INTRODUCTION

Welcome to REEF. REEF Global, Inc. (“the Company,” “we” or “us”) and its affiliates and subsidiaries (collectively “the Company,” “we” or “us”) are committed to protecting the privacy of information collected from you when you access our websites (the “Sites”), products, services, mobile applications (the “Apps”), when you visit a physical location owned or operated by us, such as a parking or kitchens facility (together, the “Services”). The nature of our business requires that we gather and maintain information of a personal nature that you may wish to keep protected. When you access or use the Services, we collect information that identifies, relates to, describes, and is reasonably capable of being associated with a particular consumer, household, or device (“Personal Information”).

This Privacy Policy (“Policy”) describes our policies and practices regarding the collection, use and disclosure of Personal Information you submit or we obtain in connection with your use of our Services. Please read this Policy carefully before using any of our Services or submitting information to us. By using the Services, you indicate your understanding that the collection, use, and sharing of your information is subject to the terms of this Policy. If you do not want your information to be collected, used, and shared as described in this Policy, please do not use our Services or provide us with such information.

If you are located in the United Kingdom, you may have additional rights. Please see our UK section below for more information.

Changes to this Policy 

We reserve the right to change this Policy at any time. In the event we make material change(s) to the Policy, changes will be effective immediately upon posting to our Sites and/or Apps and will apply to your use of our Services after the “Last Updated” date listed above. You understand that your continued use of our Services after the Last Updated date, means that the collection, use, and sharing of your information is subject to the updated Policy.

Except to the extent we obtain your consent or as permitted or required by applicable law, we will handle your Personal Information collected through our Services in accordance with the terms of the Policy in effect at the time of such collection.

Information We Collect   

As you are probably aware, we may collect information from a variety of sources to operate our Services, carry out our business, comply with law and other purposes described herein.

Information You May Provide. When you use our services (such as registering an account with us or using our Apps) or otherwise correspond with us, we collect Personal Information you provide to us. Personal Information collected in this manner includes your name, postal address, zip code, email address, telephone or mobile number, user name and password, and payment information; it may also include the make, model, and color of your car, your license plate number, driver’s license and other government-issued identification documentation.

To subscribe to newsletters, e-blasts, e-news, respond to surveys, contact us or to request information, we may ask you to provide your name, email address, postal address, organization, or affiliation. If you respond to a job posting or apply for employment with us, we collect Personal Information you provide in your application, resume, or other communications.

Information From Third Parties. We may receive Personal Information from other sources. For example, if you connect your social media account(s) to your account with us, the social media site may share information with us about your use of their services, including information about your profile, contacts, and viewed or liked content. We encourage you to read the applicable privacy policies for your social media accounts. We have no responsibility for and are not liable for the data collection and use practices of those social media sites.

Information Collected Through Automated Technologies. We and our Service Providers also collect Personal Information and other data through automated data collection technologies, such as cookies or pixel tags. This information tells us about how people use our Services so that we can analyze their effectiveness and provide you with a better web or app experience. We collect and use this information through a variety of technologies, as discussed below.

1. Statistical Data
   To monitor use of our Services and improve their quality, certain information is gathered automatically and stored in log files. This information includes: 
   • Your IP address
   • Your operating system version
   • Your browser version
   • Your device information, including identifiers
   • Internet service provider
   • The pages you visit on our Site or Apps
   • The length of time you spend on pages on the Site or Apps
   • The site from which you clicked to visit our Site
   • Search terms you used in search engines that resulted in you visiting our Site
     
     
2. Cookies and Other Tracking Technologies
   We may use technologies such as cookies, pixel tags, and browser analysis tools, to recognize you when you return to our Sites and to help us improve the quality of our service when you visit our Sites. We may also use cookies and related technologies to tailor our products and services to suit your personal interests, estimate our audience size, track visits to our Sites and, as applicable, to process your requests.A cookie contains a unique alphanumeric identifier that websites use to help identify unique visitors to our Sites, whether or not those visitors are repeat visitors, and the source of the visits. You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Please note that certain features of our Sites may not be available once cookies have been disabled. Please refer to the Help feature of your browser for information on disabling cookies.We may also use pixel tags (also called web beacons or clear GIFs), which are tiny invisible graphic images, in the Sites. Pixel tags may be used by us to count users who have visited its webpages and for related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

   We may also collect location information, which may include precise location information when you permit our Services to access your device location.
   Some of our email or text communications to you may contain a “click-through URL,” which links to content on our Sites. When you click one of these URLs, it passes information through our web server before you arrive at the destination web page. We track this click- through data to help determine interest in particular products and measure the effectiveness of our communications. If you prefer not to be tracked, simply avoid clicking text or graphic links in emails or texts you receive from us.

3. Third Party Analytics We use applications supplied by third parties, such as Google Analytics, to evaluate usage of our Sites and Apps. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our user experience. These devices and applications may use cookies, tracking pixels and other tracking technologies to perform their services. The analytics service providers may transfer information they collect or receive to third parties in case of a legal obligation or if a third party processes data on behalf of that service provider.
4. Do Not Track “Do Not Track” is a draft standard developed by the World Wide Web Consortium designed to allow you to set your internet search browser to send a signal to a website that you do not want the website operator to track certain browsing information about you. As this Do Not Track is still a draft standard, our Sites and Apps are not configured to respond to Do Not Track requests.In the 12 months preceding the Last Updated date of this Policy, we have collected the following categories of Personal Information from consumers:
   
   

   CATEGORY

   EXAMPLE

   Identifiers

   A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, vehicle license plate, account name.

   Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)):

   A name, address, telephone or mobile number, bank account number, credit card number, debit card number, education, employment. Some Personal Information included in this category may overlap with other categories.

   Commercial Information.

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

   Internet or other similar network activity.

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

   Geolocation data.

   Physical location or movements.

   Sensory data.

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

   Inferences drawn from other Personal Information.

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

How We Use Your Data

In general, we will use the information we collect about you only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in this Policy. If you are located in the United Kingdom, we have also set out the legal basis under data protection laws in the United Kingdom for each of the processing purposes. We may use your data:

• To provide you with the products and/or services you have requested. This is necessary to perform the contract with you.
• To respond to your requests for information about the Company or relating to activities, opportunities, events, services or products appearing on the Sites or the Apps. This is in our legitimate interests in order to respond to your requests.
• To communicate with you. We may send you messages about the availability of our Sites, our Apps, security, or other service-related issues. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices. This is in our legitimate interests to send such service messages to you.
• For our research and development efforts. We may use data, including public feedback and surveys, to conduct research and for the development of our Services,
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  technology platforms, fulfillment, analytics, fraud prevention and to prevent other violations of law, corporate governance, reporting and legal compliance, including responding to legal process such as court orders, warrants or subpoenas). It is in our legitimate interests conduct research and development for the above purposes, and necessary for compliance with legal obligations that we are subject to in relation to court orders, warrants or subpoenas or legal compliance.
• For advertising and marketing purposes, and to inform you of the products, services, events, or activities that we think may be of interest to you. For example, we may send you announcements, surveys, and newsletters using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-App messaging, and other means. It is in our legitimate interests to inform you of products, services or activities that may be of interest to you. Where required by applicable law, we may also rely on your consent to send such messages to you.
• To facilitate contests, sweepstakes and promotions, and process and deliver entries and rewards. It is in our legitimate interest to facilitate such contests, sweepstakes and promotions.
• To ensure your information is accurate and to personalize our communications to you. For example, we may aggregate your Personal Information with data from third-party sources for purposes of keeping information up to date. We may also rely on information from third parties in order to provide better, more personalized service. If you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal and social, or share and use it as described elsewhere in this Policy. It is in our legitimate interests to personalize our communications to you and to ensure your information is accurate.
• As otherwise described to you at the point of data collection.

We do not sell your Personal Information to any third-party advertisers for their advertising.

If you no longer wish to receive a marketing or promotional communication from the Company, you have the option of unsubscribing from our mailing list for that type of communication.

How We Share Your Data

We will not disclose your Personal Information we collect through our Services except as described in this Policy. We may disclose your data for the same reasons that we may use it as described in this Policy, which includes disclosing it to our affiliates and non- affiliated entities, as we deem necessary to carry out those purposes. We do not sell or share your Personal Information to third parties for purposes of cross-contextual behavioral advertising.

• We may disclose on an aggregated basis, personal demographic information to investors and other interested stakeholders who require such information.
• Third Party Partners. Our third party partners can include our Service Providers, landlords, parking, kitchen and other facility owners, operators and administrators where you receive services, or even your employer who uses us as a means to provide you with an employee benefit or privileges related to parking. We may disclose your information to our third party partners:
  With your consent or as you direct;
  ° To manage the Sites or the Apps;
  ° To provide you with products or services
  ° To manage our relationship with our partners where we provide our services to you;
  ° To provide you with offers or opportunities;
  ° To manage your relationship with our partners who you have an ongoing relationship with (for example, your employer who provides you with a parking benefit or privilege);
  ° To engage in fundraising related activities;
  ° To enhance our services by, among other methods, obtaining assistance with providing more personalized services to you through analytics and other technologies;
  ° To protect our interests and legal rights, such as by responding to subpoenas or defending or prosecuting legal claims; and
  ° To protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.
  
  

We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data

• Legal Process, Security, Defense, Protection. It is possible that we will need to disclose information about you if required by law, subpoena, or other legal process.
• Additionally, we may disclose information about you if we have a good faith belief that disclosure is reasonably necessary to:
  ° Fulfill our obligations under relevant law or contract;
  ° Investigate, prevent, or take action regarding suspected or actual illegal activities, security incidents, or to assist law enforcement agencies;
  ° Protect the security or integrity of the Site or the Apps;
  ° Investigate, prevent, or take action regarding suspected or actual illegal activities, security incidents, or to assist law enforcement agencies;
  ° Protect the security or integrity of the Sites or the Apps;
  ° Investigate, prosecute, or defend ourselves in connection with any allegations or claims; or
  ° Protect our rights and the rights and safety of others.
• Change in Control or Sale. We may share, transfer, assign, or license your Personal Information in connection with certain business transactions, such as a sale, acquisition, financing, merger, or change in control, or in preparation for any of these events. In such cases, we will take appropriate steps under the circumstances and to the extent possible to ensure that the recipient agrees to provide privacy protections substantially similar to those established by this Policy. Any entity that acquires all or substantially all of the Company’s assets will have the right to continue using your data consistent with this Policy or as otherwise agreed to by you.
• Social Media Plugins. Our Sites or Apps may use social media plugins (e.g., Facebook, Twitter, and LinkedIn) to enable you to easily share information with others. When you visit our Sites or use our Apps, the operator of the social plugin can place a cookie or script on your device, enabling that operator to recognize individuals who have previously visited our Sites or used our Apps. If you are logged into the social media site while browsing our Sites or using our Apps, the social plugins allow that social media site to share data about your activities on our Sites or Apps with other users of their social media site. For example, Facebook Social Plugins allow Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website or Apps. We do not control any of the content from the social media plugins. For more information about plugins from social media sites you should refer to those sites’ privacy and data/information sharing statements/policies.

Safeguarding of Information

We take a number of steps to safeguard the security of Personal Information obtained through our Services. For example, we maintain administrative, technical and physical controls to reasonably safeguard data from unlawful use, unauthorized access or disclosure. Individuals who have access to confidential and otherwise nonpublic data are required to maintain the confidentiality of such information. However, no system for safeguarding personal or other information is 100% secure and even though we have taken steps to protect your Personal Information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with the collection, use, and sharing of Personal Information.

Links to Third Parties’ Sites

We may provide links to websites or resources outside of our Sites or Apps for your informational purposes only. You acknowledge and agree we are not responsible for the availability of such sites or resources, and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through or provided by such sites or resources. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of any Personal Information that you provide or may be collected by such sites. We encourage you to review the privacy policies and terms and conditions on all linked sites before you provide any Personal Information or complete any transactions with such third parties.

Information of Minors

The Services are not directed to children as the products and services we offer through the Sites or the Apps are intended for persons 18 years of age and older. The Company does not knowingly collect, use or disclose any Personal Information from children. If you are under 18, do not use our Services and do not provide your information to us.

Our Commitment to Data Security

We have taken certain physical, administrative, and technical steps to help protect the information we collect from unauthorized access, use or disclosure. While we make every effort to help ensure the integrity and security of our networks and systems, remember that no method of transmission over the Internet or method of electronic storage is 100% secure.

UK Residents.

If you are located in the United Kingdom, the following section applies.

REEF Global, Inc. is the data controller in respect of your Personal Information.

You have various rights in connection with our processing of your Personal Information, each of which is explained below.

1. Access. You have the right to access the Personal Information we hold about you by, as applicable, logging into your account or contacting us by email at [email protected].
2. Rectification and Erasure. You have the right to edit or delete the Personal Information we hold about you by, as applicable, logging into your account or contacting us by email at [email protected]. We are not obliged to delete any Personal Information that must be retained in order to comply with a legal obligation or to establish, exercise or defend legal claims.
3. Restriction. You have the right to restrict our processing of your Personal Information where you believe such information to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it. In such case, we would mark stored Personal Information with the aim of limiting particular processing for particular purposes in accordance with your request, or otherwise restrict its processing.
4. Portability. You have the right to obtain Personal Information we hold about you, in a structured, electronic format, and to transmit such information to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you and (c) the data is processed by automated means. Additionally, you have the right to require us to transmit such Personal Information directly to another controller, where technically feasible. This right is not applicable if it adversely affects the rights and freedoms of others.
5. Objection. Where the legal justification for our processing of your Personal Information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the information for the establishment, exercise or defence of a legal claim.
6. Withdrawing Consent. If you have consented to our processing of your Personal Information, you have the right to withdraw your consent at any time, free of charge. This includes where you wish to opt out from marketing messages (where we have previously requested your consent for these).
   
   

You will not have to pay a fee to exercise any of your rights, except that we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all valid requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Note that the rights outlined above only extend to Personal Information. You can exercise any of your rights above by contacting us at [email protected].

For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information.

Complaints. If you would like to lodge a complaint about how we have processed your Personal Information, you can contact the Information Commissioner’s Office at:

• Telephone: +44 0303 123 1113
• Email: [email protected]
• Website: www.ico.org.uk
• Web-form: www.ico.org.uk/concerns/
• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
  
  

Failure to provide Personal Information. Where we are required by law to collect your Personal Information, or we need to collect your Personal Information under the terms of a contract we have with you, and you fail to provide that Personal Information when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the Personal Information we need in order to provide the product or services you or any of our Service Providers have requested from us. In this case, we may have to cancel the provision of the relevant product or services to you, in which case we will notify you.

Transfers. We only transfer Personal Information in accordance with the requirements of the UK GDPR, including entering into the approved UK International Data Transfer Agreement where required for transfers to third countries not recognised in the UK as providing an adequate level of data protection.

Submission of Requests for Information or Requests to Delete. To submit a request for information or a request to delete, you may:

Fill out the Privacy Webform

To protect your privacy and security, we will also take reasonable steps to verify your identity before providing your Personal Information and before deleting your information. Only you or someone legally authorized to act on your behalf may make a verifiable request related to your Personal Information. If you want to authorize someone else to make a request on your behalf, please contact us at [email protected].

Responses to Requests. We do not charge a fee to respond to your request unless it is manifestly unfounded or excessive. We will respond to your request within one month of its receipt. If we need more time to fulfill your request, we will inform you of the reason in writing or via email and we may take up to an additional two months to complete fulfilling your request.

Retention

We retain your Personal Information only for the period of time needed to fulfill the purposes stated in this Policy or as required by applicable legal, regulatory, or operational needs.

Notice to Site Users Located Outside the United States

When you access our Sites or Apps from outside the United States, we may transfer the Personal Information that we collect from you to a location outside of your jurisdiction, including to the United States. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using our Services, you acknowledge that these laws may provide a different standard of protection and you understand your Personal Information will be transferred to other jurisdictions, including to the United States.

Your Choices Regarding Your Personal Information

You can always limit the information you directly provide to us, but if you choose not to provide certain requested information, you may be unable to access some of our Services, including functionality and content on the Sites and the Apps. You can also limit the communications that we may send you by following a simple opt-out or unsubscribe process. Simply follow the instructions in our email, newsletter or other communications to opt-out of receiving, or unsubscribe from, future communications.

How to Contact Us

If you have any questions regarding this Policy, your privacy, or our policies, you may contact us at: [email protected]