors and consultants who provide services on our behalf or help us offer our Services, such as accounting, managerial, technical, email, chat, marketing, analytics, fraud prevention, bot detection, web hosting, and other third-party partners or service providers who process personal information solely to provide services or features to our members on our behalf. Importantly, locations associated with your Products in the AutoSky+ app will not be sold to or monetized by third parties, even in aggregated form. We will never disclose your non-obfuscated telephone number to any third-party business partners, vendors, or consultants for independent SMS marketing purposes without your explicit, affirmative opt-in consent.

E. Business Transactions Involving Third Parties

We may, at any time, buy, sell, or divest any part or combination of our company, its products, services, assets, or businesses. Personal information, such as member names and email addresses, along with other member information related to our Services, will likely be among the assets transferred in these types of transactions. We may also disclose, transfer, or assign such information during corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, or similar transactions or proceedings.

F. Legal Obligations, Regulators, and Law Enforcement

We may disclose personal information to third parties (including law enforcement, other government entities, or civil litigants; excluding our subcontractors) when required by law or subpoena, or if we determine, at our sole discretion, that it is necessary to (a) comply with the law, legal processes, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) enforce our Terms of Use or this Privacy Policy, take precautions against liability, investigate and defend ourselves against any claims or allegations, or protect the security or integrity of our site; and/or (c) exercise or protect the rights, property, or personal safety of our employees, members, or others.

G. Anonymized and Aggregated Information

We may share anonymized, aggregated, or de-identified data we collect about you and other members with third parties, including advertisers and service providers. This may include de-identified demographic information, de-identified location information, and information about the computer or device used to access our Services or the results of hashing your email address.

V. CONTROLLING YOUR INFORMATION

We believe in transparency and providing you the opportunity to make important decisions about how your information is used, processed, stored, and shared, as outlined in this Section V (Controlling Your Information).

A. Modifying, Correcting, Reviewing, and Deleting Your Information

You can modify your account information, update or amend your personal information (e.g., Full Name or Birthday), or change your password by logging in to your App and clicking on "Settings" and then "Account" (for AutoSky+).

You can review the information we collect or disclose about you, the categories of sources for that information, the business or commercial purpose for collecting your information, and the categories of third parties with whom we disclose personal information. You can also request that your information be deleted by submitting a request as described below. Please note that the information provided via the in-App links described in this section does not include technical information or support records. If you would like to request information related to your support records, please contact us directly at privacy@promasterelectronic.com.

In the AutoSky+ app, you can:

● Request deletion of your personal information by going to the "Settings" and then the "Account" page, and selecting "Delete Account" to submit your request. We will process your request, and all your personal data, including GPS subscriptions, will be deleted.

Additionally, you can request the closure and deletion of your account by contacting us at privacy@promasterelectronic.com with your deletion request. Please include your full name, the email address associated with your account, and a detailed description of your deletion request.

Please note that we will retain the minimum information required by applicable law, as outlined in the Data Retention section.

B. Communications from Promaster Electronic

We may periodically send you promotional newsletters and emails. You can opt-out of these by following the unsubscribe instructions provided in the emails you receive. Certain communications, such as billing information and service updates, are necessary for you to receive, and you will not be able to opt-out of those communications.

C. Location and Movement Data Collection and Sharing in the AutoSky+ App

As mentioned in Section 2, we gather accurate location data as well as driving event and movement data from your device in order to provide AutoSky+ Services. We may share your personal information, including location and movement data, with other AutoSky+ members in the Party you are part of and with third parties for crash detection, research, analytics, attribution, and personalized advertising purposes. You have numerous options to manage this data collection and sharing activity through the App Settings.

If you decide to stop using the Products and/or Services, you can uninstall the AutoSky+, AutoSky GPS Trackers, turn off or disable the Products completely, and log out of our Service to prevent us from collecting your location data.

D. Web-Based Personal Information Sales

You can also exercise your opt-in and opt-out rights related to the sale or sharing of web-based personal information across all of our websites.

Please note that these settings must be completed for each browser on every device you use, and for each of our websites (Promasterelectronic.com, AutoSkyUS.com, AutoSky.io) individually. They will not affect App-based settings. If you clear your cookies or your browser is set to do so, you will need to make the choice again. If you want to modify how data is collected through the AutoSky+ application, you must do so separately by following the instructions above. If you haven't visited our sites, no action is needed

VII. PROTECTING YOUR INFORMATION

Promaster Electronic prioritizes the security of your information and makes significant efforts to safeguard your personal information. However, we cannot guarantee and it is unreasonable to expect that our databases will be completely immune to wrongdoings, malfunctions, illegal interceptions, unauthorized access, or other types of abuse and misuse.

A. Security

We have implemented suitable standards to minimize the risk of unauthorized or unlawful access to your personal information. No security system is foolproof, and we cannot absolutely guarantee the security of our systems and your information.

We will never send unsolicited messages or contact you by phone requesting sensitive information, such as account ID, password, payment details, or national ID numbers. Keep in mind that emails and other communications you send to us are not encrypted, so we strongly advise against sharing sensitive information through these channels.

In case any information under our control is compromised due to a security breach, we will take reasonable steps to investigate the situation and, when appropriate, notify affected individuals and take action in accordance with applicable laws and regulations.

B. Accuracy and Confidentiality of Your Email Address and Password

You are responsible for maintaining the confidentiality of your password and ensuring that the email address associated with your account(s) is accurate. We use your email address to contact you regarding service updates, policy changes, and account-related activities, such as information requests. We recommend using a strong, unique password for this service. If you suspect that your account has been compromised, change your password immediately via the relevant app or website.

Promaster Electronic is not liable for information or data transmitted to a third party as a result of a member providing an incorrect phone number or email address.

C. Fraud Prevention

To protect our Services from misuse by bots or other malicious means, we use anti-bot services to maintain the integrity of our service.

D. Data Retention

Promaster Electronic retains the information we receive, as described in this Privacy Policy, for as long as you use our Products or Services, or as needed to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business interests, enforce our agreements, and comply with applicable laws. Our retention is based on the amount, nature, and sensitivity of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. Different retention periods may apply to the same types of information, depending on the processing purposes.

Our Services may include links to websites and services owned or operated by third parties. Any information you provide to, or that is collected by, a third-party service is given directly to the owner or operator of that service and is subject to their privacy policy. Keep in mind that when you use a link to navigate from AutoSky, Promaster Electronic, and AutoSky+ Services to another website or app, or interact with a third-party service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interactions on any third-party website or service, including those with links on our website, are subject to the third party's own rules and policies. Promaster Electronic is not responsible for the practices employed by those apps, websites, or services, nor the information or content contained therein.

If you disagree with any changes to this Privacy Policy, you must stop using our Products and/or Services and may request that we erase your personal information. Any information collected through your use of our Products or Services is governed by the Privacy Policy in effect at the time of collection.

You may designate another person (your "agent") to contact us on your behalf. Authorized agents must submit their request via email to privacy@promasterelectronic.com and include a signed letter from the AutoSky+ member confirming that the agent has permission to submit the request on the member's behalf. In some cases, we may need to request additional information to verify the identity of the member in question and/or to confirm that the member has granted the authorized agent permission to submit the request. It may take more time to process agent-submitted requests. Please note that, for privacy and security reasons, we will direct future communications to the AutoSky+ member on whose behalf the request was made. We may refuse a request if we cannot verify the authorized agent's authority to act on your behalf.