SBM PRIVACY NOTICE

SBM PRIVILEGED AND CONFIDENTIAL 05.20.2021

SBM PRIVACY NOTICE

Last Updated: May, 2021

The privacy and security of your information is important to us. This Privacy Notice explains how wecollect, use, and share your information. This Notice applies to information collected by us through anymeans, including through our website or mobile application, from client representatives, and fromindividuals who receive package deliveries through us. We provide package intercept and messenger centers and corporate concierge services in commercialbuildings in New York City. In the course of our business, we collect certain information that identifies,relates to, describes, and is reasonably capable of being associated with a particular person or household(“Personal Information”). Personal Information does not include publicly-available information ingovernment records or de-identified, anonymized, or aggregated consumer information.If you are under 13 years of age, please do not send us any information about yourself. Our website andour services are not directed to you.

INFORMATION WE COLLECT AND HOW WE USE IT

We collect Personal Information and other information from or about you in a few different ways.Specifically, we may collect or receive information: (1) directly from you through information you provide; (2) indirectly from you by observing your actions on our website; and (3) from third parties such as dealers, resellers, Google or Facebook. Each of these is discussed in more detail below.

Information You Provide

You may provide information to us in a number of ways: 

Contacting Us. When you contact us, the email address and/or telephone number you use to communicate with us generally will be collected directly from you or from our phone system, and any additional information you provide may also be collected to respond to your inquiries. If you call us, your telephone call may be recorded.

  • Corporate Concierge. If you seek services through our corporate concierges, we may collect any information you provide, including your name, address, email address, and telephone number.

  • Website Contacts. If you submit information to us through a form on our website, we will collect the information you provide. For example, if you submit our “Let’s Connect” form, we will collect your name, email address, telephone number and any message you include.

  • Client Portal. Employees and representatives of our commercial clients may register to use our client portal. We collect your name, email address, and any other information you may provide through our client portal.

  • Social Media. If you post information on our LinkedIn or social media pages, that information may be collected and used by us (as well as other users of those sites and the public generally).Please do not post any information on any site that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

  • Account and Relationship Management. We may use any or all of the information described in this section to service your account with us or to manage any contractual relationships we may have with you or your employer.

  • Applicants and Employees. If you apply for a job or obtain employment with us, we may collect a variety of information from you including your name, address, email address, telephone number, government-issued identification, work history, and references.

Information Indirectly Collected from You

Please note that, if you are visiting our website from a location outside of the United States, you will be connected through and to servers located in the United States. So the information collected as described in this section will be collected and stored in the United States.

Cookies. We automatically collect information from you using cookies, which are small text files offered to your computer by servers in order to keep track of your browser as you navigate our website. We may use cookies and similar technologies to identify who you are and may use them when you visit our website, click on our ads, or click on links in our emails. Cookies also enable us to remember your user preferences for our website. Cookies may be “session-only” or “persistent.” Persistent cookies last for more than one visit and are typically used to allow a visitor to our website to personalize their experience.

We may use cookies to analyze the traffic on our website (such as total visitors and pages viewed), to personalize features or save you the trouble of retyping your name or other information, and to make improvements to the website based on the data we collect. We do not save passwords or other sensitive information in cookies. The use of cookies has become a standard in the Internet industry, especially on websites that provide any kind of personalized service.

Cookies may also be placed by third parties prior to or during your visit to the website. Our affiliates and business partners may use these cookies in connection with pixel tracking (discussed below) or otherwise.We do not control these cookies. The use of cookies by advertisers has become standard practice in theInternet industry.

You can block or remove cookies using your Internet browser’s settings. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. If you block or remove cookies, you may not be able to perform certain transactions, use certain functionality, or access certain content on our website.

Pixel Tracking: We may employ a common technique usually referred to as “pixel tracking” to measure the effectiveness of marketing and advertisements, as well as compile aggregate usage statistics. Pixel tracking, which may be used in connection with advertisements on other sites, on our website or in email messages, involves the use of pixel tags (also known as “clear gifs,” “web beacons” or “1-by-1 gifs”) that are not visible to the user of the site and consist of a few lines of computer coding. For example, if you visit our website from an advertisement on another site, the pixel tag will reference the cookie you received when you clicked on the advertisement. The pixel tag also may register this activity with a business partner to allow us to count the number of times or when an advertisement is accessed. This data is collected for use in our marketing and research. Personal Information about you is not collected by pixel tracking, nor is any tracking information generated from the pixel tag allowed to be used for any other purpose other than to report website activity to us.

Traffic Data. We automatically track and collect general log information when you visit our website, including your: (a) Internet Protocol (IP) address; (b) domain server; (c) operating system; and (d) type of web browser; and (e) the pages you visit on our website (collectively “Traffic Data“). We use the Traffic Data to report aggregated website activity and to better understand the needs of our users so we can make informed decisions regarding the content and design of our website. We may collect Traffic Data through various technologies including, but not limited to, cookies, IP addresses, and pixel tags. While it is not our practice to link IP addresses to your Personal Information, we reserve the right to use IP addresses to identify a user when we feel it is necessary to protect the compelling interest of our website, customers or others, or to comply with laws, court orders, or law enforcement requests.

Information from Third Parties

Packages. We collect names, addresses, and telephone numbers of package and message recipients inconnection with providing our package delivery and messenger services.Mobile Application. Our staff may use our mobile application to track the receipt and delivery of packages, which may include taking a picture of the package including the name and address information on it.

Social Media Sites. To the extent you post information on our social media sites, we may collect such information. We may also receive Personal Information about you through certain social media sites such as LinkedIn.

Third Party Analytics Services. We may work with third party analytics services such as GoogleAnalytics to help us understand how our Sites are being used, such as tracking the frequency and duration of use of website and social media pages. These analytics services may use cookies and other technologies to collect information about the content you view, what website you visit immediately prior to and after visiting our website, and your system information and geographic information. The information generated by these technologies about your use of sites may be transmitted to and stored by the applicable analytics services. We receive reports of aggregated data from these services, but we do not receive Personal Information about individual users.

Background, Driving, and Credit Check Providers. When you apply for employment with us, we obtain additional information through references, former employers, background checks, credit reports, and driving records, as permitted by applicable law.

SHARING AND DISCLOSURE OF PERSONAL INFORMATION

We do not sell your Personal Information. We may share your Personal Information as follows: 

  • Delivery Service Providers. We may share Personal Information with people and entities that provide or receive delivery services on our behalf. 

  • Concierge Service Providers. We may share Personal Information with people and entities that provide or receive concierge services on our behalf

  • Service Providers. We may disclose Personal Information to third party vendors, contractors or agents who perform functions for us (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as providing analytics services, employee benefits services, payroll services, or payment processing services. Service Providers may only use the Personal Information they obtain from us or collect on our behalf to provide services to us.

  • Business Transfers. If we are acquired by, or merged with, another entity, if substantially all of our assets are transferred to another entity, or as part of a bankruptcy proceeding, or if we are evaluating or in negotiations with respect to any such transaction, we may transfer, or make available, the Personal Information we have collected from you to the other entity or resulting legal entity.

  • Legal Process. We also may disclose the Personal Information we collect from you: to comply with applicable laws and regulations, a government investigation, a judicial proceeding, a court order, or other legal process (such as in response to a subpoena); or to respond to discovery requests or present evidence in a legal proceeding in which we are involved.

  • To Protect Us and Others. We also may disclose the Personal Information we collect from you where we believe such disclosure is needed to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, suspected violations of this Privacy Notice, and suspected violations of any applicable terms and conditions.

  • Aggregated and De-Identified Information. We may share aggregate or de-identified PersonalInformation with our service providers and/or affiliated companies for marketing, advertising, research, or similar purposes.

  • Job Applications. If you apply for a job position, some of your Personal Information may be shared with third parties in order to confirm your education, work history, and references, and to obtain background checks and credit reports as permitted by law.

  • Employment. If you are employed by us, your Personal Information will be shared with our payroll service providers, benefits providers, and insurance carriers for the purpose of providing and administering payroll and benefits. In addition, certain Personal Information may be shared with our background, driving, and credit check providers for the purpose of obtaining information if you are in a position that requires these checks as a condition of employment. Finally, we maybe required to provide certain Personal Information to governmental agencies to comply with reporting and disclosure requirements.

CHILDREN’S PRIVACY

Our website and our services are not directed to children under the age of 13. We do not knowingly collect Personal Information from children under the age of 13. If you become aware that your child has provided personally identifiable information without your consent and/or is under the age of 13, please contact us at [data.security@sbmnyc.com]. If we become aware that we have unknowingly collectedPersonal Information from a child under the age of 13, we will take commercially reasonable efforts to delete such information from our records

.YOUR COMMUNICATION CHOICES

You may opt-out of receiving email communications and other marketing materials from us (or any third-party email marketing service we may use) via links provided in each email (usually at the bottom of the email).

LINKS TO THIRD PARTY WEBSITES OR PLATFORMS

Our website may contain links to third party websites or platforms. These links are provided for your convenience. We are not responsible for and have no control over the content on these other websites or platforms. The inclusion of a link on our website is not an endorsement. Please note that when you click on one of these links, you will leave our website and will be subject to the policies and privacy practices of the other website or platform, which may differ significantly from our Privacy Notice. Please review such third parties’ privacy policies before providing any Personal Information to them.We make no representations or warranties, express or implied, regarding the content of any of these linked websites or platforms. WE EXPRESSLY DISCLAIM ANY AND ALL LIABILITY FOR YOUR INTERACTION WITH SUCH THIRD PARTY WEBSITES OR PLATFORMS.

SECURITY OF YOUR INFORMATION

We take the privacy of your Personal Information seriously. We use physical, electronic, and administrative safeguards designed to protect your Personal Information, including things like encryption, passwords, and firewalls. Despite these efforts, please understand that no system is perfect and we cannot guarantee that unauthorized access, theft, or loss of data will not occur. Please advise us immediately at[data.security@sbmnyc.com] of any suspected incident involving Personal Information in our custody or control.

CHANGES TO THIS NOTICE

We may revise this Privacy Notice at any time without advance notice to you. The most current version of our Privacy Notice will be posted on our website. Once posted, any changes to the Notice are effective immediately unless otherwise specifically noted. By continuing to use our website, our services, or otherwise provide any information to us after any changes are posted, you agree to be bound by the terms of the revised Privacy Notice.

CONTACT US

If you have any questions or comments about this Privacy Notice, please contact us at:

Email:[data.security@sbmnyc.com]

Mail:

SBM Inc.
Attn. Privacy
248 West 35th Street
New York, NY 10001

57827426;2