SAFE RETRIEVE, LLC PRIVACY POLICY

Effective Date: January 19, 2023

This Privacy Policy explains our privacy practices, defines our users’ (“you,” “your,” or “Users”) privacy options, and describes how your information is collected and used by Safe Retrieve, LLC (“we,” “us,” “our,” or “Safe Retrieve”).

This Privacy Policy, along with our Terms of Use, governs your use of the Safe Retrieve website at https://www.skyshepherd.com as well as any of our applications (“App”), products, services, features, tools, or resources, including any services provided through the SkyShepherd platform (collectively, the “System.”). We will not use or share your information with anyone except as described in this Privacy Policy. By providing information to us or using our System, you are consenting to our use of your data as outlined in this Privacy Policy.

By downloading, installing, or using any portion of the System, you agree to the terms of this Privacy Policy and our Terms of Use.

REVISIONS TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy from time to time and will mark new versions with a corresponding effective date. Your continued use of the System constitutes your agreement to our then-current Privacy Policy.

INFORMATION COLLECTION AND USE

We may collect personal information about you in connection with your use of the System. For example, this information may be voluntarily provided when you register an account, customize and fill out your User, authorized user, and pet profiles, sign up for a mailing list, fill out a “Contact Us” form, or submit information in connection with a purchase or as part of other online services.

The information we may collect includes, but may not be limited to:

• Name, registered pet names, and other information submitted in connection with a customized user or pet profile;


• Email address, phone number, mailing address, and other contact information;


• Financial information necessary to process a purchase or other request;


• Business affiliations; and


• Other information related to your requests or inquiries.

Some of the personal information we collect from you may happen automatically. We use tracking technologies such as cookies and log data to automatically collect information when users visit and use our System. Information we collect includes but may not be limited to:

• Anonymous usage analytics;


• Location data of the device using our App;


• Location data of the SkyShepherd pet device;


• Behavioral patterns of a registered pet’s movements;


• In a case of an error in the System, we collect data and information (through third party products) on your device called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the App when utilizing our System, the time and date of your use of the System, and other statistics. We use this data for quality control and development in order to improve the System;


• IP address to measure our website traffic and to help provide a more personalized experience;


• Information regarding your browser and other technical specifications required to use the System;


• Your transaction history relating to the use of our products and services; and


• Computer data files, often called “web beacons” that are collected from emails or links on third-party sites that allow our server to evaluate the popularity of those links or the information contained in emails or on third-party sites.

The System also uses third party services that may collect information used to identify you.

COOKIES

Cookies are small data files that help us keep track of your usage of the System. Many of the cookies we use enable the System to function as you would expect it to. Cookies enable the System to remember things like your login information, so you do not have to re-enter it, user preferences, and other personalized settings. Cookies also enable us to track and analyze user behavior in order to improve our System. Most web browsers automatically accept cookies, but you can choose to accept or decline certain types of cookies if you prefer. However, declining cookies may impact the functionality of the System and in some cases you may not be able to access the functions of the System. We use the following categories of cookies on the System:

• Session cookies: Session cookies are stored on the user’s hard drive temporarily and are deleted when the user ends the browsing session. Session cookies are useful for things like keeping items in a shopping cart while the user continues to browse.


• Persistent cookies:Persistent cookies stay on the user’s hard drive until they expire, even after the browser is closed. Persistent cookies are useful for remembering things like login information, so users do not have to enter their password every time they visit the System.


• Third-party cookies:Third party cookies are not installed directly by our System, but by third parties such as advertisers. Third party cookies are used to track advertising preferences from site to site, and to gather data about users’ browsing habits in order to improve the user experience.

To learn more about the use of cookies by Google for analytics and to exercise choice regarding those cookies, please visit the Google Analytics Opt-out Browser Add-on or the Digital Advertising Alliance.

Apart from cookies, when you engage in a transaction with us or clock on certain features, we will use a hashing algorithm that protects your personal information before we send it to Google for analytics and matching purposes. For more information on this process, please see How Google Uses Enhanced Conversion Data.

There are “do not track” or similar browser choices available to internet users with respect to online web activity but given the present lack of consensus of what constitutes an informed election, appropriate trigger or breadth of scope of such choice, our Website will not operate any differently when a “do not track” signal is received.

CLEAR GIFS

Clear GIFs (also called pixel tags or web beacons) are small files embedded in websites that tell us what content a user accesses and how users navigate the System. Clear GIFs enable us to track and analyze user behavior on the System in order to make it more intuitive and user friendly.

LOCATION INFORMATION

Our App collects, maintains, processes, and uses your location data, including the real-time geographic location of your mobile device as necessary to provide the App’s full functionality.

If you do not want us to collect this information you may opt out at any time by turning off the location-based feature on your mobile device. Note, however, that opting out of the App’s collection of location information will disable some of its location-based features.

HOW IS THE INFORMATION WE COLLECT USED?

We collect information about you in order to provide you with services and products, and also to collect information that is necessary for the System to work properly. We use personal information for a variety of purposes related to our business, including but not limited to:

• Providing services and support: Performing the essential functions of the System including providing feedback about a pet’s whereabouts and movement, creating boundaries through the System, responding to user inquiries, fulfilling orders and requests, processing payments, providing support and troubleshooting, verifying customer identification, providing information about a pet’s location, behaviors, and movements to the user, and communicating with users about their use of the System or regarding a user initiated inquiry on the System.


• Alerting User to Changes in Pet Behavior and Location: Over time, the System will store information about the behavioral patterns of registered pets. We may use this information to alert users to significant changes in their registered pets’ normal behavior. We may also use this information to share a pet’s location with a user or authorized user in the event a pet is lost.


• Communicating with users about products or services: Sending or initiating direct marketing programs, such as newsletters or information about new products or services we are offering; using content from social media platforms where users discuss our products or use a hashtag related to our products.


• Personalizing user experiences on our System: Tailoring content on the System based on user location, preferences, and other personalization factors.


• Analytics and System Improvement: Tracking information about your and your pet’s use of the System to allow us to provide better service; using collected aggregated data sets to improve System algorithms; using certain online preferences in the aggregate across all users to evaluate the System and develop additional products and services to offer.


• Compliance with legal obligations:Sharing information to comply with the law or a legal proceeding, such as in response to a subpoena or court order.


• Other purposes necessary to carry out our obligations under this Privacy Policy or our Terms of Use

DISCLOSURE OF INFORMATION

We may share information, in the aggregate, regarding your online browsing preferences to evaluate our products or allow the third parties we work with to better serve our users. We will not share personally identifiable information in these instances, other than as described in this Privacy Policy.

may provide user information to third-party service providers or vendors for purposes including but not limited to:

• To facilitate our System;


• To provide the System on our behalf;


• To perform System-related services;


• To initiate direct marketing programs on our behalf;


• To perform data tracking;


• To maintain or develop our System;


• To perform quality assurance;


• To provide contracted promotional opportunities provided to our users; or


• To assist us in analyzing how our System is used.

These third parties have access to your personal information submitted through the System in order to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

We may also share this information with any subsidiaries, licensees, suppliers, distributors, affiliates, assigns, successors, or other related entities and their respective owners. We may also share your personal information in connection with law enforcement requests or in response to investigations, subpoenas, court orders, or other legal processes to establish or exercise our legal rights or defend against legal claims, or as otherwise required by law.

BUSINESS TRANSFERS

We may also disclose your information to a third party as part of reorganization or a sale of the assets of Safe Retrieve, or its subsidiaries or divisions. Any third party to which Safe Retrieve transfers or sells the System or related assets will have the right to continue to use the personal and other information that you provide to us.

SECURITY

We value your trust in providing us your personal information, thus we are striving to use commercially acceptable means of protecting it and maintain administrative, physical, and technical safeguards for all user information collected in our System. However, no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

LINKS TO OTHER SITES

The System may contain links to other websites. These websites may have privacy policies different than our Privacy Policy. The System may also contain social media icons or widgets. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the privacy policies of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

CHILDREN’S PRIVACY

The System is not designed for children. We do not knowingly collect personally identifiable information from children under 13. If we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we may take appropriate actions.

YOUR OPTIONS

By providing information to us or using the System, you are consenting to our use of your personal information as outlined in this Privacy Policy.

While we work hard to use and disclose our users’ personal information only for the purposes identified above, you can choose not to provide personal information or limit the personal information obtained by us as follows:

• You may have your contact information removed from our marketing lists to inform users of new or relevant products, services, and special offers by clicking on the unsubscribe link in any communication received from us, or by emailing us at support@skyshepherd.com; and


• You may limit the collection of “cookies” through your browser settings. However, this may disable our ability to provide you with the most relevant products or information regarding the System.

YOUR CALIFORNIA PRIVACY RIGHTS NOTICE

This California Consumer Privacy Act Notice (“Notice”) is applicable only to California residents (“consumers” or “you”) and only supplements the information provided elsewhere in this Privacy Policy. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

INFORMATION WE COLLECT

We may collect “Personal Information,” defined as information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Personal Information does not include publicly available information from government records, de-identified or aggregate consumer information, 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; or 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.

The Personal Information we collect may depend on your relationship to us. We may have collected the following categories of Personal Information from California consumers in the past 12 months:

• Identifiers, such as name, contact information, and online identifiers;


• Commercial information, such as transaction information and history;


• Internet or network activity information from visits to our websites, such as browsing history and interactions with our and other websites and systems;


• Geolocation data, to the extent you use our mobile App and choose to share such data from your device; and


• Inferences drawn from any of the Personal Information categories above to create a profile or summary.

SOURCES OF PERSONAL INFORMATION

We collect some of the Personal Information described above directly from you, such as through your interactions with us, including those on our websites and through our systems. We also collect Personal Information from categories of sources such as third parties authorized by you.

USE OF PERSONAL INFORMATION

Depending on your relationship with us, we may use or disclose the Personal Information we collect for one or more of the following business purposes:

• Facilitate the creation of and secure your account on our network;


• Identify you as a user in our system;


• Provide improved administration of our website, services and products;


• Create, develop, operate, deliver, and improve our products, services, content, and advertising;


• Measure and analyze audience traffic and improve the quality of your experience when you interact with our website and services, and for other internal purposes;


• Send you a welcome e-mail to verify ownership of the e-mail address provided when your account was created;


• Send you administrative e-mail notifications, such as security, or support and maintenance advisories;


• Send newsletters, surveys, offers, and other promotional materials and for other marketing purposes;


• Help recognize you as a previous visitor and save and remember your preferences and settings and deliver to you appropriate interest-based content;


• Understand whether you read email messages and click on links within those messages;


• Prevent potentially prohibited or illegal activities, comply with applicable law, and enforce our Terms of Use;


• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA; and


• For other purposes permissible under applicable law.

We will not collect additional categories of Personal Information from those identified above or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

SHARING PERSONAL INFORMATION

We may engage third party companies or individuals as service providers or business partners to process other information and support our business. These third parties may, for example, provide virtual computing and storage services, or we may share business information to develop strategic partnerships with third party service providers to support our common customers.

We share your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates;


• Service providers and vendors;


• Third parties whom you authorize us to disclose your Personal Information so we may provide you our products or services; and


• To other third parties as required or permitted by law.

We do not disclose the Personal Information of consumers under 18 years of age.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may have certain rights with respect to your Personal Information, including the following:

• The right to know, for a period of 12 months prior to your request:
  • the categories of Personal Information we collected about you;
  
  
  • the specific pieces of Personal Information we collected about you;
  
  
  • the categories of sources from which we collected the Personal Information;
  
  
  • the business or commercial purposes for collecting the Personal Information;
  
  
  • the categories of Personal Information we disclosed or sold to third parties, if any, and the categories of those third parties.
  
  
• The right to “opt-out” of our sale of your Personal Information to any third parties;


• The right, with some exceptions, to have your Personal Information deleted from our possession or control; and


• The right to receive equal service and pricing from us even if you exercise any of your privacy rights.

If you exercise the right to delete your Personal Information, we may still retain your Personal Information as permitted under applicable law, including but not limited to the following purposes:

• To provide goods or services you requested;


• To detect security incidents or other fraudulent or illegal activity;


• To identify, debug and repair errors and existing impairments to intended functionality;


• To comply with our legal and regulatory obligations; and


• To enable other uses compatible with your expectations, or appropriate given the context in which the Personal Information was collected.

In addition, California Civil Code Section 1798.83 permits California residents who use our website to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

To make a request to exercise any of these rights, or if you have any questions or concerns about your rights, our Privacy Policy or our use of your Personal Information, please contact us at:

Safe Retrieve, LLC
2095 Daniels Street #474
Long Lake, MN 55356
Phone: 1 (612) 808-9925
Website: https://www.skyshepherd.com
Email: support@skyshepherd.com

Only you (or a person registered with the California Secretary of State you have authorized 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 make such a request no more than twice during a 12-month period.

We shall respond to consumer inquiries within forty-five (45) days and at no cost to you. We will inform you in writing if we require more time to respond, up to an additional forty-five (45) days. We may charge a fee to respond to excessive, repetitive, or manifestly unfounded requests, in which case we will provide you with a cost estimate and rationale before completing your request.

We must verify your identity with respect to such inquiries. Please provide enough information to permit us to locate you in our records. Depending on the nature of the Personal Information at issue and the clarity of your request, we may require additional measures or information from you as part of that verification. If you have an account with us, we will deliver our written response to that account. If you request delivery of specific pieces of Personal Information, we will select a readily useable format that should permit you to transmit the information to another entity without hindrance.

For California residents under age 18 who have publicly posted content or information, you may request and obtain removal of such content or information pursuant to California Business and Professions Code Section 22581, provided you are registered user of any website where this Notice is posted. To make such a request, please send an email with a detailed description of the specific content or information to support@skyshepherd.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that the law may not require or allow removal in all instances, even if requested.

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; or


• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

CONTACT US

If you have any questions or suggestions about this Privacy Policy, contact us at support@skyshepherd.com.