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SafeSole

data protection

This Privacy Policy of Global SafeTrack Systems is intended to inform you about how we and our partners GARMIN and INREACH/IRIDIUM/GSM operators ("INREACH/IRIDIUM/GSM") process your personal data when you visit the Global SafeTrack Systems website, create a ProteGear account, register and use your INREACH/IRIDIUM/GSM device, subscribe and use GSM or satellite communication services, and use the Earthmate app and the Explore app.

"Personal Data" refers to information about an identified or identifiable natural person.

If you want to navigate to a specific section of this Privacy Policy, click on one of the following links:

- Categories of personal data processed by Global SafeTrack Systems
- Categories of recipients of personal data
- Transfer of personal data
- Cookies and similar technologies
- Children
- Updates to the Privacy Policy
- Storage of personal data
- Responsible person and data protection officer
- Your rights
- Basic information on data storage, backups, and deletion of data.

Categories of personal data processed by Global SafeTrack Systems

PERSONAL DATA PROCESSED WHEN CREATING A PROTEGEAR ACCOUNT:

When you create a ProteGear account, you will be asked to provide your email address and name. If you prefer, you can provide just your first name or a nickname instead of your full name.

PURPOSES AND LEGAL BASIS:

(a) Global SafeTrack Systems processes your email address as you use this email address and your password to log into your account. The legal basis for processing the email address for this purpose is based on the legitimate interest of Global SafeTrack Systems to protect the security of your account.

(b) Global SafeTrack Systems also processes the email address to send you important information about your devices, your apps, your subscription, or your account, such as important safety information or significant changes to this Privacy Policy. The name you provided is linked to your ProteGear account. The legal basis for processing the email address for this purpose is based on the legitimate interest of Global SafeTrack Systems to provide you with important information about your devices, your apps, your subscription, or your account.

(c) If you agree to receive marketing information from Global SafeTrack Systems, we will also process your email address to send you marketing information about Global SafeTrack Systems products and apps. The legal basis for processing the email address for this purpose is your consent. You can withdraw consent at any time by changing preferences in your ProteGear account or clicking on the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from Global SafeTrack Systems are based on preferences set in your ProteGear account, the location indicated by your IP address, the types of Global SafeTrack Systems devices you have added to your ProteGear account, and the subscriptions in your ProteGear account. The legal basis for processing this data for this purpose is the legitimate interest of Global SafeTrack Systems to reduce the number of marketing emails sent to individual customers by selecting which customers receive a particular marketing email rather than sending the marketing email to all customers who have agreed to receive marketing emails.

(d) Global SafeTrack Systems also processes your email address to link it to your ProteGear account when you communicate with our support. The legal basis for this processing is our legitimate interest in providing high-quality support.

PERSONAL DATA PROCESSED WHEN YOU CHOOSE TO LOG IN TO YOUR PROTEGEAR ACCOUNT WITH SOCIAL NETWORK CREDENTIALS:

You have the option to log into your ProteGear account using social network credentials (e.g., your Facebook login details). If you choose this option, you will be asked at the first login if you agree that the social network provider may share certain information with Global SafeTrack Systems, such as your name, email address, profile photo, posts, comments, and other information associated with your social network account. This information is provided to Global SafeTrack Systems by the social network provider based on how the social network login configuration works. However, Global SafeTrack Systems only stores and processes your email address from the entirety of this information. If you do not want the social network provider to share your data with Global SafeTrack Systems, you can simply log in with your ProteGear account credentials and not use the social network login details.

PURPOSE AND LEGAL BASIS:

Global SafeTrack Systems links the email address provided by the social network provider to your ProteGear account so you can log in with your email address to your ProteGear account in the future if you no longer wish to log in with social network credentials. The legal basis for processing this information for this purpose is the legitimate interest of Global SafeTrack Systems to provide you with an alternative login method and to protect your account.

PERSONAL DATA PROCESSED WHEN YOU PURCHASE A SUBSCRIPTION FOR INREACH/IRIDIUM/GSM SATELLITE COMMUNICATION SERVICES:

When you purchase an INREACH/IRIDIUM/GSM subscription, INREACH/IRIDIUM/GSM collects your email address, mailing address, billing address, phone number, and contact information for

 the emergency contacts you have set. Vantiv, a third-party provider, processes payment card information when you purchase a subscription for INREACH/IRIDIUM/GSM satellite communication services. Read the privacy policy carefully.

PURPOSE AND LEGAL BASIS:

(a) INREACH/IRIDIUM/GSM processes the email address to link it with your subscription for INREACH/IRIDIUM/GSM satellite communication services so you can send and receive emails to and from other users of INREACH/IRIDIUM/GSM devices and to send you billing and other information about your subscription to the INREACH/IRIDIUM/GSM satellite communication services. The legal basis for processing the email address for these purposes is the fulfillment of the subscription contract.

(b) INREACH/IRIDIUM/GSM processes your mailing address because GEOS and the GEOS International Emergency Response Coordination Center ("IERCC") use the mailing addresses of INREACH/IRIDIUM/GSM subscribers to determine whether the SOS button was accidentally activated by a subscriber at their residence. The legal basis for this processing is the legitimate interest of INREACH/IRIDIUM/GSM to reduce the number of false alarms.

(c) INREACH/IRIDIUM/GSM processes the phone number as it is used by GEOS and the IERCC to determine whether the subscriber accidentally activated the SOS button at their residence; it is also used by INREACH/IRIDIUM/GSM to contact subscribers regarding billing information. The legal basis for this processing is the legitimate interest of INREACH/IRIDIUM/GSM to reduce the number of false alarms and to contact subscribers regarding their billing information.

(d) INREACH/IRIDIUM/GSM processes contact information for the emergency contacts you have set so that INREACH/IRIDIUM/GSM and/or GEOS and IERCC can communicate with these emergency contacts if you are in an emergency situation. The legal basis for this processing is the legitimate interest of INREACH/IRIDIUM/GSM to communicate with the emergency contacts you have set if you are in an emergency situation.

(e) INREACH/IRIDIUM/GSM processes the email address to send you emails to retain you as a subscriber if you reside in the USA and have not declined to receive these emails or if you reside outside the USA and have agreed to receive these emails. The legal basis for this processing is your consent, which you can withdraw at any time.

PERSONAL DATA PROCESSED WHEN USING INREACH/IRIDIUM/GSM SATELLITE COMMUNICATION SERVICES:

The INREACH/IRIDIUM/GSM products and satellite communication services are intended to notify relevant authorities that emergency assistance is required. To enable INREACH/IRIDIUM/GSM and Global SafeTrack Systems, its affiliates, and service providers to provide this service, INREACH/IRIDIUM/GSM and Global SafeTrack Systems process text, SMS, and email messages sent to and from your INREACH/IRIDIUM/GSM device, and INREACH/IRIDIUM/GSM and Global SafeTrack Systems process the location of your INREACH/IRIDIUM/GSM device when the INREACH/IRIDIUM/GSM device communicates with Iridium satellites.

PURPOSE AND LEGAL BASIS:

Fulfillment of a contract.

PERSONAL DATA PROCESSED WHEN USING THE GLOBALMAIL SERVICE:

When you use the ProteGear GlobalMail system, we store data for transmitting text messages (EMAIL / SMS etc) to and from the device and process it further through MailGun services, with servers located exclusively in the EU.

PURPOSE AND LEGAL BASIS:

Fulfillment of a contract.

PERSONAL DATA PROCESSED WHEN COMMUNICATING WITH GLOBAL SAFETRACK SYSTEMS OR INREACH/IRIDIUM/GSM:

When you communicate with our support via email, phone, online, or in person, we collect personal data, such as name, mailing address, phone number, email address, and preferences for contacting, as well as information about the Global SafeTrack Systems products you own, such as serial numbers and purchase date, and information about your subscriptions. We may also create event logs that can be helpful in diagnosing product or app performance problems, and we collect information about the support or service issue. To improve customer service, subject to applicable laws, conversations with customer service representatives may be recorded and reviewed by us; we may also analyze feedback provided to us in voluntary customer surveys. With your consent, our customer service representatives may log into your ProteGear account, if appropriate, to assist with treating and resolving the issue.

PURPOSE AND LEGAL BASIS:

We use this information to provide customer and product support and to monitor the quality and type of customer and product support we offer to our customers. The legal basis for processing this information for these purposes is the legitimate interest of Global SafeTrack Systems and INREACH/IRIDIUM/GSM to provide high-quality product support. The legal

 basis for logging into your ProteGear account, if appropriate to assist with treating and resolving the issue, is your consent, which you can revoke.

Categories of recipients of personal data

GEOS AND IERCC:

If you use the satellite communication services and trigger an SOS emergency signal, INREACH/IRIDIUM/GSM provides various information, including name, email address, mailing address, phone number, content of the message, time of sending, as well as the identity and location of the sender and receiver of the message, to GEOS and the GEOS International Emergency Response Coordination Center ("IERCC"); we may also provide this information to relevant authorities and emergency services and members of your family. GEOS and IERCC may also provide information required for emergency services.

SEARCH AND RESCUE SERVICES AND EMERGENCY SERVICES:

If you use the satellite communication services and trigger an SOS emergency signal, INREACH/IRIDIUM/GSM may provide various information, including name, email address, mailing address, phone number, content of the message, time of sending, as well as the identity and location of the sender and receiver of the message, to relevant search and rescue services and emergency services. GEOS and IERCC may also provide this information, where applicable, to relevant search and rescue services and emergency services.

FAMILY MEMBERS:

If you set this in our subscription settings, INREACH/IRIDIUM/GSM can also provide information such as the content of the message, the time of sending, as well as the identity and location of the sender and receiver of the message to family members listed in your subscription settings.

PEOPLE YOU INVITE TO TRACK YOUR LOCATION:

You can invite family, friends, or other individuals to track your progress on a computer or mobile device via the web-based MapShare / TripShare™ portal. The INREACH/IRIDIUM/GSM device sends track points at pre-determined intervals so others can track your location online. You can also invite family members, friends, and other individuals staying at home to send a location request to your INREACH/IRIDIUM/GSM device via MapShare / TripShare to receive your GPS location during the trip, track your route, and exchange messages. You can also integrate your MapShare / TripShare page into a blog, website, or social media if desired.

OTHER SERVICE PROVIDERS:

Global SafeTrack Systems uses third-party cloud services such as Adobe and Emarsys to support sending emails. These services track activities associated with the emails, such as whether the email was opened, whether links in the emails were clicked, and whether purchases were made after clicking these links. Global SafeTrack Systems uses this data to analyze the level of interaction with these emails. Global SafeTrack Systems works with external service providers to better understand the use of our websites and apps and for similar purposes.

INREACH/IRIDIUM/GSM uses SendGrid to send messages from Global SafeTrack Systems INREACH/IRIDIUM/GSM devices to email addresses, and SmartFocus to send newsletters and other content via email to subscribers.

FURTHER DISCLOSURE OF INFORMATION:

We may disclose data about you to others: (a) if we have your effective consent; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce our terms or policies; (d) to exercise available legal remedies or defend legal claims; or (e) if we deem it necessary or appropriate to attempt to assist you if you are in an emergency situation.

Additionally, we may transfer your personal data in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Global SafeTrack Systems or INREACH/IRIDIUM/GSM business, assets, or stock, including, without limitation, in connection with any bankruptcy or similar proceedings, to affiliated companies, subsidiaries, or third parties, provided that any party to whom we transfer personal data is not permitted to process your personal data in any manner other than as set forth in this Privacy Policy without informing you and, if required by applicable laws, obtaining your consent.

Transfer of personal data

Global SafeTrack Systems is a global company. To offer our products, apps, and services, we may need to transfer your personal data to other Global SafeTrack Systems companies in other countries. Personal data concerning individuals residing in a country of the European Economic Area or in Switzerland is under the control of Global SafeTrack Systems GmbH.

Cookies and similar technologies

WEBSITE:

To better analyze the navigation on the Global SafeTrack Systems Explore website by you and other visitors, compile statistical data on website usage and response rates, diagnose problems with Global SafeTrack Systems servers, and manage the Global SafeTrack Systems Explore website, we collect certain information with the support of external analytics service providers when you visit our website. This information includes the IP address, the geographical location of the device, the browser type, the browser language, the date

 and time of the request, the times of your visits, page views, and the page elements (e.g., links) you click on. We may use cookies, tracking pixels, web beacons, clear gifs, or similar tools on our website or in our email messages to help us collect and analyze this information. We use this information to provide better, more relevant content on our website, to identify and fix problems, and to improve the user-friendliness of our website.

If you do not want information to be collected using these technologies, most browsers give you the option to automatically reject many of these technologies or to choose whether to reject or accept them.

If you reside in the European Union or a jurisdiction where we need your consent to use cookies on our websites, you have the option to manage your cookie preferences on the websites; an exception to this are certain cookies that are necessary for website operation; you cannot disable these cookies.

Below are some third-party providers of analytics and similar services that we are currently working with:

ANALYTICS SERVICES:

- Google: Google Analytics is used to collect usage statistics, demographic data, and interests of users, and user behavior on websites. We also use Google Search Console to understand how our website visitors find our website and to improve our search engine optimization. Get more information on the possible use of these analytics data, controlling the use of your information, and refusing consent for the use of data by Google Analytics.

Children

Our websites and apps are not directed to individuals under the age of 16, and we ask that individuals under 16 not provide Global SafeTrack Systems with any personal data. If we learn that we have collected personal data from a child under 16, we will take steps to delete the data as soon as possible.

Updates to the Privacy Policy

We may occasionally update this Privacy Policy as we add new products and apps, optimize our current offerings, or technologies and laws change. The date of the last revision of this Privacy Policy can be found in the "Last Updated" legend at the top of the page. Changes take effect upon the publication of the revised Privacy Policy.

If there are significant changes, we will inform you and, if required by applicable law, obtain your consent. We will inform you by email or by publishing a notice of the changes on the Global SafeTrack Systems websites and apps that link to the Privacy Policy.

Storage of personal data

We store your personal data as long as your ProteGear account is considered active. Furthermore, below under "Your Rights" you will find a description of your right to delete the data.

Responsible person and data protection officer

If you reside in a country in the European Economic Area or Switzerland, the responsibility for the personal data collected by Global SafeTrack Systems lies with Global SafeTrack Systems GmbH, Filzenweg 14, 83071 Stephanskirchen. The EU Data Protection Officer of Global SafeTrack Systems can be found at the same address and can be reached by email at the following address: euprivacy@protegear.com.

Your rights

If you reside in the European Union, you are entitled under the General Data Protection Regulation to request access to and correction or deletion of your personal data from Global SafeTrack Systems; you also have the right to data portability, the right to restrict the processing of your personal data, the right to object to the processing of your personal data, and the right to lodge a complaint with a supervisory authority. If you reside outside the European Union, you may have similar rights under local laws.

To request access to or correction, portability, or deletion of personal data or to delete your ProteGear account, visit the Account Management Center.

If you reside in the European Union and wish to exercise your right to restrict the processing of data or object to the processing, contact the EU Data Protection Officer of Global SafeTrack Systems: Global SafeTrack Systems GmbH, Filzenweg 14, 83071 Stephanskirchen, Germany; Email: euprivacy@protegear.com. If you do not reside in the European Union but believe you are entitled to restrict the processing of data or object to the processing under local laws, please contact Global SafeTrack Systems International, Inc. at privacy@protegear.com.

Additionally, the following terms apply to all InReach rates: https://www.garmin.com/de-DE/privacy/inreach/policy...

This consent may only be given by users who are older than 13 years old. If you are younger, we ask you to seek advice from your guardians.

Basic information on data storage, backups, and deletion of data:
Global SafeTrack Systems GmbH generally stores the above data only on data centers in the EU.
These data are usually automatically deleted after a period of 12 months.
A shorter deletion interval can be agreed upon request, but the minimum is 7 days.

For more information on shipping costs & payment information, please see the Shipping Policy.

Please send us an email if you wish to revoke your consent: mailto:info@globalsafetr

ack.com

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