Privacy Policy

ConnectM Technology Solutions, Inc. Privacy Policy
Effective August 25, 2021

We want to help you to understand what information we collect about you, why we collect it, and how you can update, manage and delete your information. To do that, we have created this Privacy Policy. To make this Privacy Policy easier to understand, we have included additional information about certain key terms at the end of this document. We capitalize those key terms throughout this Privacy Policy so that you can more easily identify them as you read through it.We build a range of services that help people to automate, monitor and control their residential and/or commercial heating, ventilation, air-conditioning, hot water and other mechanical and/or electro-mechanical systems (your “Equipment”). Our services include cloud-based remote performance management platforms for such Equipment (the “Cloud Services”) which may be accessed via ConnectM’s web portal, including without limitation the Keen Home Pro Contractor Portal (the “Portal”) or ConnectM software installed on your systems and/or devices (your “Devices”), including without limitation the “Keen Home Pro Homeowner app” made available to you via a third party, such as through the Apple App Store and Google Play Store (the “Software” and, together with the Portal and the Cloud Services, the “Platform”).If you have any questions about this Privacy Policy, you can contact us at: info@connectm.com.

INFORMATION WE COLLECT

We collect information to provide a better experience to our users, such as providing better insight to you about how you use your Equipment. This may include detecting patterns of usage to suggest changes to promote efficiency, recommending repairs, replacement, or other Equipment maintenance, along with determining and recommending products and services we believe that you may find useful. The information we collect, and how that information is used, depends on how you use our Platform.When you are signed in to a ConnectM account, we collect information about you, your Devices, your Equipment and any ConnectM hardware components (“ConnectM Hardware”) that you may own, which information we store with your ConnectM account (“Customer Data”), which we treat as Personal Information (as defined below) to the extent that it has not been anonymized. When you’re not signed in, we store the information we collect with data tags tied to the browser, application, or Device or Equipment you are using. This helps us do things like support trigger-based notices, workflow automations, and improve our models of your Equipment’s reliability and usage. We also may track your Equipment’s or Device’s location (if you enable location tracking for our application on your Device) to support automated behaviors based on your proximity to your Equipment.

Information You Provide to Us

When you create a ConnectM Account, you provide us with personal information that may include one or more of the following (“Personal Information”):your name your email addressyour mailing, residence, billing, facility and other addressesa passworda description of your Equipment’s physical location (i.e. “basement”) your Devices’ geolocation (if you enable location tracking for our application on your Device)Phone numbers Payment information You might choose to provide us with information like an email address to receive updates about our services, which you can do without a ConnectM Account.

Information We Collect

We collect and store information using the ConnectM Hardware and various other technologies, including cookies, pixel tags, web storage or application caches, databases, and server logs. We may collect information about you, your activity, your Devices, and your Equipment.Your Activity – We collect information about your activity in our application, which we use to do things like trigger automations, suggest automations, predict Equipment usage to improve your experience, support and recommend third party services and to improve our user experience and features we provide to you. The activity information we collect may include commands you send to Equipment and the success or failure results of those commands and information on application screens you visit and interact with.Your Devices – We collect information about the Devices, browsers and other applications you use to access the Platform. This helps us to provide automatic updates and to ensure compatibility and correct functionality of our software. The information we collect includes Device type, operating system and application version number, data tags, and browser type. We also collect information regarding the settings for your Devices, Equipment and browser. We also collect information about the interaction of your Devices, applications and browsers with our Platform, including IP addresses, crash reports, system activity, the date and time, commands executed and application pages visited. We collect this information when a ConnectM application on your Device contacts our servers — for example, when our applications check for automatic updates. Your Equipment – We collect information about the Equipment that you control and manage using our application and any ConnectM Hardware, which helps us to access the types of Equipment that are monitored and controlled via our Platform. The information we collect includes Equipment type, Equipment location, Equipment information (including, but not limited to, make, model, serial number, rated capacity, and fuel type), Equipment settings, and Equipment performance data. We also collect information about the interaction of your Equipment with our Platform, including IP addresses, crash reports, system activity, the date and time and error and other reports from your Equipment. We collect this information when your ConnectM Hardware contacts our servers or when our servers contact the ConnectM Hardware installed on your Equipment — for example, when you identify a new piece of Equipment in our application or you monitor or control your Equipment with our applications. We also may collect information about your Equipment to communicate performance data about such Equipment to the manufacturers of such Equipment, to your service providers who install and/or maintain your Equipment and to you to provide information and offers for service, repairs or equipment maintenance or replacement warnings which you might find useful.We collect information on your Equipment’s and your Devices’ locations (if you enable location information to our application) to support automated behaviors based on your proximity to your Equipment.

WHY CONNECTM COLLECTS DATA

We use the information we collect from all our services for the following purposes:

To Provide Our Services

We use your information to deliver our services, like remotely monitoring and controlling your Equipment and creating predictive models to improve your Equipment’s longevity and to provide autonomous and automated Equipment behaviors.Examples of how we use your information to deliver our services include:We use data tags stored in cookies on your device to help us authenticate you as the person who should have access to your ConnectM Account.When you purchase services or physical goods from us or our partners, you may provide us information like your shipping address or delivery instructions. We use this information for things like processing, fulfilling, and delivering your order, and to provide support in connection with the product or service you purchase.We track data regarding the status and performance of your Equipment, including without limitation run time, operating mode, suction/liquid line temperature, inlet/outlet water temperature, and supply/return air temperature.We provide you with reports about your Equipment’s performance to help you better understand how you use and maintain your Equipment and when your Equipment may require repairs, replacement or other maintenance.

To Maintain and Improve Our Services

We also use your information to make sure our Platform is working properly, such as troubleshooting issues that you report to us or issues that we detect using analytics software. We may also collect information about how you use our Platform. We use analyze that information to help us to improve our applications for all of our users. We also continuously monitor our Platform to detect problems. This may allow us to fix problems before they arise.

To Develop New Services and Measure Performance

We use the information we collect through our Platform and websites to guide new product and feature development and to measure Platform performance. For example, we optimize our user interface based on popularity of features and determine new features to provide to you.

To Detect Abuse

We use information to help improve the safety and reliability of our Platform, websites and services, including taking efforts to detect and respond to security risks and technical issues that could harm ConnectM or our customers and end-users.

To Provide Personalized Services, Content and Advertising

We use the information we collect to customize our services for you, including providing recommendations for needed repairs, replacement or other Equipment maintenance, or other equipment we think may be of interest to you and providing information to you that we think you might find to be useful. Depending on your settings, we may also show you personalized advertisements based on your use of our Platform and the Equipment you monitor and control with it. We do not share information that personally identifies you with advertisers (other than your service provider who installed, services, and/or monitors your Equipment), such as your name or email unless we have your consent. We never show you personalized advertisements based on personally or politically sensitive information, such as ethnicity, religion, sexual orientation, or health. We may collect information about views and interactions with advertisements so we can provide aggregated reports to advertisers, like telling them whether we served their advertisement on a page and whether the advertisement was likely seen by a viewer. We may also measure other interactions, such as how you move your mouse over a piece of content or an advertisement or how you interact with a page on which the advertisement appears.

To Communicate with You

We use information we collect to communicate with you. For example, we may contact you about your account or to let you know about new services we are offering or changes that we may be making to our Platform. If you contact us, we will maintain a record of it so that we can provide a consistent service and try to address any issues you might have.

HOW connectm PROCESSES YOUR INFORMATION

We use different technologies to process your information for these purposes. We use automated systems, cloud-based services, and computer programs that analyze your use of our Platform and websites to provide you with things like personalized advertisement or to customize our services for you, including providing recommendations for repairs, replacement or other Equipment maintenance, or other equipment we think may be of interest to you and providing information to you that we think you might find to be useful. We may combine information we collect from your use of our Platform and websites and across your Devices for the purposes described in this Privacy Policy. We will ask for your consent before using your information for a purpose that is not covered in this Privacy Policy.

YOUR PRIVACY CONTROLS

You have choices regarding the information we collect and how it is used. This section describes the methods available to you for managing your privacy across our Platform and websites.

Managing, Reviewing, and Updating Your Information

When you are signed in to the ConnectM Platform, you can always review and update information by visiting the services you use.

Ways to Review & Update Your Information

When you are signed into our Platform or websites, you can manage information associated with the Platform or those specific websites, including managing your contact information, such as your name, email, and phone number.

Removing & Deleting Your Information

You can also request to remove content from specific ConnectM services based on applicable law.To delete your information, you can:Delete specific ConnectM applications, including your information associated with those applications.Delete your entire ConnectM account.There are other ways to control the information ConnectM collects whether or not you are signed in to a ConnectM Account, including:Browser settings: You can configure your browser to indicate when ConnectM has set a cookie in your browser. You can also configure your browser to block all cookies from a specific domain or all domains. However, please note that our services rely upon cookies to function properly.Device-level settings: Your Devices may have controls that determine what information we collect. For example, you can modify location settings on your Android device.

SHARING YOUR INFORMATION
When ConnectM Shares Your Information

ConnectM does not share your personal information with businesses, organizations, or individuals outside of ConnectM, except in the following cases:Equipment Service Providers and Vendors – We may share data about your ConnectM Hardware and Equipment to the service providers and vendors of your Equipment. For example, we collect this information when your ConnectM Hardware contacts our servers or when our servers contact your ConnectM Hardware — for example, when you identify a new piece of ConnectM Hardware and/or Equipment in our Platform or you monitor or control your Equipment with our Platform.When You Provide Consent – We may share personal information outside of ConnectM when we have your consent. For example, when you purchase ConnectM Hardware or purchase or subscribe for other services through the Platform or by otherwise contacting ConnectM we share information to facilitate your purchase or subscription. We will ask for your explicit consent to share any sensitive personal information.Account Administrators – Any service providers who manage your account on your behalf will have access to your ConnectM Account. They may be able to:Access and retain information stored in your ConnectM accountChange your account passwordView and change the equipment registered in your ConnectM accountSuspend or terminate access to your ConnectM accountAccess your account information in order to comply with laws or governmental requestsChange your privacy settings.Our Service Providers – We provide your personal information to our affiliates and other service providers so that they may process it for us. This processing is only to be done in accordance with our instructions and in compliance with this Privacy Policy. We require our service providers to keep your information confidential and to maintain appropriate security measures. To Comply with Law – We will share your personal information with third parties if we have a good-faith belief that those third parties require your information in order to:Meet any applicable law, regulation, valid governmental request or legal process. Enforce applicable service contracts, including investigation of potential breaches.Detect, prevent, or address fraud or security issues.Detect, prevent or address technical issues.Protect others against harm, including the rights, property or safety of ConnectM, our employees, our users and the public, as required or permitted by applicable law.We may share aggregated or other anonymized information that we have derived from your information publicly and with our suppliers, vendors and other partners. For example, we may share information publicly to show trends in the use of different types of hardware and equipment. If ConnectM sells or otherwise transfers its business, such as in a merger, acquisition, or sale of assets, we will use best efforts to require the acquiring party to continue to keep your information confidential and to comply with this Privacy Policy.

HOW WE KEEP YOUR INFORMATION SECURE

We work hard to protect you and our Platform from unauthorized access, alteration, disclosure, or destruction of information we hold, including:We restrict access to personal and confidential information to those ConnectM employees, contractors, suppliers, partners and agents who need that information in order to process it. We encrypt your data to keep it private while in transit.We periodically review our information collection, storage, and processin

You can delete specific ConnectM applications, including your information associated with those applications, from your Devices. You can also delete your entire ConnectM account. Even if your account is deleted, we may retain certain of your information as provided below.When you delete data, we follow a process to make sure that your data is completely removed from our servers or retained only in anonymized form. This process takes time, so there may be delays between when you delete something and when copies are deleted from our systems.

RETAINING YOUR INFORMATION

We retain the data we collect for different periods of time depending on what it is and how we use it:We keep some data until you delete your ConnectM Account, such as what type of Equipment is remotely monitored and controlled using our products.We keep some data for longer periods of time when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention or financial record-keeping.

COMPLIANCE

We regularly review this Privacy Policy to ensure that we process your information in ways that comply with it.Our hosting providers maintain servers all over the world. Because of this, your information may be processed on servers located in a country other than where you live. Wherever we process your data, we do so in compliance with this Privacy Policy. When we receive formal written complaints about data, we take the following steps:We contact the person who made the complaint. We attempt to work with the owner of the data.If we cannot resolve complaints directly, we work with the appropriate legal and regulatory authorities to resolve any complaints.

CCPA (CALIFORNIA) REQUIREMENTS

The California Consumer Privacy Act (CCPA) requires specific disclosures for California residents.This Privacy Policy is designed to help you understand how ConnectM handles your information:We explain the categories of information ConnectM collects and the sources of that information in the section of this Privacy Policy entitled, “Information ConnectM Collects.”We explain we use information in the section entitled, “Why ConnectM Collects Data.”We explain when we might share your information in the section entitled, “Sharing Your Information.”ConnectM does not sell your personal information.The CCPA also gives you the rights to:Request information about how we collect, use, and disclose your personal information,Access your information,Request that we delete your information, and not be discriminated against for exercising your privacy rights.If you have questions or requests related to your rights under the CCPA, you (or your authorized agent) can also contact us as provided above.The CCPA requires a description of data practices using specific categories. The list below uses these categories to organize the information in this Privacy Policy.

Categories of Personal Information We May Collect

Identifiers such as your name, phone number, email address and mailing address, as well as data tags tied to the browser, application, or device you are using.Demographic information, such as your age, gender and language.Commercial information such as your payment information and a history of purchases you make on the Platform or our websites.Equipment information such as the location, type, make, model, and serial number of Equipment that you remotely monitor and control using the Platform.Geolocation data, such as may be determined by GPS, IP address, and other data from sensors on or around your Device or your ConnectM Hardware, depending in part on your Device and account settings. You can disable this by changing the permissions on your Device. Inferences drawn from the above.

Business Purposes for Which Information May Be Used or Disclosed

Protecting against security threats, abuse, and illegal activityConnectM uses and may disclose information to detect, prevent and respond to security incidents and for protecting against other malicious, deceptive, fraudulent, or illegal activity. For example, to protect our services, ConnectM may receive or disclose information about IP addresses that malicious actors have compromised.Providing information to your service providers – We share data about your ConnectM Hardware and Equipment to the service providers and vendors of your Equipment. For example, we collect this information when your ConnectM Hardware contacts our servers or when our servers contact your ConnectM Hardware — for example, when you identify a new piece of ConnectM Hardware and/or Equipment on our Platform or you monitor or control your Equipment with our Platform.Auditing and measurementConnectM uses information for analytics and measurement to understand how our Platform and services are used, as well as to fulfill obligations to our partners. We may disclose anonymized information publicly and with these partners, including for auditing purposes.Research and developmentConnectM uses information to improve our services and to develop new products, features and technologies that benefit our users. Use of service providers ConnectM shares information with service providers to perform services on our behalf, in compliance with our Privacy Policy and other appropriate confidentiality and security measures. For example, we may allow service providers to process payments using your payment information.Advertising ConnectM may process information, including online identifiers and information about your interactions with advertisements, to provide advertising.Legal reasons ConnectM may also use information to satisfy applicable laws, rules or governmental regulations, and discloses information in response to legal process or enforceable government requests, including to law enforcement.

Parties with Whom Information May Be Shared

Third parties to whom you consent to sharing your information, such as services that integrate with ConnectM’s services. You can review and manage third party applications and sites who have access to data in your ConnectM account.Service providers, trusted businesses or persons that process information on ConnectM’s behalf, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.Law enforcement or other third parties, for the legal reasons described in the section entitled, “Sharing Your Information.”

ABOUT THIS POLICY
When This Policy Applies

This Privacy Policy applies to all of the services offered by ConnectM and its affiliates, including without limitation the use of the Platform and our websites. This Privacy Policy does not apply to services that have separate privacy policies that do not incorporate this Privacy Policy.This Privacy Policy does not apply to:The information practices of other companies and organizations that advertise our services.Services offered by other companies or individuals, including products or sites that may include ConnectM services or third-party services for which links may be provided in our applications and websites.

Changes to This Policy

We may change this Privacy Policy from time to time. We always indicate the date the last changes were published, and we offer access to archived versions for your review. If changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

Key termsApp Cache

An application data cache is a data repository on a device. It can, for example, enable a web application to run without an internet connection and improve the performance of the application by enabling faster loading of content.

Cookies

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.

Data Tags

A data tag is a string of characters that can be used to uniquely identify a browser, application, or device. Different identifiers vary in how permanent they are, whether they can be reset by users, and how they can be accessed.Data tags can be used for various purposes, including security and fraud detection, syncing services such as your email inbox, remembering your preferences, and providing personalized advertising. For example, data tags stored in cookies help sites display content in your browser in your preferred language. You can configure your browser to refuse all or certain types of cookies or to indicate when a cookie is being sent. On other platforms besides browsers, data tags are used to recognize a specific device or application on that device. For example, a data tag such as the Advertising ID is used to provide relevant advertising on Android devices and can be managed in your device’s settings. Data tags may also be incorporated into a device by its manufacturer (sometimes called a universally unique ID or UUID), such as the IMEI-number of a smartphone. For example, a device’s data tag can be used to customize our service to your device or analyze device issues related to our services.

Device

A device is a computer that can be used to access the ConnectM Platform or services. For example, desktop computers, laptop computers, tablets, and smartphones are all considered devices.

Equipment

Equipment includes any hardware and smart devices that you might use the ConnectM applications to remotely monitor and control, such as heating, ventilation and air-conditioning systems, water heaters and other similar mechanical and electro-mechanical systems.

IP address

Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.

Non-Personally Identifiable Information

This is information that is recorded about users so that it no longer reflects or references an individually identifiable user.

Personal Information

This is information that you provide to us which personally identifies you, such as your name, email address, or billing information, or other data that can be reasonably linked to such information by ConnectM, such as information we associate with your ConnectM account.

Pixel Tag

A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking certain activity, such as views of a website or when an email is opened. Pixel tags are often used in combination with cookies.

Referrer URL

A Referrer URL (Uniform Resource Locator) is information transmitted to a destination webpage by a web browser, typically when you click a link to that page. The Referrer URL contains the URL of the last webpage the browser visited.

ConnectM Account

You may access some of our services by downloading our applications and signing up for a ConnectM account and providing us with some personal information (typically your name, email address, and a password, but you may, at your election, also provide your mailing address and geo-location). This account information is used to authenticate you when you access the Platform and other ConnectM services and to protect your account from unauthorized access by others. You can edit or delete your account at any time through your ConnectM account settings.

Sensitive Personal Information

This is a particular category of personal information relating to topics such as confidential medical facts, racial or ethnic origins, political or religious beliefs, or sexuality.

Server Logs

Like most websites, our servers automatically record the page requests made when you visit our sites. These “server logs” typically include your web request, Internet Protocol address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser.

Web Storage

Web Storage enables websites to store data in a browser on a device. When used in “local storage” mode, it enables data to be stored across sessions. This makes data retrievable even after a browser has been closed and reopened. One technology that facilitates web storage is HTML 5.

[End of Privacy Policy]
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