Legal

EU/UK PRIVACY POLICY

Last Updated May, 2024

We take your privacy seriously

The following EU/UK Privacy Notice (“Notice”) applies to residents of the European Union, the European Economic Area, United Kingdom, and Switzerland.

This Notice supplements the information contained in the Locus Robotics Privacy Policy.

Personal Data and Processing. 

For the purposes of this Notice: 

“Personal Data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person; and 

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether by automated means such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. 

Purposes and Legal Bases for Processing Personal Data.  Locus is accountable for Personal Data that it receives and subsequently transfers to third parties.  The types of third parties with which we may share your Personal Data are set out in the sections of this Notice entitled “HOW DO WE SHARE THE PERSONAL DATA.”  The categories of Personal Data Locus may receive, as well as the purposes for which Locus collects and uses the Personal Data, are set out in other relevant sections of this Notice, including in those entitled “WHAT PERSONAL DATA DO WE COLLECT” and “HOW DO WE USE THE PERSONAL DATA COLLECTED.” 

The lawful basis for our Processing of your Personal Data will depend on the purposes of the Processing.  For most Personal Data Processing activities covered by this Notice, the lawful basis is that the Processing is necessary for our legitimate business interests.  Where we Process Personal Data in relation to a contract, or a potential contract, with you, the lawful basis is that the Processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract.  If we are required to share Personal Data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so.  We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your mobile device. 

Depending on what Personal Data we collect from you and how we collect it, we may also rely on various grounds for Processing your Personal Data, including the following reasons: 

• Processing on the basis of legitimate business interests.  When we Process Personal Data on the basis that the Processing is necessary for our legitimate business interests, such interests include: (i)  providing, improving, and promoting our services; (ii) communicating with current and potential customers, other business partners, and their individual points of contact; (iii) managing our relationships with our customers and other business partners, and their individual points of contact; (iv) other business development purposes; (v) sharing information within the company, as well as with service providers and other third parties; and (vi) maintaining the safety and security of our products, services, and employees, including fraud protection. 

• Processing on the basis of performance of a contract.  Examples of situations in which we Process Personal Data as necessary for performance of a contract include e-commerce transactions in which you purchase a service from us. 

• Processing on the basis of consent.  Examples of Processing activities for which we may use consent as its legal basis include: (i) collecting and Processing precise location information from your mobile device; (ii) sending promotional emails when consent is required under applicable law; and (iii) Processing Personal Data on company services through cookies and similar technologies when consent is required by applicable law. 

• Processing because we are under a legal obligation to do so.  Examples of situations in which we must Process Personal Data to comply with our legal obligations include: (i) providing your Personal Data to law enforcement agencies and other governmental bodies when required by applicable laws; (ii) retaining business records required to be retained by applicable laws; and (iii) complying with court orders or other legal process. 

If the processing of your Personal Data is based on your consent, the GDPR and Data Protection Act 2018 also allow users the right to access, revoke, or modify your consent at any time.  Please see the Exercising Your Rights section below to review or modify your consents.  

Your Data Protection Rights.  As a resident of the EU/EEA or a country following substantially similar legislation regarding the protection of Personal Data, individuals may have one or more of the following additional rights: 

• Access: To request a copy of the Personal Data we have collected about you by contacting us. 

• Rectification & Erasure: To request that we rectify or delete any of the Personal Data about you that is incomplete, incorrect, unnecessary, or outdated. 

• Objection: To object, at any time, to Personal Data about you being Processed for direct marketing purposes. 

• Restriction of Processing: To request restriction of Processing of Personal Data about you for certain reasons, such as, for example, if you consider Personal Data about you collected by us to be inaccurate or you have objected to the Processing and the existence of legitimate grounds for Processing is still under consideration. 

• Data Portability and Transfer: To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.  You may also request that this Personal Data be transferred to a third party specified by you. 

• Right to Withdraw Consent: If Personal Data about you is Processed solely based on your consent and not for any other legitimate interest, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including Processing related to existing contracts for our products and services. 

• Right to Lodge a Complaint with a DPA: If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, you may lodge a complaint with your local supervisory data protection authority (“DPA”), but we invite you to contact us with any concern and we would be happy to try and resolve it directly. 

Exercising Your Rights.  To exercise any of the above-listed rights, please contact us as set forth below and provide sufficient details so that we can respond appropriately.  

• Calling us at (888) 724-7551 

• Emailing us at [email protected] 

• Writing us at  

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

• Online Form 

We will process any requests in accordance with applicable law and within a reasonable period of time.  We may need to verify the identity of the individual submitting a request before we can address such request.  If the request relates to data our customers collect and process through the Locus Services, we will refer the request to that customer and will support them in responding to the request.  For Locus customers, certain information may be reviewed, corrected, and updated by logging into the Locus Services account and editing the profile information. 

Retention.  We will retain your Personal Data for as long as needed for the purposes described in this Notice.  More specifically, the time we maintain your Personal Data depends on the following factors: 

• Whether we need the Personal Data to provide you with goods or services.  We will maintain any data needed to provide you with goods or services, such as contact information and payment or transaction information, for as long as needed for us to provide you with goods or services, respond to your questions and requests, and/or administer your account (if applicable). 

• Whether we need the Personal Data to comply with our legal obligations.  We may have legal obligations to maintain your Personal Data where a legal or regulatory body may ask for it in the future, for example in response to a data subject request or complaint.  This information may include contact information and location information.   

• Whether we need the Personal Data for a legitimate business interest.  We may store Personal Data like contact information, information provided from cookies, and location information in order to perform analytics, troubleshoot errors, or improve our goods or services.  In any event, we delete information when it is no longer needed for our legitimate interest. 

Questions and Complaints.  Locus commits to resolving complaints about our collection or use of your Personal Data.  EU/EEA, UK and Swiss users with inquiries or complaints regarding this Notice should first contact us by email at [email protected], or please write to the following address: 

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

Locus has further committed to refer unresolved privacy complaints to JAMS, an alternative dispute resolution provider located in the United States, at no cost to you.   

Compelled Disclosures.  Locus may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

Contact Information.  Unless otherwise specified, the data controller of Personal Data provided to Locus is the Locus customer for whom Locus is providing goods or services, and Locus is the data processor of such Personal Data for such customer.  In certain cases, Locus may also be the data controller of aggregated, anonymous, or pseudonymous data relating to the Locus Services.  If you have any questions about this Notice or the Personal Data we have collected about you, please contact us at the following: