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 consent to the collection, use, and sharing of your information as described in this Policy, please do not use our Services or provide us with such information.

If you are a California resident, you may have additional rights. Please see our California Residents 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 and agree 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.

(a) 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

(b) 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.

(c) 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.

(d) 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:

For purposes of this disclosure, Personal Information does not include: publicly-available information from government records; de-identified or aggregated consumer information.

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. We may use your data:

• To provide you with the products and/or services you have requested.
• 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.
• 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.
• 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, products, and information we provide to you.
• For other everyday business purposes such as refinement and development of services and products, contract management, administration of our information 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).
• 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.
• To facilitate contests, sweepstakes and promotions, and process and deliver entries and rewards.
• 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.
• 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

In general, 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.

• In general, 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.

In the 12 months preceding the Last Updated date of this Policy, we have disclosed the following categories of consumer Personal Information for a business purpose:

• Identifiers.
• Personal information categories listed in the California Customer Records statute (California Civil Code § 1798.80(e)).
• Commercial information.
• Internet or other similar network activity.
• Geolocation data.
• Sensory data
• Inferences drawn from other Personal Information.

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.

California Residents

Some state laws provide consumers who are residents of those states with specific rights regarding their Personal Information. If you are a resident of a state that provides you specific privacy rights, this section generally describes your rights and explains how to exercise those rights.

Right to Information. Subject to certain limits, you may ask us to provide the following information for the 12-month period preceding your request:

(1) The categories of Personal Information we collected about you;

(2) The categories of sources from which the Personal Information was collected;

(3) The business or commercial purpose for collecting Personal Information;

(4)The categories of third parties with whom we shared the Personal Information;

(5) The specific pieces of Personal Information we collected about your (also called a data portability request);

(6) If we disclosed Personal Information for a business purpose, a list of the disclosures and the Personal Information categories that each category of recipient received;

(7) If we sold Personal Information for a business purpose, a list of the sales and the Personal Information categories that each category of recipient purchased.

Right to Delete.

You also have the right to ask us to delete any Personal Information that we have collected about you, subject to certain limitations as set forth under your specific state law. We may deny your deletion request if the information is necessary for us or our service providers to, among other things, provide a good or service you requested, take actions reasonably anticipated in the context of our ongoing business relationship with you, perform a contract we have with you, detect and protect against security incidents or illegal activity, comply with a legal obligation, or exercise a right provided for by law

Right to Nondiscrimination.

We will not discriminate against you if you exercise your privacy rights under California law, including by:

• Denying you goods or services.
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Providing you a different level or quality of goods or services.
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Submission of Requests for Information or Requests to Delete.

To submit a request for information or a request to delete, you may:

Call us at 1.888.801.7333

Submit this form

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 repetitive (more than twice in a 12-month period) or excessive. We will respond to your request within 45 days 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 45 days 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.

Please note that even if you opt-out of certain communications from us, we may still contact you with important information about your use of our Services which are not marketing 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].