Introduction

This Privacy Policy aims to give you information regarding how Montaro, Inc. (formerly Montaro, LLC) collects and uses your personal data through your use of our website. Personal data is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. It is important that you read this Privacy Policy so that you are fully aware of how we collect, use, protect, or otherwise handle your personal data. This Privacy Policy applies to all websites owned and operated by Montaro, Inc. (“we”, “us”, “our”).

This Privacy Policy was last updated on August 1, 2021.

When you visit our website, you have choices about whether to provide us with information and how we use that information. You may choose not to provide us with information, but your choice(s) may prevent you from contacting Montaro directly or limit your use of certain features. For example, if you do not provide us with an email address we cannot respond to your inquiry.

We may update this Privacy Policy to reflect changes in the law, our services, our company, or advances in technology. We reserve the right to change this Privacy Policy from time to time without notice. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically to familiarize yourself with any modifications. Your continued use of this site, our services, or our technology after such modifications will constitute acknowledgment and agreement of the modified terms and conditions. Our use of the information we collect is subject to the Privacy Policy in effect at the time such information is used.

Information We Collect & Use

Some of the information we collect is provided by you, some is collected automatically, and some may be collected from other sources.

INFORMATION YOU PROVIDE

When you use our website, you may submit an inquiry request to Montaro and will be asked for the following personal information:

• Name
• Company Name
• Phone Number
• Email Address
• Additional information you voluntarily provide

INFORMATION WE AUTOMATICALLY COLLECT

We automatically collect certain information to help us understand how visitors use our website. For example, each time you visit our website we automatically collect your IP address, location information, browser and computer type, access time, the webpage from which you came, and the webpage(s) that you access during your visit.

ANALYTICS

We may use Google Analytics or other providers to understand better how individuals and their devices interact with the Services.

COOKIES AND RELATED TECHNOLOGIES

We may use cookies (which are small amounts of data sent from a web server to your browser that are stored on your computer hard drive) to validate your identity, tailor our website to meet your personal interests, improve the quality of our website, or learn about your online activity and preferences. Generally, you can set your browser not to accept cookies or to notify you if you are sent a cookie, giving you the opportunity to choose whether or not to accept the cookie.

PLUG-INS

Our website may offer you the ability to interact with plugins from websites, which allows Montaro to receive data from or about you. In some cases, we may know that you clicked on a plugin.

How We Use Information & Lawful Bases

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to provide you requested information, respond to a survey or marketing communication, or respond to your customer service requests.

For purposes of European Union data protection laws, we process personal data where:

• We need to perform the contract we are about to enter into or have entered into with you, such as when we process a payment.
• It is in our legitimate interests (or those of a third party) and your data protection interests and fundamental rights and freedoms do not override those interests, such as when we secure the services, engage in fraud prevention, and direct marketing.
• We need to comply with a legal or regulatory obligation.
• We have your consent to do so. We do not generally rely on consent as a lawful basis for processing your personal data, but you have the right to withdraw consent to marketing at any time by contacting us.

We may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device, which can help support our research and marketing efforts. This Privacy Policy does not apply to our use of such aggregated or de-identified information.

Location of Data Processing

Information that we collect and use is processed in the United States. By accessing our website, you acknowledge that your information will be processed as described in this Privacy Policy.

How We Protect Your Data

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to a limited number of employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

THIRD PARTY DISCLOSURE

We do not rent, sell or share information except as described in this Privacy Policy. We may share your personal data with service providers and other third parties if necessary to fulfill the purposes for collecting the information, provided that any such third party will commit to protect your privacy as required under the applicable law and this policy.

We may share personal data with law enforcement, government agencies, courts, or other organizations: (a) as required by law, such as to comply with a subpoena or similar legal process; or (b) when Montaro believes in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

We may share or transfer personal data if Montaro is involved in a merger, acquisition, or sale of all or a portion of its assets, as part of such transaction. In any event, your information will remain protected under this Privacy Policy.

We may share it in any other circumstances where Montaro receives your written consent.

RETENTION OF PERSONAL DATA

We keep your information for the time period required to complete the purposes for which it is processed or satisfy legal requirements. The length of time for which we retain information depends on the purposes for which we collected and use it or the requirements of applicable laws.

OPT-IN CHOICES & LEGAL RIGHTS

You will be given an opportunity to opt-in to targeted communications from Montaro. If you opt-out, Montaro will only respond to direct inquiries and will not use your personal information to contact you for any other purpose.

Furthermore, you have the legal right to:

• Access the data that we keep about you. We may need to ask you to provide us certain credentials to make sure that you are who you claim you are. If you find that the data is not accurate, complete, or up-to-date, then you may provide us with the necessary information to rectify it.
• Contact us if you want to withdraw your consent to the processing of your personal information. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
• Request to delete or restrict access to your personal information. We may postpone or deny your request if your personal information is in current use for providing our services or for other legitimate purposes such as compliance with regulatory requirements.
• You may ask to transfer your personal information in accordance with your right to data portability.
• You may object to the processing of your personal information for direct marketing purposes.
• You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
• You have a right to lodge a complaint with a data protection supervisory authority.

If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold your personal information, in accordance with this Policy, will act accordingly.

We do periodic assessments of our data processing and privacy practices to ensure that we comply with this Privacy Policy, to update this Privacy Policy when needed, and to verify that this Privacy Policy is displayed properly and is accessible.

If you have any concerns about the way we process your personal information, you are welcome to contact info@montro.co.

We will investigate your inquiry and make good-faith efforts to resolve any existing or potential dispute with you. If you are unhappy with the response you receive and reside in the EU, you can also refer the matter to the Information Commissioner’s Office (ICO).

CHILDREN’S PRIVACY

We do not knowingly collect or solicit “personal information” (as defined by the U.S. Children’s Online Privacy Protection Act) from anyone under the age of 13. If you are under 13, please do not attempt to contact us or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information. If you believe that a child under 13 may have provided us personal information, please contact us at info@montaro.co.

For residents of the EU, where processing of personal data is based on consent, we will not knowingly engage in that processing for users under the age of consent established by applicable member or data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.

CALIFORNIA RESIDENTS

If you are a California resident, you may ask for a list of third parties that have received your information for direct marketing purposes during the previous calendar year. This list also contains the types of information shared. We provide this list at no cost. To make such a request, contact us at info@montaro.co.

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Montaro, Inc. and applies solely to users who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

PERSONAL DATA THAT WE COLLECT:

• Advertising Identifiers. Advertising identifiers are unique strings associated with your mobile device that are provided by the operating system. Certain advertising identifiers may be modified or disabled by users in the operating system’s settings.
• Geolocation Data. When you access or use the Services using a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to us information about how you browse and use the Services. Some features of the Services, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
• Commercial Communications. Insofar as permitted under applicable law, we may use the information we collect or receive to communicate directly with you in relation to the Services or related services we offer. Subject where legally required to your consent to receiving such communications, we may use the information to communicate with you in relation to other services that we offer. For example, we may use the information to send you emails containing newsletters, promotions and special offers. We may also use the information to send you service-related notices (e.g., account verification, technical and security notices).
• Internet or other similar network activity. We may use information from browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
• Use of Certain Service-Type information. We may use information from cookies, log files, device identifiers, location data, clear GIFs and other tools to: (i) remember information so that you will not have to re-enter it during your visit or the next time you use the Services; (ii) provide custom, personalized content or information to you or others; (iii) monitor the effectiveness of the Services; (iv) monitor aggregate metrics, such as total number of visitors, traffic and demographic patterns; (v) diagnose or fix technology problems; (vi) provide advertising to your browser or device; and (vii) conduct research or surveys. (k) Use of information with Your Consent. We may use your information for any other purpose for which you provide consent.

Personal information does not include:

• Publicly available information from government records.
• De-identified 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 (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents.
• Indirectly from our clients or their agents.
• Directly and indirectly from activity on our website.
• From third parties that interact with us in connection with the services we perform.

HOW WE USE PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• 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 is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without updating our policy.

SHARING PERSONAL INFORMATION

Montaro, Inc. may disclose your personal information to a third party for a business purpose. In the preceding twelve (12) months, Montaro, Inc. has not disclosed any personal information.

SALES OF PERSONAL INFORMATION

In the preceding twelve (12) months, Montaro, Inc. has not sold 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 Montaro, Inc. 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, 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.

DELETION REQUEST RIGHTS

You have the right to request that Montaro, Inc. Inc 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, we will 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, 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.

EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS

To exercise the access, data portability, and deletion rights described above, you can initiate the process by emailing info@montaro.co. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

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.
• 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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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 except as outlined by the CCPA.

CONTACT INFORMATION

If you have any questions or concerns regarding this Privacy Policy or Montaro’s use of your data, please send a detailed message to info@montaro.co.