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CCPA PRIVACY POLICY

Last Updated May, 2024

We Take Your Privacy Seriously

This California Privacy Notice (the “Notice”) sets forth the disclosure obligations of Locus Robotics, [Inc.], and its subsidiaries and affiliates (collectively, “Locus,” “we”, “us,” and “our”) under California law, including the California Consumer Privacy Act of 2018, [as amended by the California Privacy Rights Act of 2020 (“CPRA”)] (collectively, “CCPA”) and the California Civil Code section 1798.83, as amended.

This Notice provides the additional details regarding the information defined as ‘Personal Information’ under applicable California law and related to a California resident or household (“Consumers,” “User,” or “you”) referred to as “Personal Information.” This Notice describes the categories of Personal Information Locus has collected, the categories of Personal Information Locus has disclosed, the categories of Personal Information Locus has sold (if any), and a description of the Consumer’s rights. This Notice supplements the information contained in the Locus Robotics Privacy Policy.

Categories of Personal Information Locus Collects 

We collect Personal Information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a Consumer or device.  In addition to the Personal Information set forth below, please also consult our Locus Robotics Privacy Policy for a further description of the types and categories of information we collect. 

Personal Information does not include (i) publicly available information that is lawfully made available to the general public by way of federal, state, or local government records; (ii) de-identified or aggregated consumer information; and (iii) information excluded from the CCPA’s scope, like: (a) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, and (b) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. 

Below is a summary of categories of Personal Information and whether we have collected such information from Consumers within the last twelve (12) months: 

CategoryPersonal Information (corresponds to categories listed in CCPA §1798.140(o)(1)) 

CCPA Example 

Collected 

A. Identifiers 

 

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. 

Y 

B. Personal Information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 

Name, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, medical information, or health insurance information. 

Y 

C. Protected classification characteristics under California or federal law 

Age (40 years or older), ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information). 

Y 

D. Commercial information 

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

N 

E. Biometric information 

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. 

N 

F. Internet or network activity 

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

Y 

H. Sensory data 

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

N 

I. Professional or employment-related information 

Current or past job history or performance evaluations. 

Y 

J. Non-public education information 

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. 

N 

K. Inferences drawn from other Personal Information 

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

N 

 

Sensitive Personal Information 

We may also collect and process the following categories of Sensitive Personal Information and have done so within the last twelve (12) months: 

  • Geolocation data; 
  • Racial or ethnic origin information; 
  • Sexual orientation information; 
  • Financial account log-in information; 
  • Social Security number; 
  • Driver’s license number; 
  • State identification card number; and/or 
  • Passport number. 

Sources of Personal Information 

Locus obtains the categories of Personal Information listed in the Table above from the following categories of sources: 

  • Directly from you.  For example, (i) if you visit our Websites, respond to a survey, participate in a telephone interaction, fill out a registration form; (ii) if you fill out a form or communicate with us through one of our Websites to receive information about our business to business services or to schedule a demonstration of our services, products or programs; and (iii) if you expressed interest in being contacted by us at a trade show in which we participated or hosted. 
  • Indirectly from you.  For example, from your activity on our Websites. 
  • Directly and indirectly from activity on our Websites.  For example, from observing your actions on our Websites or through your submission of an online form requesting a demonstration of one (1) of our products or services. 
  • From third parties that contract with us or interact with us in connection with the services we perform.  For example, from (i) vendors and partners that help us to build contact lists, supplement or update your information in our database, or confirm/verify our records and information are accurate and up to date; (ii) third parties that may contact you, on our behalf, to provide you relevant content; or (iii) third parties that integrate their services or products with ours or provide us access to their services. 

Use of Personal Information 

We may use or disclose the Personal Information we collect for one (1) or more of the following business purposes: 

Locus will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice. 

Sharing of Personal Information 

Locus may disclose your Personal Information to a third party for a business purpose as described in the Locus Robotics Privacy Policy.  In the preceding twelve (12) months, Locus has disclosed the following categories of consumer information for a business purpose: 

  • Identifiers 
  • California Customer Records Personal Information categories 
  • Protected classification characteristics under California or federal law 
  • Internet or network activity 
  • Geolocation data 
  • Professional or employment-related information 

Your Rights and Options 

The CCPA provides California residents with specific rights regarding their Personal Information.  This section describes your CCPA rights and explains how to exercise those rights.  Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the CCPA or other laws. 

Access to Information and Data Portability Rights 

You have the right to request that Locus disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months.  Once we receive and confirm your verifiable Consumer request (see Exercising Your Rights), we will disclose to you: 

  • The categories of Personal Information we collected about you. 
  • The categories of sources for the Personal Information we collected about you. 
  • Our business or commercial purpose for collecting or selling that Personal Information. 
  • The categories of third parties with whom we share that Personal Information. 
  • The specific pieces of Personal Information we collected about you (also called a data portability request). 
  • If we disclosed your Personal Information for a business purpose, two (2)separate lists disclosing: 
  • sales, identifying the Personal Information categories that each category of recipient purchased; and 
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. 

You have the right to request that the information described above be provided to you in a portable and readily useable format, to the extent technically feasible (“data portability”).  

Deletion Request Rights 

You have the right to request that Locus delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request (see Exercising Your Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
  • Debug products to identify and repair errors that impair existing intended functionality. 
  • Exercise free speech, ensure the right of another Consumer to exercise their free speech rights, or exercise another right provided for by law. 
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. 
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 
  • Comply with a legal obligation. 
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

Right to Correct Inaccurate Information   

To the extent that we may maintain inaccurate Personal Information, you have the right to request that we correct such inaccurate Personal Information taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.  Once we receive and verify your verifiable consumer request, we will use commercially reasonable efforts to correct your Personal Information.  

Sale and Sharing of Personal Information and the Right to Opt Out  

You have the right to opt out of the processing of your Personal Information for the following purposes: 

  • Sale of your Personal Information. 
  • Sharing of your Personal Information for cross-context behavioral advertising. 

The use of online tracking technologies may be considered a “sale” or “sharing” under California law.  To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under California law, you may opt out of these online tracking technologies by submitting a request or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC). 

Right to Limit Use and Disclosure of Sensitive Personal Information   

You have the right to request that we limit the ways we use and disclose your Sensitive Personal Information (as defined by CCPA) to uses which are necessary for us to provide services, or deliver the goods reasonably expected by you, or and as authorized by law.   

Right to Disclosure of Direct Marketers   

You have a right to the categories and names/addresses of third parties that have received Personal Information for their direct marketing purposes upon simple request, and free of charge.  

Exercising Your Rights 

To exercise your rights described above, please submit a verifiable consumer request to us by either: 

  • Calling us at (888) 724-7551 

  • Writing us at  

Locus Robotics Corporation 
301 Ballardvale St. 
Wilmington, MA 01887 
Attn: Data Privacy 

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.  You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Depending on the request(s) submitted, you may need to: 

  • Provide sufficient information that allows us to reasonably verify whether you are the person about whom we collected Personal Information or an authorized representative. 

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

We may not be able to respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. 

Making a verifiable consumer request does not require you to create an account with us. 

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

Authorized Agent 

You may use an authorized agent to submit verifiable consumer requests on your behalf provided that the authorized agent is a natural person or a business entity that you have authorized to act on your behalf.  If you use an authorized agent, we will require: (i) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (ii) proof of power of attorney pursuant to California Probate Code sections 4000 to 4665.  We may deny a request from an authorized agent that does not submit proper verification proof. 

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: 

  • Deny you goods or services. 
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. 
  • Provide you a different level or quality of goods or services. 
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.  Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects.  Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time by submitting a request to privacy@locusrobotics.com.  Additionally, to the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.   

Other California Privacy Rights 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits Users of our Websites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.  To make such a request, please send an email to privacy@locusrobotics.com,or write us at: Locus Robotics Corporation, 301 Ballardvale St. Wilmington, MA 01887. 

Changes to Our Privacy Notice 

Locus reserves the right to amend this Notice at our discretion and at any time.  When we make changes to this Notice, we will post the updated notice on the Websites and update the Notice’s effective date.  Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes. 

Contact Information 

If you have any questions about this Notice or our privacy practices, contact us at: 

Phone:            (888) 724-7551 
Website:         https://locusrobotics.com/company/legal/privacy  
Email:            privacy@locusrobotics.com 

Mail: Locus Robotics Corporation 
301 Ballardvale St. 
Wilmington, MA 01887 
Attn: Data Privacy