background image On Time Connect Privacy & Cookie Policy This Privacy & Cookie Policy was last modified on June 25, 2024. On Time Connect protects and connects you and your loved ones to resources and emergency services to make your life easier and less stressful. We take your privacy as seriously as you do, and we are committed to protecting it. This Privacy Policy explains our practices regarding the collection, use, disclosure, transfer, storage, and protection of personal information that is collected through our products and services, as well as your choices regarding the same. As you review our policy, keep in mind that it applies to On Time Connect, LLC’s (“On Time Connect”, “we”, “our”, or “us”) websites, mobile app, help center and other associated services we provide (“Services”). It also applies to On Time Connect physical devices (e.g. Wrist Smart Watch, and any partner products that have location tracking technology embedded within them) as well as other products such as Labels (“Products”). Before accessing or using our Products and/or Services, please ensure that you have read this Policy and understand how we collect, store, use and disclose your personal information as described herein. Table of Contents I. INFORMATION WE COLLECT A. Information You Give Us Directly B. Information We Collect when You Use or Interact with our Products and Services C. Background Data Collection D. Information Provided to Us by Third Parties II. HOW WE COLLECT INFORMATION A. Cookies and Similar Technologies B. Analytics and Advertising Technologies III. HOW WE USE YOUR INFORMATION A. Administrative Purposes B. Marketing On Time Connect Products and Services C. Research and Development D. Connecting with Social Media E. Information Collected Automatically Through the use of Tracking Technology IV. INFORMATION WE DISCLOSE TO THIRD PARTIES A. Disclosing to Others B. Third Parties that Provide Features You Use in Connection with our Services C. Information Posted to our Blogs, Community Forums or Other Public Websites D. Service Providers, Business Partners and Advisors E. Purchasers and Other Third Parties in Connection with a Business Transaction F. Law Enforcement, Regulators and Other Parties for Legal Reasons G. De-Identified Information V. YOUR CHOICES ABOUT YOUR INFORMATION A. Modifying, Correcting, Reviewing and Deleting Your Information B. Communications from On Time Connect C. Location and Movement Data Collection and Sharing in the On Time Connect App D. Web-Based Personal Information Sales VI. OUR POLICY TOWARDS CHILDREN A. Setting up a Child Account B. Personal Information We Collect about Children C. Information sharing about Children D. Minors Generally E. Contact Us Regarding your Child’s Account or Information VII. HOW WE PROTECT YOUR INFORMATION A. Security B. Accuracy and Confidentiality of Your Email Address and Password C. Wrist Tracker Device Security D. Fraud Prevention E. Onward Transfer F. Data Retention VIII. ADDITIONAL STATE, COUNTRY AND REGION-SPECIFIC PRIVACY TERMS A. State Specific Consumer Privacy Laws B. International Transfer IX. LINKS TO OTHER WEB SITES AND SERVICES X. CHANGES TO THIS PRIVACY POLICY XI. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS A. Authorized Agents B. Right to Contact a Data Protection Authority XII. HUMAN RESOURCE INFORMATION MEXICO ADDENDUM TO THE PRIVACY NOTICE The Policy I. INFORMATION WE COLLECT The information On Time Connect collects depends on what On Time Connect Products or Services you use and how you use them. Note that failure to provide necessary information when requested may result in you not being able to fully utilize our Products and/or Services. A. Information You Give Us Directly When you create or modify an On Time Connect account, update your preferences, purchase and/or activate a Product, contact us (including by social media), participate in an online survey, or otherwise interact with On Time Connect’s Products and Services, we may collect a variety of information, including: • Account Information. Your username, email address, real name, nicknames, date of birth, telephone number, password, shipping and billing addresses, and Products activated. You may also be required or choose to provide a photo or facial scan to associate with your On Time Connect account or Products. • Identity Verification. In certain circumstances, for instance, depending on the features of our Products and Services you use or based on your age and relevant country of residence, we may collect additional information to verify that your parent or guardian has consented to your use of the Services which may include an image of their government-issued ID along with a selfie image which are used with facial recognition technology to produce a unique biometric identifier based on facial geometry. (Note: the digital age of consent may vary by jurisdiction and On Time Connect may adjust our parental consent process accordingly.) • Payment and Transaction Information. The jurisdiction you are located in pays for this Service pursuant to a contract with that jurisdiction. Any information that you provide to the Company is used for providing the Service or for the purpose of connecting you with resources in your area. • Other Information You Provide to Us. Information you provide in response to surveys about our Products or Services; any information about your friends that you provide us through our referral services, any information or content that you voluntarily submit or post to the On Time Connect websites or blogs, or comments you post to our Facebook page (or other social media pages), information you provide when seeking help from us, such as your name, email address, telephone number, mailing address and records (including call recordings) and technical information related to the issues you experience. B. Information We Collect When You Use or Interact with our Products and Services We may collect other information when you use our Products and Services, such as: • Device Information. Information about your device, hardware and software information, such as your mobile device identifiers, IP address, or browser information (including browser type and language preference), • Location and Movement Information. We collect your location and motion information through your IP address, Wi-Fi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device, motion information such as altitude, heading and speed. • Driving Event Information. We may collect sensory and motion data from your mobile device including gyroscope, accelerometer, compass and Bluetooth (including, information related to your motion activity such as whether you are cycling, walking running or driving, and information about your speed, acceleration and deceleration). • Messages and Member Content. We may collect information when you message other users through use of our Services, when you provide On Time Connect with feedback, when you make a blog post, comment, or when you tag On Time Connect in a social media post or any photos or videos you send via the in-app messaging to other users. Certain data we collect may be considered sensitive under applicable law. To the extent we collect sensitive personal information, we process such information for disclosed purposes as permitted by and in compliance with applicable law. C. Background Data Collection Our application may collect information while running in the background to enhance your experience and the functionality of the service. This data may include, but is not limited to, location information, app activity, and other relevant data. Background data collection allows us to provide real-time updates, improve the accuracy of location services, and optimize app performance. This information is handled with the same level of security and privacy as data collected while the app is actively in use. You can control and manage background data collection permissions through your device settings. D. Information Provided to Us by Third Parties We may receive information about you from other sources, including through third-party services that you may connect to your On Time Connect account, or third-party services and organizations to supplement information provided by you. For example: • When you link your On Time Connect account to a partner platform to enable interaction with our Products and Services that platform’s interactions or services (e.g. county websites or other programs offered by your relevant jurisdiction). • When you choose to connect or interact with our Services through a third-party social networking service (“Social Network”), such as when you Like us on Facebook or post a comment to our Facebook page, we may collect information that you have already made public on your Social Network account. • We may use social plugins, widgets and other features (each, a “Social Feature”) that are made available by and/or access third-party Social Networks. These Social Features allow these Social Networks to place cookies on your browser and to collect certain information, which may be associated with your personal Social Network account such as your name, your Social Network user identification number, your Social Network username, location, gender, birth date, email, profile picture, and your contacts on the Social Network. II. HOW WE COLLECT INFORMATION When you visit our websites, use our apps, read our emails or otherwise engage with us, we may automatically collect certain information about your device through a variety of technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “Tracking Technologies”), and we may combine this information with other personal information we collect about you. We use these Tracking Technologies to collect usage and device information, such as: • Information about the computer, tablet, smartphone or other device you use, for example, your device’s telephone number (if it has one), your 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 that allows us to uniquely identify your browser, mobile device or your account (including, for example, 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 Wi-Fi, and other such information. With your permission, we may also access your photo or camera roll. We also use Analytics, Advertising, and Anti-Fraud technologies in our Products and Services. These technologies may utilize the same cookies or similar mechanisms as further described below. A. Cookies and Similar Technologies 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 (such as your 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 member’s device, web beacons are typically embedded invisibly on web pages (or in an e-mail). B. Analytics and Advertising Technologies 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 are as follows: • 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; • 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); and • other similar actions. We may collect your personal information, including unique identifiers and data such as app events, for purposes including but not limited to analytics and research. This collection may occur in the background, even when the app is not actively in use. We do not share your information with social media companies or other third parties. We only share and collect your data in accordance with our contract and the relevant laws of your jurisdiction, specifically with the county (government), which is our client. Any data collected may be combined with information gathered directly through tracking technologies or received from other sources, solely for use by the county under their own privacy policies. User accounts are created by On Time Connect under a contract with the county. The information collected from GPS, documents, and photos is for the administrative use of On Time Connect only. This information is used to determine the proximity of users to one another. For reporting purposes, users are notified once a day to share their location and a photo upon request. III. HOW WE USE YOUR INFORMATION We may use and disclose your information to service providers 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 de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such information as necessary for our business purposes and as permitted by applicable law. The specific purposes for our acquisition, retention, use, and processing of your information are described in this Section III (How We Use Your Information). A. Administrative Purposes We may use information about you for our administrative purposes, including to: • Provide the Products and Service to you; • Measure interest in On Time Connect’s Products and Services; • Develop new products and Services; • Ensure the integrity, security and perform internal quality control and optimization of our Products and Service; • Verify individual identity; • Communicate about individual accounts and activities utilizing On Time Connect’s Products, Services, and systems; • Make changes to any On Time Connect policies; • Send messages to the email address you provide to us to verify your Account; • For informational, transactional, marketing and operational purposes, such as Account management, customer service, or system maintenance; • To prevent potentially prohibited or illegal activities; and • To enforce our Terms of Use and this Privacy Policy. B. Marketing On Time Connect Products and Services On Time Connect may use information, and Individuals who provide us with personal information may receive periodic emails, newsletters, mailings, or phone calls from us, as allowed by applicable law, for marketing purposes such as to: • Provide you with information related to On Time Connect’s or our business partners’ products and services that may be of interest to you; • Conduct research and drive marketing analytics; • Introduce new content, features, Products or Services; and • For other purposes disclosed at the time that you provide us your information; or otherwise with your consent. C. Research and Development We may use information to create non-directly identifiable information that we may use alone or in the aggregate with information obtained from other sources as set forth herein, in order to: • Help us to optimally deliver our existing Products and Services; • To develop new Products and Services; • For research, and internal analysis; D. Information Collected Automatically Through the use of Tracking Technology We may use information collected through the use of Tracking Technologies (e.g. cookies and web beacons) to: • Remember information so that you will not have to re-enter it during your visit or the next time you visit our website or use our Services; • Authenticate your access; • Keep track of your in-app specified preferences or choices; • Record your device’s location and movements; • Identify and contact you across multiple devices; • Monitor aggregate metrics such as total number of visitors, members, traffic, and demographic patterns; • Provide specific technical support (diagnose or fix technology problems reported by our members or engineers that are associated with certain IP addresses or User IDs; • Detect or prevent fraud or other harmful activities; • Automatically update our mobile application on your system and related devices; and • Otherwise plan for and enhance our Services. IV. INFORMATION WE DISCLOSE TO THIRD PARTIES We disclose your information to select third-parties as well as our subsidiaries as set forth below. We will not disclose your personal information to independent third parties other than in the circumstances discussed in this Privacy Policy without your prior consent. We may also use and disclose your information for our protection and the protection of others to prevent fraud, misappropriation, infringements, identity theft, and other illegal activities and misuse of our Products and Services. We may disclose this information within On Time Connect, with our subsidiaries, and with third parties for our or their purposes. A. Disclosing to Others Depending on which tools and functionalities are enabled, you may choose to disclose your personal information to other users including your: • Full name; • Email address; • precise location; • driving event data; • information about your use of our Service with other users (e.g. whether you have logged in on a new device); and • Wrist Smart Watch information. In addition, other Users may disclose your personal information in certain circumstances, such as your location in relation to them for purposes of enforcing a temporary restraining order or any other judicial determination that prevents one User from being in the same location as another. B. Third Parties that Provide Features You Use in Connection with our Services We may disclose personal information, including contact information and location and movement data, mobile device information (such as information generated by the gyroscope and accelerometer in your device), application analytics (including IP address and device identifiers), technical and analytical data, and driving event data with third-party partners that provide certain features and services in connection with our Products or Service, to the extent that they are available in your country or region of residence. Some examples are as follows: • Emergency Dispatch Services; • Law enforcement assistance; • Social services assistance; and • Driving analytics services. C. Information Posted to our Blogs, Community Forums or Other Public Websites Any information or content that you may voluntarily submit, or post to any On Time Connect website or blogs, community forums, or comments you post to our Facebook page (or other social media pages) will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile app or link your reviews to third-party websites. We are not responsible for any information you choose to provide on social media pages, or for 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 info@ontimeconnect.com. D. Service Providers, Business Partners, and Advisors We may disclose your personal information to our third-party partners who perform services on our behalf or who help us provide our Services, such as accounting, managerial, technical, email or chat services, marketing or analytic services, fraud prevention, bot detection, web hosting, and to other third-party partners or service providers who contractually agree to process personal information solely as necessary to provide services or features to our members on our behalf. Importantly, and for the avoidance of doubt, locations associated with your Products whether they appear in apps, on the website, or on the Wrist Smart Watch will not be sold to or monetized by third parties even in aggregated form. We will never disclose your telephone number (in a non-obfuscated format) with any of our third-party business partners, vendors, or consultants for their independent SMS marketing purposes without your explicit, affirmative opt-in consent. E. Purchasers and Other Third Parties in Connection with a Business Transaction We may at any time buy or sell/divest the company, or any portion or combination of its products, services, assets and/or businesses. Personal information such as user names and email addresses, and other user information related to our Services will likely be one of the items transferred in these types of transactions. We may also disclose, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, or similar transactions or proceedings. F. Law Enforcement, Regulators, and Other Parties for Legal Reasons We may disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) when required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use [Hyperlink to Terms of Use], this Privacy Policy, to take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of On Time Connect, our employees, members or others. V. YOUR CHOICES ABOUT YOUR INFORMATION We believe in transparency and providing you with the opportunity to make important decisions about how your information is used, processed, stored and shared as outlined in this Section V (Your Choices about Your Information). If you would like more detailed information about the information we have, shared, sold, or disclosed please contact us at info@ontimeconnect.com. A. Modifying, Correcting, Reviewing, and Deleting Your Information You may not modify your account information, update or amend your personal information (e.g. name, email address, or phone number), or change your password by logging in to your App, clicking on “Settings” and then “Account” (for On Time Connect) or “Manage Account.” Your probation officer or jurisdictional contact sets up and manages the account for you. Please note, we will retain minimum information as required by applicable law, as outlined below in Section VII(F) (Data Retention). B. Location and Movement Data Collection and Sharing in the On Time Connect App As described in Section 2, we collect precise location data and movement data from your device to provide the On Time Connect Services, and may share your personal information, including location and movement data, with other On Time Connect users, and with third parties for legal enforcement of court orders, research, and analytics. If you no longer want to or are required continue using the Products and/or Services, please contact your jurisdiction. On Time Connect provides its Services to your jurisdiction. Any inquiries about your account status should be directed to your probation officer or jurisdiction contact. VI. OUR POLICY TOWARDS CHILDREN On Time Connect takes special precautions to protect the privacy of our younger members. In accordance with the Children’s Online Privacy Protection Act (“COPPA”), On Time Connect does not knowingly collect personal information from children under the age of 13, 16 in California, (a “child”) without verifiable consent of a parent or guardian, and our Services are intended to be used by children under 13 only with significant parental or guardian involvement and approval. If On Time Connect learns that we have inadvertently collected personal information of a child without parental consent as required by law, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child has a registered account with our Services or is using our Products without your consent, please alert us immediately by emailing info@ontimeconnect.com. By enabling your child to create a member account and/or permitting your child to use the Products or Services, you expressly agree to the practices described in this Privacy Policy and you consent to the collection, use, and disclosure of your child’s personal information as described herein. A. Setting up a Child Account If a parent wishes to add a user who is a child to our Services, we request the parent provide verifiable consent when required by COPPA, through one of several methods, such as by verifying the parent’s driver’s license or by submitting a parental consent form (available here) [Hyperlink to Parental Consent Form] via the relevant jurisdiction contact. The child will then be able to participate in all aspects of On Time Connect’s Services. By providing the Products to a child, you represent and warrant to On Time Connect that you consent to such child’s use of our Products and Services and further consent to parent to enable and permit On Time Connect’s collection and use of the information from the Products and Services used by the child as stated in this Privacy Policy and the Terms of Use[Hyperlink to Terms of Use]. B. Personal Information We Collect about Children We take special precautions to collect only as much information as is reasonably necessary for the child to use our Products and Services. C. Information sharing about Children On Time Connect may disclose a child’s personal information to our third-party partners, service providers, and business partners as described in this Privacy Policy. However, we do not share or sell personal information collected from the accounts of children for marketing or advertising purposes, nor do we permit our service providers and business partners to collect and use such information for advertising purposes. The child’s profile information and location will be shared with other users as necessary for the child to use our Service as intended. Please note the child will be able to share his or her location with other users and may be able to exchange messages with those users. You are responsible for monitoring your child’s account and location-sharing activity through our Products and Services and for blocking or permitting location-sharing features. D. Minors Generally We do not sell the personal information of users we know to be less than 16 years of age. If you are under the age of 18 and you want to remove your name or comments from our website or publicly-displayed content, please contact your probation officer or jurisdiction contact. We may not be able to modify or delete your information in all circumstances. E. Contact Us Regarding your Child’s Account or Information The parent or legal guardian has a right to request to review or have deleted the child’s personal information and may withdraw consent for our Products and Services to collect any further personal information from the child. Please contact us at info@ontimeconnect.com to request to review and/or delete any personal information we may have collected from the child, or to withdraw permission for On Time Connect to collect any additional information from the child. We will require the parent or guardian to provide us with sufficient identification before providing access to, or acting upon, such personal information. VII. HOW WE PROTECT YOUR INFORMATION On Time Connect cares about the security of your information and we take great efforts to protect your personal information. We cannot guarantee and you cannot reasonably expect that our databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. A. Security We have implemented appropriate standards to reduce the risk of unauthorized or unlawful access of your personal information. No security system is impenetrable and we cannot absolutely guarantee the security of our systems and your information. We will never send you unsolicited messages or contact you by phone requesting sensitive information. This may include account ID, password, payment, or national ID numbers. Please note that e-mails and other communications you send to us are not encrypted, and we strongly advise you not to share any sensitive information through these means. If any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify the impacted individuals and take steps in accordance with any applicable laws and regulations. B. Accuracy and Confidentiality of Your Email Address and Password You are responsible for the secrecy of your password and ensuring the email address associated with your account(s) is accurate. We may use your email address to contact you about service updates, changes to our policies, and account activities such as requests for your information. We recommend using a strong password unique to this service. If you believe your account has been compromised, change your password immediately via the applicable app or website. On Time Connect is not responsible for information or data transmitted to a third party as a result of a member providing an incorrect phone number or email address. C. Wrist Smart Watch Device Security On Time Connect take its User’s privacy very seriously. Any User’s location data that may be stored by On Time Connect will be held on a secure server; however, no server is completely free of issues. On Time Connect is not responsible for any secure server malfunctions that occur as a result of third-party actors or any other circumstance outside our control. EACH USER HEREBY INDEMNIFIES AND HOLDS HARMLESS ON TIME CONNECT FOR ANY HARM OR DAMAGES THAT MAY RESULT FROM A BREACH OF THE SECURED SERVER AS A RESULT OF CIRCUMSTANCES THAT ARE OUTSIDE THE COMPANY’S CONTROL WHETHER BY A THIRD-PARTY ACTOR, NATURAL DISASTER, ACTS OF TERRORISM, INSURRECTION, WAR, OR ANY OTHER CIRCUMSTANCE WHICH THE LAW CONSIDERS A FORCE MAJUER. D. Fraud Prevention To prevent the misuse of our Services by bots or other nefarious means, we may use anti-bot services to ensure the integrity of our service, for more information please email us at info@ontimeconnect.com E. Onward Transfer With respect to onward transfers to third-party agents acting on our behalf, On Time Connect does not remain liable should its agents process information in a manner inconsistent with the Privacy Shield Principles or other applicable laws. We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. F. Data Retention On Time Connect retains the information we receive as described in this Privacy Policy for as long as you use our Products or Services or as otherwise necessary to fulfill the purpose(s) for which it was collected, to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business interests, enforce our agreements, and to comply with applicable laws. Our retention is based upon the amount, nature, and sensitivity of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information may dictate different retention periods for the same types of information. VIII. ADDITIONAL STATE, COUNTRY, AND REGION-SPECIFIC PRIVACY TERMS A. State Specific Consumer Privacy Laws State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. Information about the privacy laws that may be applicable to your state are as follows: • California. To learn more about California residents’ privacy rights, visit [HYPERLINK TO CCPA AND CPRA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS IF COMPANY INTENDS TO DO BUSINESS IN CALIFORNIA IN THE NEAR FUTURE]. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App 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 info@ontimeconnect.com. • Nevada. Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to info@ontimeconnect.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements. Additionally, Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to: · Confirm whether we process their personal information. · Access and delete certain personal information. · Data portability. · Opt-out of personal data processing for targeted advertising and sales. Colorado, Connecticut, and Virginia also provide their state residents with rights to: · Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose. · Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise any of these rights please email info@ontimeconnect.com. B. International Transfer As we are located in the USA, you agree that all information collected via or by On Time Connect may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, Mexico, Canada, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to On Time Connect you explicitly consent to the storage of your information in these locations if you are in the EEA, Switzerland, or the UK, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will implement appropriate safeguards to ensure that your personal information is treated securely and in accordance with applicable EEA and UK privacy laws and this privacy policy, including: (i) ensuring that we use your personal information in accordance with standard data protection clauses adopted by the European Commission for transfers of personal data to recipients outside the EEA and UK; and (ii) ensuring that any recipients of your personal information commit to the same standards. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy notice. IX. LINKS TO OTHER WEBSITES AND SERVICES Our Services may contain links to websites and services that are owned or operated by third parties. Any information that you provide on or to a third-party service, or that is collected by a third-party service, is provided directly to the owner or operator of the third-party service and is subject to the owner’s or operator’s privacy policy. Please remember that when you use a link to go from the On Time Connect Services to another website or app, or engage with a third-party service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction, on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies, and On Time Connect is not responsible for the practices employed by those apps, websites, or services, nor the information or content contained therein. X. CHANGES TO THIS PRIVACY POLICY We may update this Privacy Policy from time to time, so please review it frequently. We will notify you of material changes thirty days before they go into effect. If we are required by applicable data protection laws to give you enhanced notice or seek out consent to any such changes, we will do so. Otherwise, changes to this policy will be effective when posted. If you object to any of the changes to this Privacy Policy, you must cease using our Products and/or Services, and may request us to erase your personal information. Any information that is collected through your use of our Products or Services is covered by the Privacy Policy in effect at the time such information is collected. XI. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS If you have any questions about our privacy practices, this Privacy Policy, our Products, or Services, please contact us at info@ontimeconnect.com or by postal mail to: 3201 Cherry Ridge Drive Suite B-216 San Antonio, TX 78230 A. Authorized Agents You may authorize another person (your “agent”) to contact us on your behalf. Authorized agents must submit the request via email to info@ontimeconnect.com and include a signed letter from the On Time Connect user confirming the agent has permission to submit the request on the user’s behalf. In certain circumstances, we may need to request additional information to verify the identity of the member about whom the request is being made and/or to verify that the member has provided the authorized agent permission to submit the request, and it may take additional time to fulfill agent-submitted requests. Please note that for privacy and security reasons, we will direct future communications to the On Time Connect user on whose behalf the request was made. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf. B. Right to Contact a Data Protection Authority You also have the right to contact your local Data Protection Authority if you prefer. We are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC). XII. HUMAN RESOURCE INFORMATION We collect information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a Curriculum Vitae (CV) or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin, veteran or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals. We acquire, hold, use and Process Human Resources Data for a variety of business purposes including: workflow management, including assigning, managing and administering projects; Human Resources administration and communication; payroll and the provision of benefits; compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs; job grading activities; performance and employee development management; organizational development and succession planning; benefits and personnel administration; absence management; helpdesk and IT support services; regulatory compliance; internal and/or external or governmental compliance investigations; internal or external audits; litigation evaluation, prosecution, and defense; diversity and inclusion initiatives; restructuring and relocation; emergency contacts and services; employee safety; compliance with statutory requirements; processing of employee expenses and travel charges; and acquisitions, divestitures, and integrations. MEXICO ADDENDUM TO THE PRIVACY NOTICE To the extent Mexican privacy laws or regulations apply, the following additional Mexico-specific provisions apply and shall prevail over conflicting provisions in the Privacy Notice. How We Use The Information We Obtain We may use your personal information for the following primary purposes, which are directly linked to the Service we provide to you and your legal relationship with us. • Provide customer support and respond to and communicate with you about your requests, questions and comments • Process claims we receive in connection with our services • Comply with applicable legal requirements and our policies • Provide our Service to the Jurisdiction as anticipated by our Contract with that Jurisdiction In addition, we may use your personal information for the other purposes listed in the “HOW WE USE YOUR INFORMATION” section of the Privacy Policy, which may be considered secondary purposes under Mexican law. We do not use or share personal information except where there is a legal basis. If we transfer your data for a secondary purpose, then we will obtain your consent and keep evidence of such consent. You may withdraw your consent to our processing of your personal information by contacting us as indicated in the Privacy Policy. If you withdraw your consent for us to process your personal information for one of the primary purposes indicated above, then in some situations we may not be able to provide the service, though we may still engage in certain processing authorized by law. Information We Share We may share your personal information as provided in the Privacy Policy, but, to the extent permitted by law or the officer over seeing your matter, you may withdraw your consent to this sharing by contacting us as indicated in the Privacy Policy.