Abraxas Technology Website Privacy Statement, effective as of July 2018

Purpose: This Privacy Policy explains how we use any personal information that is collected about you, and your rights in relation to such information. We encourage you to read the following in its entirety prior to browsing our website, using our
Services, or otherwise conducting business with us. Please note that this Privacy Policy is intended to apply to visitors to our website, clients of Abraxas, and individuals that may encounter an Abraxas device in a public space. Depending upon your relationship with Abraxas, some of the information below may not apply to you. We also recognize that it is possible that you may encounter an Abraxas device in a public space prior to reading this notice; in such event, we wish to reassure you that
we respect your privacy and have implemented multiple measures to safeguard any data that could conceivably be used to identify any individual human being.

Policy
Abraxas Technology, Inc. (“Abraxas”, “Abraxas Technology”, “us”, “our”, or “we”) is committed to protecting the privacy of individuals who visit the abraxastechnology.com Site (“Visitors”), individuals and companies associated with organizations who register to use the Services as defined below (“Customers”), and members of the general public that may encounter Abraxas services used to assist out-of-home (“OOH”) advertisers obtain metrics regarding OOH advertising locations and / or campaigns (“Individuals”). Visitors, Customers, and Individuals are collectively referred to in this Statement as “you” and “your” or as “User(s)”. This Privacy Policy (“Statement” or “Privacy Policy”) describes Abraxas’ privacy practices in relation to the use of Abraxas’ public Website at www.abraxastechnology.com and the software, data, and / or portals made available to Users in connection with the business services offered by Abraxas; this Privacy Policy also covers our collection and use of MAC addresses as a means of generating OOH advertising information (collectively, the “Services”).
We adhere to the principles of the EU-U.S. Privacy Shield, and please read below for further information.

Scope
This Statement covers only data collected through our website or Services.        For questions regarding this policy or to submit a privacy-related request: CLICK HERE [emailto:privacy@abraxastechnology.com]                                                    You acknowledge notice of this Statement and agree with and acknowledge the terms, conditions and responsibilities as set out below.
We may make access available to third party sites through our Site. When accessing these third party sites, the privacy policy of the third-party applies, and this Statement does not apply.

What Information do we collect about you?                                                            Our Site does not use cookies. The only information we collect is: (1) the information you actively submit to us through the Site, such as your email address with a request to contact you; (2) information you actively submit to us in the course of being a customer, such as contact or billing information; or (3) data from a mobile device that transmits cellular communication signals. With respect to #3, we only collect mobile device identifiers that are NOT readily associated with the device’s owner. In addition to the foregoing, we may collect general information via Google Analytics about Site visits and activity on our Site.

How will we use the information about you?
We collect information about you to contact you, professionally maintain and manage our Site, process your order, manage your account, provide data to OOH signage owners regarding sign visibility (e.g. number of views per day), and to email you about other products and services we think may be of interest to you. (Please note that if you begin receiving emails from us and no longer wish to receive them, click UNSUBSCRIBE in any email we send to you, and you will be unsubscribed from our list immediately.) In processing your order or managing your account, we may send your details to, and also use information from, credit reference agencies, payment processing firms, banking service providers, fraud prevention agencies, and other third parties that are related to our business. With respect to OOH advertising installations that use Abraxas technology, we only collect information from mobile devices for the purpose of furnishing OOH advertisers with accurate information regarding advertising views and customer conversion metrics. We do not seek to personally identify you, or collect information that can be used to identify you without substantial secondary processes.
When you submit information to us, it will only be used for the purposes of contacting you, engaging in business with you as a client of our OOH technology, or using that information to provide OOH advertisers (our clients) with data regarding views, impressions, and the overall effectiveness / reach of OOH signage.

Marketing
We would like to send you information about products and services which may be of interest to you. If you have consented to receive marketing information, you may opt out at a later date. You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of our network. If you no longer wish to be contacted for marketing purposes, please contact us or click UNSUBSCRIBE the next time you receive an email from us.

Types of Data and Collection Methods                                                                  We receive data that you actively submit through the Site or Services (“Data”) as described below, or in the case of data from OOH advertising installations equipped with Abraxas technology, data that is passively collected from a person’s device.

When you request information or otherwise actively send us Data through the Abraxas public Web site or through a third party host such as AWS (“actively submitted data”), we may collect Data such as, but not limited to, name, e-mail address(es), telephone number(s), or user profile information. You can opt-out of providing information by not entering it when asked, and, if such information is required in order to allow us to respond to your inquiry, you may not receive any response from us at all if we have no viable way to contact you, or you will receive a notice advising you of this situation and the nature our request for additional information. When you submit Data via the Services, you will know what Data we collect through the Services, because you actively submit it. With respect to Data collected from Individuals, we only collect Data from electronic devices that provides OOH advertisers with data that can not readily be used to identify you. You may contact us at privacy@abraxastechnology.com with further questions.                                                                                                        Additionally, when you visit the Abraxas public Web site(s), Google Analytics may passively track information on your computer and Internet connection, such as the IP address of your computer and/or Internet service provider, the date and time you access the Web site(s), the Internet address of Web sites from which you link to our Services, the computer technology you are using and your movements and preferences on our Web site(s).                                                                     Unless you also actively submit personal information such as your name or address, passively tracked Data from Individuals does not typically allow us to identify you personally (even though it can theoretically be done, we do not have the means or an interest to find out who you are, unless you identify yourself voluntarily through an active submission of data). To the extent permitted by applicable law, we reserve the right to combine passively tracked Datawith personal Data that you actively submit.

Collection Purposes and Use of Data
We collect Data via our Services primarily for purposes of administering, providing, protecting, and improving our Services, to better understand the preferences of our Users, to identify server problems, to compile aggregated statistics about site usage, to compile aggregated statistics about OOH advertising, and to help personalize your experience with our Services. We do not deliver third party online advertisements on our sites but we may advertise our products and services on others’ Web site. Nevertheless, we may promote our Customers or the existence of a business relationship between Abraxas and any other organization or individual on our Site or within our Services.              Abraxas may also use Data you voluntarily provide to perform the services you request. For example, if you fill out a “Contact Me” form, we will use the information provided to contact you about your interest in the Services.

Web Site Navigational Information: Cookies, Web Beacons, and Analytics   Abraxas does not use commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Site (“Web Site Navigational Information”). Abraxas does use Google Analytics to understand basic information regarding visitors to our site. Please visit https://support.google.com/analytics/#topic=3544906 for more information on Google Analytics.

Links to Other Web Sites
Abraxas occasionally provides links to other entities related to the Services for your convenience in locating certain information, Services, and / or products. Please be advised that when you access these other sites, you are leaving the Abraxas Site and / or Service(s) and that these third party sites are maintained by organizations over which Abraxas has no control.
Accordingly, a link provided by Abraxas does not constitute endorsement of the content, viewpoint, policies, legality, products, or services provided or advertised on the third party site. Once you link to a site not maintained by Abraxas, you are subject to the terms and conditions of that site and all inquiries regarding such third party sites or services should be directed to the owner of such site or services, not Abraxas.

Social Media                                                                                                                    If you post material to a blog or other social media feed located on or accessed through the Services, you should be aware that any personally identifiable information you submit can be read, collected, or used by other users of this Site or our Services, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit via social media or any other publicly-available forum, online or not.

Opt-Out
Abraxas does not seek to conduct business or communicate with folks that are not interested in working with Abraxas or hearing from Abraxas. You always have the right to opt-out. To submit a request contact privacy@abraxastechnology.com.                                                                                In connection with promotions or other projects, we may ask you specifically whether you have objections against a certain kind of Data use or sharing. If you opt-out under such circumstances, we will respect your decision. To opt-out of receiving marketing communications from Abraxas via email please click on the “opt-out” link in the email communication or submit a request to the email address you see throughout this notice. Please be advised that communications sent by Abraxas via other means such as USPS mail are initiated via lists maintained by Abraxas from explicit opt-in scenarios such as website downloads or tradeshows. These lists provide for an opt-out option at the time you submit your information. Please note that our affiliates and other data recipients have their own data privacy policies, which may differ from ours and you would have to contact them separately with respect to opt-out requests. If you are having difficulty opting out of any lists, communications, promotions, or from any Services, please contact us at [mailto:privacy@abraxastechnology.com] for further assistance.
Please note that it is not possible to opt out of any services that do not personally identify you.

Correcting and Updating Your Information
Customer Data                                                                                                      Abraxas’ Customers may electronically submit Data or information, including payment information, for hosting and processing purposes (“Customer Data”). Abraxas is not responsible for Customer Data data submitted to and / or maintained by third party sites such as, but not limited to, AWS. Abraxas will not host or retain payment information or any personal data collected by a third party seller for the purpose of accessing, purchasing, using, or maintaining the Services, except to the extent that information such as, but not limited to, payment information, may need to be retained for some limited time per legal requirements. Customer Data may include Customer contact information (such as email address, name, phone number), financial information (such as credit card information), or other requested information. Abraxas will not review, share, distribute, or reference any such Customer Data except as provided in this policy, through another agreement, or as may be required by law. In accordance with the Terms of Service and this Privacy Policy, Abraxas may access Customer
Data only for the purpose of providing the Services, or preventing or addressing service or technical problems, or as may be required by law. If you wish to correct or update your Data, please contact us at privacy@abraxastechnology.com.

Your California Privacy Rights                                                                            California law provides that California residents have a right to request businesses to tell them how their personal information has been shared, if at all, with third parties for the third parties’ direct marketing purposes. While Abraxas does not collect or share or personal information, you are still welcome to contact us at privacy@abraxastechnology.com to submit a formal request and receive a formal response.

Your Texas Privacy Rights
The Texas Identity Theft Enforcement and Protection Act does not technically apply to Abraxas because we do not collect - unless you actively submit it to us - your name, address, social security number, credit card number, or other similar information. Nonetheless, we believe in following the spirit of this law, protecting the identity of people, and notifying people impacted by any type of data breach. For more information and your rights in Texas, you may visit: https://www.texasattorneygeneral.gov/cpd/protecting-consumers-personaldata

Privacy Rights in other States & Countries                                                                    If you live in one of the 48 States that isn’t Texas or California, or a foreign country, you may also have unique privacy or data rights. If you wish to contact us pursuant to another state or foreign law, please contact us at privacy@abraxastechnology.com and be sure to provide a citation or link to any law you reference so we can do our best to help you.

EU – U.S. Privacy Shield
Abraxas has subscribed to the EU-U.S. Privacy Shield Framework. Abraxas adheres to the Privacy Shield Principles including the Supplemental Principles, (collectively, the “Privacy Shield Principles”) for Personal Data received from entities in the European Economic Area (the “EEA”).
This Abraxas Privacy Shield Policy (“Privacy Shield Policy”), along with the entirety of this Privacy Policy, describe the privacy practices that we implement for Personal Data received from the EEA in reliance on the Privacy Shield and other relevant laws. This Privacy Shield Policy uses terms which are defined in the Privacy Policy. If there is any conflict between the terms in this Privacy Shield Policy and the Privacy Shield Principles as concerns the Data received under the Privacy Shield, the Privacy Shield Principles shall govern to the extent of the conflict. To learn more about the Privacy Shield program visit www.privacyshield.gov, and to view our certification, please visit https://www.privacyshield.gov/list. (Please note that as of May 2018, we are in the midst of completing this process, so if you do not see Abraxas listed at this site, please contact us for an update.)

Privacy Shield Principles:

1. and 2. Notice and Choice
Our Privacy Policy describes how we use personal data we receive from different sources, including, possibly from EU locations and / or from EU citizens. This Privacy Shield Policy describes how we process personal data covered by the Privacy Shield. Abraxas as a technology service provider usually will not have a direct relationship with Individuals generally or your Customers. In the event that any third party is ultimately responsible for providing anyone with a privacy notice like this, that third party is responsible for ensuring that you are provided with appropriate notice and choice with respect to your personal data.
3. Data Integrity and Purpose Limitation
We only collect data that is relevant to providing our Services. In addition to making every possible effort to minimize any personal data collected or otherwise collect data that could be used to identify you, we only process data concurrently with our provision of the Services. We take reasonable steps to ensure that the data received under the Privacy Shield is needed
for Abraxas’ Services, and we will utilize commercially reasonable efforts to ensure that such data is accurate, complete, and current.
4. Accountability for Onward Transfers                                                              Abraxas may disclose data to trusted third parties, such as a payment processing company. Abraxas requires that its agents and service providers that have access to our data provide the same level of protection as required by the Privacy Shield Principles. We require our partners to process Personal Data received under the Privacy Shield in a manner consistent with our obligations under the Privacy Shield Principles. We may need to disclose data in response to lawful requests by public authorities, for law enforcement, or national security reasons, or when such action is necessary to comply with a judicial proceeding or court order,
or when otherwise required by law. Furthermore, in the context of an onward transfer, Abraxas has responsibility for the processing of personal information it receives under the Privacy Shield and subsequent transfers to a third party acting as an agent on our behalf. And please note that Abraxas shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
5. Data Security
We use reasonable and appropriate physical, electronic, and administrative safeguards to protect data from loss, misuse, and unauthorized access, disclosure, alteration or destruction, taking into account the nature of the data and the risks involved in processing that information.
6. Access to Personal Data
Our Privacy Policy explains how you may access and/or submit requests to review, correct, update, suppress, or delete Personal Data. You can ask to review and correct data that we maintain about you by sending a written request to privacy@abraxastechnology.com. We may limit or deny access to data where providing such access is unreasonably burdensome, expensive under the circumstances, or as otherwise permitted by the Privacy Shield Principles, relevant State law, Federal law, or International law. Further information regarding how to access, control, or otherwise tell us what to do with your data, see the Section regarding GDPR.
7. Recourse, Enforcement and Dispute Resolution
If you have any questions or concerns, please write to us at the address listed below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of data in accordance with the Privacy Shield Principles. In the event we are unable to resolve your concern, you may contact BBB, which provides an independent third-party dispute resolution body based in the United States, and they will investigate and assist you free of charge. The Better Business Bureau may be contacted here:
https://www.bbb.org/EU-privacy-shield/file-a-complaint/. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means. Abraxas is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).

Contact Information
If you have any questions regarding this Privacy Shield Policy, please contact us by email at privacy@abraxastechnology.com or please write to the following address:
Abraxas Technology, Inc.
4009 Banister Lane, #430
Austin, Texas 78704 USA
Attention: Legal Department
Changes to this Privacy Shield Policy
This Privacy Shield Policy may be changed from time to time, consistent with the equirements of the Privacy Shield and in accordance with the process described in the Privacy Policy. You can determine when this Privacy Shield Policy was last revised by referring to the date at the top of this page.

General Data Protection Regulation (GDPR)                                                              Abraxas has a legitimate commercial interest in processing data for the purpose of providing valuable professional services to our clients, namely data regarding views and impressions of OOH advertising. To achieve this Service for our clients, we collect and process minimal data from mobile devices (MAC addresses only), and we utilize measures to ensure that the data we do collect, cannot be associated with any particular human being. We recognize that your privacy is important, and to help protect your interests, Abraxas is guided by incorporating privacy protections wherever possible into our data collection and data processing practices.                                                                                                       If you are a European citizen or otherwise entitled to the protection of European laws, you may have additional rights under the GDPR. In honor of those rights, Abraxas furnishes the following information:
You have the right to be informed of what data we may have, how we process it for business purposes, and how we store it. Reading this Privacy Policy carefully will provide all such information, but if you are having trouble finding it yourself within this document, you may contact us here: privacy@abraxastechnology.com You also have the right to contact us and inquire if we have any data about you, and how any such data is used. We will do our best to respond to any such inquiries in a timely manner. If you make an inquiry, please understand that it is very well possible that we will have no data associated with you because our data collection and processing methods seek to minimize the data we collect, and much of the data we collect can not readily be associated with a
particular human being.                                                                                              You have the right to correct any data we do possess about you. Who wants incorrect data?? Not us, and not you either! Please email us with any rectification requests: privacy@abraxastechnology.com In the event that any of your information is incorrect, you may also request that we discontinue processing of your data.                                                                                                                       You also have the right to contact us and request that we simply erase any data associated with you. (Please note that if you are a paying client of Abraxas, such a request will require conversation, as certain information such as how we can contact you can not practicably be deleted while we are doing business together.)
You also have the right to object to our use of your data. If you wish to submit an objection, you must provide an explanation for your objection so we can determine how to best service your request. Please send objections and explanations to privacy@abraxastechnology.com
*Abraxas does not intend for its software or services to be used for any automated decisionmaking purposes.

Do Not Track
Certain web browsers and other devices you may use to access the Services may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, the Services do not respond to “Do Not Track” signals.

Security & Transfers
Transmissions over the Internet are never 100% secure or error-free. However, we take reasonable steps to protect your Data and our Services from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Children Under 13
Abraxas is committed to protecting the privacy needs of children, and we encourage parents and guardians to take an active role in their children’s online activities and interests. Neither the Abraxas public website nor are our Services directed to children under 13 years old, and we do not market to or knowingly collect any personally identifiable information from a child under the age of 13 without the consent of the child’s parent or legal guardian. If a parent or guardian becomes aware that his or her child has provided us with personal or contact information without their consent, the parent or guardian should contact us immediately at privacy@Abraxastechnology.com. If we become aware that we have inadvertently collected personally identifiable information from a child under the age of 13, we will immediately take reasonable steps to delete such information from our Site and / or Services.

Amendments
We reserve the right to change, modify, add or remove portions of this Statement from time to time and in our sole discretion, but will alert you that changes have been made by indicating on the Statement the date it was last updated. When you visit the Services, you are accepting the current version of this Statement as posted on the Service at that time. Especially due to the fluid nature of data security compliance, we recommend that users
revisit this Statement on occasion to learn of any changes.

Contact Us                                                                                                                         If you have any questions about t his Statement, please email us at
privacy@abraxastechnology.com, or you may contact us at the following address:
Abraxas Technology
4009 Banister Lane, #430
Austin, TX 78704 USA
ATTN: Privacy