SHOELACE WIRELESS, INC.

Privacy Policy

Thank you for your interest in the EcoBytes APP and Service (the “Service”) made available by Shoelace Wireless, Inc., a Delaware corporation, (hereinafter, “Shoelace,” “us,” “we,” “our”). The terms “you”, “your”, and “yours” refer to anyone downloading, installing, or using the Service.

Your personal privacy is important to us. This Privacy Policy, effective April 4, 2022, explains our information practices and has been incorporated by reference into the End User License Agreement that governs your use of the Service. Please read carefully to understand when do we collect your information, what type of information do we collect, how we collect, how we use, with whom do we share and what steps do we take to protect your information. By downloading, installing, or using the Service, you consent to the collection and use of your information as outlined in the Privacy Policy.

COLLECTION OF INFORMATION

1. Information You Provide Us.

We may collect information about you anytime you interact with us such as when you (i) download and install the APP, (ii) communicate with us either by e-mail or over the phone, (iii) request information about our products, or (iv) use the Service and the Service reports the APP’s statistics to us.

2. Information We Collect When You Use EcoBytes.

When you access or use EcoBytes, we automatically collect information about you including:

2.1. Personally Identifiable:

Personally identifiable information comprises any information, which can help us identify or locate an individual, including, without limitation, an individual’s name, address, e-mail address, telephone number, etc.

We collect personally identifiable information only when you specifically and knowingly disclose such information. For example, we collect your information when you decide to register an account or when sending us feedback that includes your email address. If you disclose your personal information, we will only store and use such information that we need to meet your requests and our legitimate business objectives. If provided, we primarily use your personal information to enable an improved and customized online experience and service for you, as well as advocating on your behalf for other benefits. We may also use the information we collect from you for the purpose of providing you with customer service and to comply with any requirements of law.

2.2. Non-personally Identifiable:

Non-personally identifiable information comprises information that does not by itself identify an individual and generally includes anonymous information about an individual’s use of the Service, for example, information type of mobile device used, type of network accessed, the type of operating system on your mobile device, network performance, and the options selected when using the Service.

We will automatically collect certain non-personally identifiable information each time you use the Service only when you explicitly accepted the End User License Agreement (EULA). For this purpose, we may use certain technology such as Firebase Analytics.  We collect anonymous information about our users so that we can understand how users are using the Service and improve our Service.  This information includes, without limitation, network types, network usage, APP usage, broad demographic information and location data.

2.3.  Information Collected by Cookies:

Our website may contain “cookies.”  Cookies are bits of electronic information generated by web servers and stored on your hard drive when you visit practically any website on the Internet.  Cookies are often used to differentiate users, store user preferences and track user trends in general.  We may use cookies to improve the quality of our website and to better understand how users interact with our website.  We do not use cookies to retrieve individual personally identifying information about you from your computer unless you knowingly and willingly provide such information.  You can adjust your web browser security settings to refuse all cookies or to indicate when a cookie is being sent.  However, if you disable the use of cookies in your web browser, some features of our website we offer may not function properly.

SHARING OF INFORMATION

3. General Uses.

Personal information which we collect for a particular purpose will only be saved and used for that purpose, unless you have agreed to allow us to use it for some other purpose, as described in this Privacy Policy.  We use Firebase Analytics to process and analyze only non-personally identifiable information.  Firebase’s Privacy Policy can be found at https://firebase.google.com/policies/analytics/. We sometimes share non-personal information with other third parties about our user base, but that information does not include any personally identifiable information.  Except as set forth in this Privacy Policy, we do not trade, share, rent, sell, or give away information concerning you to third parties.

4. Service Providers and Strategic Partners.

We may disclose your personally identifiable information to our service providers and strategic partners. These third party service providers and partners will have access to personal information needed to perform their functions but may not use it for other purposes.

5. Enforcement.

We may disclose your personally identifiable information or otherwise use such information to communicate with you if required or permitted to do so by law or in the good-faith belief that such action is necessary to: (i) conform to legal requirements or comply with legal process or governmental requests; (ii) protect and defend our rights or property and that of our users and licensors; (iii) enforce our applicable service agreements; or (iv) protect the personal safety or interests of our employees and consultants, other users of the App, or members of the public in urgent circumstances. We may also disclose any of your personal information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or, as we deem necessary in our sole discretion, in order to protect our legitimate legal and business interests.

6. Aggregated General Information.

We may share aggregated general information about our Service with our corporate partners, investors, advertisers or others. Aggregate general information includes without limitation the number of users of our Service, usage statistics and user feedback. Aggregated general information does not include any personally identifying information that could be used to contact or identify you.

7.Change of Control.

In the event that another company acquires all or substantially all of our assets, or if we experience some other change of control event such as merger, insolvency, bankruptcy or receivership, we reserve the right to include any or all user-related information among the assets transferred to the acquiring company. We cannot guarantee that any entity receiving such information in connection with any of these transactions will comply with all the terms of this policy.

SECURITY

8. Security.

We take appropriate security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, users’ information. We restrict access to your personally identifying information to employees who need to know that information in order to operate, develop or improve the Service. Our servers are protected by firewalls and are physically located in secure data facilities to further increase security. While no computer is 100% safe from outside attacks, we believe that the steps we have taken to protect your personal information drastically reduce the likelihood security problems to a level appropriate to the type of information involved. If you have any questions regarding which measures and techniques we use, feel free to contact us.

YOUR CHOICES

9. Account Information.

During the online account registration process, if applicable, you can review, change or remove the information you have submitted. We aim to keep our information about you as accurate as possible and encourage you to promptly update your information if it changes. You may, at any time, access your information to update, modify or delete any inaccuracies by accessing your account through the Service. You may also request us to remove your account information from our databases and we will try to remove as much information as possible. However, as we generally keep information related to past transactions for our records, we will not be able to completely remove your information.

10. Changes to Privacy Policy.

We may change our policy at any time by posting a new version of it on our website. We encourage you to check our website regularly for information about revisions to this Privacy Policy. In the event that we change our Privacy Policy, such changes will affect all of the information we collect after any such change. If you object to the change to our Privacy Policy, then you must contact us in writing regarding your objection.

QUESTIONS AND COMMENTS

If you have any questions or comments about this Privacy Policy, you may contact us at info@shoelacewireless.com.