R-Zero Privacy Policy

Last updated: September 17, 2024

At R-Zero Systems, (“R-Zero”, “we”, “our”, or “us”), the privacy of our Customers is of the utmost importance. Thank you for taking the time to read our privacy policy (the “Privacy Policy”). R-Zero is a healthy building technologies company that provides products and services to enterprises developing or managing real estate properties. (collectively, the “Services”). This Privacy Policy sets out how we collect, use, process, store, and disclose your personal information on https://www.rzero.com (the “Website”) and the Services.

By accessing and using our Services you freely and expressly consent to the collection, use, processing, storage, and disclosure of your personal information as set out in this Privacy Policy and our Terms of Service.

1. When We Collect Your Personal Information
2. Personal Information We Collect
3. How We Use Your Information
4. How We Disclose Your Personal Information
5. Your Privacy Choices
6. Use of Cookies and Tracking Technologies
7. U.S. State-Specific Disclosure
8. UK/EEA Residents" Notice
9. Security
10. Retention
11. Third-Party Links On Our Website
12. Changes To This Privacy Policy
13. Contact Information

1. When We Collect Your Personal Information

We may collect personal information that you provide when you:

• Register for our Services
• Visit our Website
• Use our Services
• Sign up for our email newsletter
• Contact or otherwise correspond with us

2. Personal Information We Collect

Information you provide:

• Account Creation. When you register to our Services (“Customer(s)”), we collect contact details such as your name, email address, phone number, and professional information such as company and title.
• We may collect information from your inquiries into our services, or how you otherwise indicate you may be interested in our services, which may include signing up for email communications or providing us with your name, work email, phone number, company name, position title, website, social media links, and time zone.
• Payment Information. We may collect data necessary to process your product or service purchases, such as your credit card number, or other financial instrument used to make a payment.

Information we automatically collect through our website:

• Metadata and Analytics. We may collect Metadata and analytics of your use of our Services, including IP address, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, what you do on those pages.

Information from third parties:

• Demographic or Other Third Party information. We may collect information from third party data brokers, including firmographic and demographic information about our current or prospective customers. This may include attempts to identify business visitors to our websites. See below for more information about "Cookies and Tracking Technologies."
• Social Media Activity. When you interact with our accounts on a social media platform such as LinkedIn, we may collect certain information that you or the platform makes available to us such as your social media account profile, social media "likes", click-throughs to our Website, or custom interactions.

Information from our smart building products and services:

• Camera information. Our sensors include cameras to assist with operational usage, such as whether there are people or items located in a particular section of a building floor, and how many people or items are present. Our sensor cameras do not capture identifiable photographic images of individuals, the images captured are not for the purpose of identifying any individuals, nor do they provide any capabilities for our Customers to use the cameras for video monitoring purposes. The images collected by our cameras are automatically obfuscated to avoid processing unique individual characteristics, and are exclusively stored in temporary memory on the camera itself and automatically rewritten with subsequent information.
• Proximity and other sensors. Our sensors may categorize whether a person or item is in a particular workspace, and enable our Customers to use this categorical information to determine whether and how the workspace is occupied. As this information could be used by our Customers for employee monitoring purposes, even without using our cameras that will identify the presence of people/a person generally, it may still be considered "personal information" under various privacy laws if the employer has express knowledge that an employee should be present in a specific workspace.

Our Website and Services are designed for business professionals. We do not intentionally collect any personal information from minors under the age of 16. If you believe we have obtained personal information associated with children, please contact us at privacy@rzero.com and we will delete it.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To process your product payments securely and efficiently
• To provide and operate our Services, including facilitating account creation and managing user accounts as well as providing our software or services
• To improve our Services, for example, we use your information to better our Services
• To identify usage trends and otherwise measure all activities on the Services
• For customer support, including via email
• To communicate with you, including via our newsletter or to request feedback
• To protect our Services and keep our Services safe and securing, including fraud monitoring and prevention
• For other business and legal purposes, such as to collect amounts owing to us, and to maintain business records
• With your consent

4. How We Disclose Your Personal Information

We may disclose your information with your consent. We may also disclose your information with our corporate affiliates, as well as vendors or service providers who:

• Help us communicate with you
• Manage and optimize our Website and Services (see "Cookies and other Tracking Technologies" below)
• Provide cloud hosting
• Help us provide customer support

In addition to the above, we may disclose your information for the following purposes:

• Our Other Group Entities (g., by and among R-Zero and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership). We may disclose your Personal Information to our other R-Zero group companies, including third-party employers-of-record (EOR), to provide you with tailored services and communications, or in accordance with our business administrative practices. Some of these may be abroad outside the USA; we may share your provided log files with the and other service providers or contractors located in other countries or jurisdictions for select technical issues.
• Legal and Compliance Purposes. We may share information with external parties when complying with legal process (eg; subpoena), to protect our intellectual property and other legal rights, to prevent fraud or imminent harm, and secure the use of our Services. We reserve the right to disclose information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a law enforcement order, such as a search warrant, judicial proceeding, or court order. We may also retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms of Service.
• Business Transactions. In the event that R-Zero goes through a business transaction, such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change, including, without limitation, during the course of any due diligence process, Customer information, including Personal Information, will likely be among the assets shared and transferred. We will endeavor to notify any Customers via email and/or a prominent notice on the Services of any completed change in ownership or materially different uses of personal information. This Privacy Policy will become binding upon the new owner of the information until amended.
• Anonymous Data. We may use and disclose anonymous or aggregated information about our Customers to any external parties, including current and potential business partners/affiliates, investors, or the public, or use it for research or analytics purposes.

5. Your Privacy Choices

R-Zero provides you with the ability to exercise the following choices with our use of your personal information:

• Access the personal information we maintain about you.
• Delete the personal information we maintain about you.
• Correct inaccurate personal information we maintain about you
• Opt out of certain uses of your personal information, notably, you can unsubscribe to our email list by clicking the unsubscribe link at the bottom of marketing emails.

You can exercise these rights by contacting us at privacy@rzero.com.

In addition, if you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you are a current or former employee of one of our Customers, and you would like to fulfill your rights to the personal information we maintain about you on behalf of our Customer, including any information collected through our sensors or other technologies, please contact a representative of that Customer rather than email us with your request. We cannot provide personal information about a specific individual on behalf of a Customer without their express written instructions.

6. Use of Cookies and Tracking Technologies

We may use cookies and similar tracking technologies like web beacons and pixels (“cookies”) to access or store information for functional and analytics purposes.

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that because this opt-out is specific to the device or browser on which it is exercised, you will need to opt out on every browser and device that you use. To control the cookies R-Zero sets on your browser, utilize the following choices;

• Cookie Preferences.
• Advertising Industry Opt-Out Tools. You can also use these opt-out options to limit use of your information for interest-based advertising online or in apps by visiting http://optout.aboutads.info
• With Each of Our Vendors Individually. The following advertising or marketing services partners offer opt-out features that let you opt-out of use of your information for interest-based advertising or profiling:

Third Party Advertising Services
Google	Google Advertising Opt Out
Meta (Facebook)	Facebook Advertising Preferences
Zoominfo	Zoominfo Privacy Choices
Adobe Marketo	Adobe Privacy
LinkedIn	LinkedIn Privacy

7. U.S. State-Specific Disclosure

Some U.S. states have enacted comprehensive privacy laws related to the "sale" or "sharing" of personal information for cross-contextual behavioral or targeted advertising purposes. R-Zero discloses these third party advertising services above which may be deemed a "sale" or "sharing" of personal information with privacy choices enabled for you to opt-out.

R-Zero does not process personal information that may be deemed "sensitive" under state privacy laws. The information collected through R-Zero cameras and sensors are not considered to be "biometric data" as defined by any U.S. law due to the privacy controls used by R-Zero to obfuscate any imagery or unique characteristics associated with individuals.

8. UK/EEA Residents Notice

Residents of the United Kingdom (“UK”) and European Economic Area (“EEA”) are provided certain privacy rights under the UK and EU General Data Protection Regulations (“GDPR”).

Legal Basis:

Under the GDPR, we process "Personal Data" (as defined in the GDPR) under the following legal basis.

Processing Activity	Legal Basis under GDPR
Providing our Services	Contract Fulfillment
Improving our Website and Services	Legitimate Interest
Product, Marketing or Service-Related Communications	Legitimate Interest
Customer support	Contract fulfillment
Cookies and Other Tracking Technologies

Controller Designation:

Under the GDPR, we are designated as a "Controller" for all information collected through this website.

As related to information provided to our Customers through our Services, we may be deemed a "processor" and not the "controllerc for any such designations of potentially associated personal information.

Cross-Border Data Transfers:

All data is stored in the United States. As such, if you are a resident of the EEA, UK, or Switzerland, we may transfer to, and store the data we collect about you, to countries other than the country in which the data was originally collected, including the United States. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA, UK, and Switzerland. We rely on Standard Contractual Clauses (“SCCs”) for the transfer of personal data to countries that have not received an applicable adequacy decision, as well as the UK"s "International Data Transfer Addendum" to the SCCs.

For more information on cross-border transfers of your Personal Data or the appropriate safeguards in place, please contact us at privacy@rzero.com.

Additional Rights for UK or European Economic Area Residents:

In addition to the rights granted above, if you are a UK or EEA resident, the GDPR grants you the right to lodge a complaint against us with your local data protection authority. You can find your data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

9. Security

We protect information we collect about you by maintaining physical, electronic and procedural safeguards designed to prevent unauthorized access to user data retained in our servers, however, due to the inherent open nature of the internet, we cannot ensure or warrant the security of any information provided online. We take reasonable precautions to protect your information both online and offline. The servers on which we store data are kept in a secure environment.

10. Retention

We will retain your Customer information for as long as your account or inquiry is active or as needed to provide you with the website or any requested services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your personal information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your Personal Information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

11. Third-Party Links

Our Services may contain links to other websites or services. We do not exercise control over the information you provide, or is collected by these third party websites. We encourage you to read the privacy policies or statements of the other websites you visit.

12. Changes To This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will communicate directly with you via email and/or post the updated Privacy Policy on this page with a “Last Updated” effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Services.

13. Contact Information

If you have any privacy-related questions, you can contact us at privacy@rzero.com or

R-Zero Systems, Inc.
595 Pacific Ave. Floor 4
San Francisco, CA 94133
+1 (801) 823-0314 (United States)