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    PRIVACY POLICY

    PRIVACY POLICY AS UPDATED ON 07/31/2026. Smart Spray is a leading provider of advanced chemical-tracking hardware and software for the lawn care, pest control, and snow removal industries. Our precision spray hardware products, including the LP100, LP100 Pro, LPM100, LR100, and any other hardware products, accessories, peripherals, replacements, upgrades, or related equipment that we may manufacture, distribute, or offer from time to time (collectively, the "Products"), together with our cloud-based Smart Spray dashboard, software, mobile applications, and related services, enable business owners and technicians to obtain real-time, location-verified visibility into where, when, and how much chemical is applied across every truck, technician, and property in a fleet. We respect your privacy and care about how your Personal Information is used. This Privacy Policy (the “Policy”) outlines how Smart Spray Technologies, LLC. (“Company” or “Smart Spray” "us" or "we" or "our") including our affiliates collect, use, store, process, transfer, and disclose your information through our Website https://smartspray.io/ (“Website”), our Software, our Services, and any of our other websites, mobile or digital applications, or any other services we offer from time to time by or in connection therewith (the “Platform” )... This Policy describes how we collect, use, store, process, transfer, and disclose your information through our Website, our customer sign-in portal (app.smartspray.io), our Smart Spray hardware devices, our cloud software and dashboard, our mobile applications, and any other services we offer from time to time in connection therewith. By reviewing this Policy, you will gain a comprehensive understanding of your privacy rights and choices. Your access to or use of our Platform and/or Services implies your agreement to be governed by this Policy. By providing us with your Personal Information, you expressly consent to the use and disclosure of your Personal Information as outlined in this Policy. This Policy, along with our Terms of Use, is applicable to your use of the Services, and you agree to read this Policy in conjunction with our Terms of Use

    Your privacy matters to us, so please do take the time to get to know and familiarize yourself with our policies and practices. Please understand that we reserve the right to change any of our policies and practices at any time, but you can always find the latest version of this Privacy Policy here on this page. The terms “Users,” “you,” or “your” mean any natural or legal person who accesses or uses the Platform or Services, including business owners, account administrators, managers, and field technicians who are provisioned with login access to the Smart Spray dashboard or mobile application, depending on the context in which the Platform or Services are accessed or used. Any Personal Information relating to a manager or technician using a customer's account is processed strictly in connection with that customer's use of the Services and in accordance with the customer's instructions. By visiting the Platform or providing your information, you acknowledge that we operate in, and this Policy is designed to comply with the privacy laws applicable to, the United States and Canada, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”), other applicable U.S. state privacy laws, and Canada's Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial private-sector privacy legislation (collectively, “Data Protection Laws”). IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS PRIVACY POLICY, PLEASE REFRAIN FROM ACCESSING AND/OR USING OUR PLATFORM.

    1. TO WHOM DOES THIS POLICY APPLY? 1.1. This Policy applies to all Users of our Platform and/or Services, irrespective of their browsing intent or their extent of using the Services offered on our Platform. 1.2. The applicability of this Policy extends to Users regardless of the device type used for accessing our Platform and/or Services, whether it be a laptop/desktop, a mobile/tablet device, or a Smart Spray hardware unit installed on a vehicle or handheld sprayer. 1.3. Pursuant to the “Are Children Allowed to Use Our Platform?” section below, we do not knowingly collect or solicit Personal Information from anyone under the age of eighteen (18) or knowingly allow minors to register for or use the Services. If you are under the age of eighteen (18), please do not attempt to register for the Services or send any information about yourself to us.
    2. WHAT PERSONAL INFORMATION WE COLLECT? 2.1. To access and use our Platform, Website or Services, you are provisioned with your own customized subdomain. The Users are required to provide the following information to the Company at the time of setting up their Account or at different instances, including, without limitation: 2.1.1. Basic Information: This will include full name, business addresses, phone number, email id and professional roles or designations. 2.1.2. Verification Data: We implement verification and security measures at the time of Account creation and login, including One-Time Password (OTP) verification and Two-Factor Authentication (2FA), and may collect related information such as verification emails, internal authentication tokens, or OTPs solely to validate user identity, Account access, and system login. 2.1.3. Communication with Us: Any communications sent to us, including emails, support requests, onboarding discussions, or security notifications. 2.1.4. Payment and Financial Information: Although transactions are not processed through the Platform, we may receive limited payment-related information, such as billing addresses, bank account details, or other invoicing particulars, through offline or external channels, solely for invoicing, billing, or contract fulfillment; 2.1.5. Device and Technical Information: This includes information that may assist us in identifying your device, including browser type and version, session logs, IP address, login timestamps, and software usage patterns, etc.; 2.1.6. Administrative and Configuration Activity Data: This includes logs and records relating to administrative actions performed on the Platform, such as creation, modification, or deletion of User Content, configuration of access controls, permissions, integrations, subscription settings, and security-related changes. 2.1.7. Interaction and AI Agent Configuration Data: This includes prompts, commands, or inputs provided by you to configure or interact with Platform, including text, documents, preferences, workflow settings, AI-generated outputs, and any other content you voluntarily contribute while using the Platform as well as information collected, generated, or inferred through the Platform’s Agentic AI systems during or after live meetings, interactions, or engagements, and from recordings, summaries, artifacts, or outputs generated during or after such meetings; 2.1.8. Additional Information: It includes, without limitation, when you voluntarily provide during participation in feedback surveys, product demos, webinars, support queries, or beta-testing initiatives. 2.1.9. Other Data: This can include the following, based on your interaction with the Platform and/or Services- 2.1.9.1. Number of times you access our Platform and/or Services; 2.1.9.2. The length of time you spent on the Platform; 2.1.9.3. Your engagement patterns, including the time when you became active and have continued to be active on the Platform; 2.1.9.4. In-Platform actions and interactions; 2.1.9.5. Other similar statistics we may collect with the intention of improving the user experience of the Platform. 2.2. You agree to provide us with your Personal Information whenever you use our Services by performing any of the following functions: 2.2.1. Accessing our Platform and/or Services by means of any web browser or any device; 2.2.2. Signing in and registering for our Services; 2.2.3. Inquiring about our Services through our Platform; 2.2.4. Initiating and maintaining correspondence with us. 2.2.5. Interacting with our platform, which includes inputting data, receiving outputs, and engaging with personalized recommendations and insights. 2.3. You understand and agree that all Personal Information, sensitive or otherwise, collected through our Platform is provided solely by the User. We do not collect any personal or sensitive information without the User’s explicit input and consent. Users are responsible for the accuracy and completeness of the information they provide. 2.4. We strive to take additional precautions to ensure that such Personal Information is kept secure and confidential, and we retain this data only for as long as is necessary to fulfil the purposes for which it is collected, in accordance with applicable laws. The Company stores and uses all Personal Information solely for the purpose of providing the Services and does not use such Personal Information for any unrelated or commercial activities without your additional, explicit consent. 2.5. Further, you understand and acknowledge that, to operate and provide the Platform and Services, we utilize certain trusted third-party service providers as mentioned in Section 5. While we manage your Personal Information in accordance with this Policy, certain data may be processed by these third-party service providers solely for the purpose of enabling the Services. By using our Platform and Services, you acknowledge that you are bound by the terms and policies of our third-party service providers. We prioritize user privacy and security by relying on trusted third-party service providers, and we encourage Users to review and understand the policies of these platforms to protect their interests. 2.6. This Policy will not apply to any unsolicited information provided by you through the Platform or through any other means. This includes but is not limited to information posted on any public areas of the Platform and other social media. All such unsolicited information shall be deemed to be non-confidential, and we will be free to use and disclose such unsolicited information without limitation. 2.7. We shall not be liable for any loss or damage sustained by you as a result of any disclosure (inadvertent or otherwise) of payment-related information shared by you through offline or external invoicing and billing processes, including invoices raised through third-party accounting or payment service providers. For this purpose, you are advized to review the terms of service and privacy policies of such third-party service providers, as the handling of payment-related information by them is governed by their respective policies. 2.8. Access to your Personal Information is limited to employees, agents, partners, and third parties, who we reasonably believe will need that information to enable us to provide Services to you. However, we are not responsible for the confidentiality, security, or distribution of your own Personal Information by our partners and third parties (who have their own privacy policies) outside the scope of our agreement with such partners and third parties. 2.9. When you use our Platform, we collect and store your information, which is provided by you from time to time. In general, you can browse the Platform without telling us who you are or revealing any Personal Information about yourself. Once you give us your Personal Information, you are not anonymous to us. Where possible, we indicate which fields are required and which are optional. You always have the option to not provide information by choosing not to use a particular service, product, or feature on the Platform.
    3. HOW DO WE COLLECT THE INFORMATION? 3.1. We employ various methods to gather information, ensuring a comprehensive and accurate record of application activity and account usage. The collection of Personal Information is facilitated through the following processes: 3.2. Information You Give Us: When you or your technicians provide us with the information referred to in the “What Information Do We Collect From You?” section above, such as when you create an account, register a device, or contact support. 3.3. Smart Spray Hardware Collection: Our LP100, LP100 Pro, LPM100, and LR100 hardware devices automatically collect geolocation, application-rate, and job data as technicians perform work in the field. This includes the technician's walking path and spray swath, comparisons against geofenced property boundaries, and the timestamped records used to generate a property's “Verification Map.” This data is transmitted from the hardware to the Smart Spray cloud software for processing, mapping, and discrepancy detection. 3.4. Dashboard and Session Analytics: We study session metrics to understand how Users interact with the Smart Spray dashboard and website. This helps us learn how account administrators and managers review discrepancy alerts, coverage maps, and reports. We may use analytics tools to collect anonymized data, including number of views, session duration, and navigation patterns, which allows us to optimize the user experience. 3.5. Log Files: Our servers automatically collect certain technical information transmitted by your browser or device when you access the Platform, commonly referred to as log files. This information may include IP addresses, browser type, operating system, date and time of access, and requested pages. Log files are used for security monitoring, analysing usage trends, administering the Platform, and diagnosing technical issues. 3.6. Cookies and Similar Technologies: We utilize cookies and similar tracking technologies, described further in the “Cookies” section below, to recognize you as a customer, remember preferences, and analyse usage of the website and dashboard. 3.7. Information From Other Sources: We may collect Personal Information from other sources, including: (i) if a User or third party submits a complaint about you, information relating to that complaint; and (ii) to the extent permitted by applicable law, information from third-party service providers, payment processors, or resellers who help set up or support your account, which we may combine with information we already have about you.

    3.8. Accuracy and retention of Personal Information: We take reasonable and practicable steps to ensure that your Personal Information held by us is (i) accurate with regard to the purposes for which it is to be used, and (ii) not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.In determining the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Information, the purposes for which we process it, whether we can achieve those purposes through other means, and any applicable legal, accounting, or reporting requirements. By default, account and operational data is retained for up to five (5) years from the date of last active use or account termination, unless a shorter period is requested by the customer or a longer period is required by law. When Personal Information is no longer needed, we securely delete, destroy, or de-identify it. 4. HOW WE USE YOUR PERSONAL INFORMATION 4.1. We collect Personal Information about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Information to: 4.1.1. Provide you with our Services. We use your Personal Information to provide you with our Services pursuant to the terms of our Terms of Use. For example, in order to facilitate fiat transfers out of your account, we need to know your financial information 4.1.2. Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations. 4.1.3. Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account. 4.1.4. Protect the security and integrity of our Services. We use your Personal Information, including information about your device and your activity on Smart Spray to maintain the security of your account and the Smart Spray platform. Provide you with customer support. We process your Personal Information when you contact our support team with questions about or issues with your account. 4.1.5. Market our products. We may contact you with information about our Services. We will only do so with your permission, which can be revoked at any time. 4.1.6. Other business purposes. We may use your Personal Information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent. 4.1.7. California Privacy Rights: To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the Personal Information we collect:

    The right to know what Personal Information we have collected and how we have used and disclosed that Personal Information; The right to request deletion of your Personal Information; and The right to be free from discrimination relating to the exercise of any of your privacy rights. Exercising Your Rights: California residents can exercise the above privacy rights by emailing us at: hello@smartspray.io Verification: in order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information. Authorized Agents: you may submit a request to know or a request to delete your Personal Information through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.

    1. HOW WE SHARE YOUR PERSONAL INFORMATION? 5.1. We will not share your Personal Information with third parties, except as described below: 5.1.1. Service Providers. We may share your Personal Information with third-party service providers for business or commercial purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising and marketing, network infrastructure, storage, transaction monitoring. We share your Personal Information with these service providers only so that they can provide us with the services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose.These service providers are contractually obligated to process such data solely for the purpose of providing their services to us and in compliance with applicable Data Protection Laws. The table below identifies the categories of service providers we currently rely on:

    No. Category of Service Provider Purpose / Function Example

    1. Cloud hosting & storage Hosting the Smart Spray dashboard, databases, and hardware data pipelines Amazon Web Services
    2. Payment processing Billing and subscription payment processing Third-party payment processor
    3. Mapping & geolocation services Rendering coverage maps, geofence boundaries, and Verification Maps Mapping API provider
    4. Communications & notifications Sending discrepancy alerts, OTPs, and account notifications via email/SMS Email/SMS delivery provider
    5. Analytics Understanding dashboard and website usage to improve the Services Web analytics provider
    6. Customer support tooling Managing and responding to support tickets Helpdesk software provider
    7. IT security & fraud monitoring Detecting and preventing fraud, unauthorized access, and abuse Security monitoring provider 5.1.2. Payment Processors. You authorize us to collect and share with our payments provider your Personal Information including full name, email address and financial information, and you are responsible for the accuracy and completeness of that data. Your Personal Information collected by the payment processor will be subject to their Privacy Policy 5.1.3. Law Enforcement. We may be compelled to share your Personal Information with law enforcement, government officials, and regulators 5.1.4. Corporate Transactions We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
      5.1.5. Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations. 5.1.6. Consent. We may share your Personal Information with your consent If we decide to modify the purpose for which your Personal Information is collected and used, we will amend this Privacy Policy.
    8. COOKIES When you access Smart Spray, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit Smart Spray. We use Cookies to help us recognize you as a customer, collect information about your use of Smart Spray to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities; (ii) assess and improve our services and advertising campaigns. 6.1.1. You also can learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note that if you reject cookies, you will not be able to use some or all of Smart Spray If you do not consent to the placing of Cookies on your device, please do not visit, access, or use Smart Spray. 6.1.2. Direct Marketing: Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from or about you. You may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy to not provide your Personal Information for those third parties’ direct marketing purposes without your consent. 6.1.3. Information Security: No security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect Smart Spray and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take include encryption of the Smart Spray website communications with SSL; optional two-factor authentication; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. 6.1.4. Information For Persons Subject to EU Data Protection Law: While customers who are located in the European Union (“EU”), European Economic Area (“EEA”) or the Channel Islands, or other locations subject to EU data protection law (collectively, “Europe”) are customers of our US entity, we recognize and, to the extent applicable to us, adhere to relevant EU data protection laws. For purposes of this section, “personal data” has the meaning provided in the General Data Protection Regulation (EU) 2016/679 (“GDPR”). 6.1.5. Lawful bases for processing: We process personal data subject to GDPR on one or more of the following legal bases: 6.1.5.1. Legal Obligation: to conduct anti-fraud and to fulfill our retention and other legal obligations; 6.1.5.2. Contractual Obligation: to satisfy our obligations to you under our Terms of Use, including to provide you with our Services and customer support services, and to optimize and enhance Smart Spray; 6.1.5.3. Legitimate Interest: to monitor the usage of Smart Spray, conduct automated and manual security checks of our Services, to protect our rights; and 6.1.5.4. Consent: to market Smart Spray and our Services. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before consent is withdrawn 6.1.5.5. European privacy rights: European residents have the following rights under GDPR, subject to certain exceptions provided under the law, with respect to their personal data:

    6.1.6. Rights to Access and Rectification. You may submit a request that Smart Spray disclose the personal data that we process about you and correct any inaccurate personal data. 6.1.7. Right to Erasure. You may submit a request that Smart Spray delete the personal data that we have about you. Right to Restriction of Processing. You have the right to restrict or object to our processing of your personal data under certain circumstances. 6.1.8. Right to Data Portability. You have the right to receive the personal data you have provided to us in an electronic format and to transmit that personal data to another data controller. To submit a request to exercise these rights please contact us using the methods described at the end of this Privacy Policy. When handling requests to exercise European privacy rights, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request. 6.1.9. Collection and transfer of data outside the EEA: Smart Spray operates with many of our systems based in the United States. As a result, we may transfer personal data from Europe to third countries outside of Europe, including the United States, under the following conditions: 6.1.9.1. Contractual Obligation Where transfers are necessary to satisfy our obligation to you under our Terms of Use, including to provide you with our Services and customer support services, and to optimize and enhance Smart Spray; and 6.1.9.2. Consent: where you have consented to the transfer of your personal data to a third country. Where transfers to a third country are based on your consent, you may withdraw your consent at any time. Please understand, however, that our services may not be available if we are unable to transfer personal data to third countries. 6.1.9.3. When we transfer personal data to third countries, we endeavor to ensure adequate safeguards are implemented, for example through the use of standard contractual clauses or Privacy Shield certification. 6.1.9.4. Automated decision-making: We may engage in automated decision-making for purposes of fraud detection and prevention. 7. INFORMATION FOR CANADIAN RESIDENTS 7.1. We are committed to complying with Canada's federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and, where applicable, substantially similar provincial private-sector privacy legislation (including Quebec's Act Respecting the Protection of Personal Information in the Private Sector, as amended by Law 25). This section supplements the rest of this Policy for residents of Canada; a fuller description of your rights is set out in Schedule II to this Policy. 7.2. Consent. We collect, use, and disclose your Personal Information only with your knowledge and consent, except where otherwise permitted or required by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. 7.3. Access and Correction. You have the right to request access to the Personal Information we hold about you and to request that we correct any inaccurate or incomplete Personal Information. 7.4. Cross-Border Storage and Processing. Your Personal Information may be stored or processed on servers located outside of Canada, including in the United States, and may therefore be subject to the laws of those jurisdictions. Accountability. We have designated a Privacy Officer who is responsible for our compliance with PIPEDA and applicable provincial privacy laws. 7.5. Complaints. If you believe we have not complied with this Policy or applicable Canadian privacy law, you may submit a complaint to us using the contact details below, or to the Office of the Privacy Commissioner of Canada. 8. WHO IS THE DATA CONTROLLER AND DATA PROCESSOR OF YOUR PERSONAL INFORMATION? 8.1. Smart Spray acts as the Data Controller (or “business” under the CCPA) where we determine how and why your Personal Information is used in connection with the Platform or our Services, such as account and billing information. 8.2. Smart Spray acts as a Data Processor (or “service provider” under the CCPA) where we process operational and field data solely on behalf of, and pursuant to the instructions of, the customer whose technicians generate that data using Smart Spray hardware. 8.3. The service providers identified in the “Who Do We Share Your Personal Information With and Why?” section above act as our sub-processors. They are contractually required to use Personal Information only as instructed by us, to maintain appropriate safeguards, and not to use Personal Information for their own independent purposes. 9. ARE CHILDREN ALLOWED TO USE OUR PLATFORM? 9.1. This Platform is strictly prohibited for use by individuals under the age of eighteen (18) years or the age of majority as defined by the applicable laws of their country of residence. Specifically, individuals under the age of sixteen (16) residing in European Union (EU) countries and those under thirteen (13) years old in the United States or United Kingdom are also restricted from accessing our Platform and Services (collectively referred to as “Minors”) Accessing or using the Platform by Minors constitutes a violation of our Terms of Service and Privacy Policy. 9.2. We do not knowingly collect, solicit, or process any Personal Information from Minors. We implement commercially reasonable age verification measures and data protection practices to prevent such unauthorized collection and usage. 9.3. If you are a parent or legal guardian ("Guardian") and believe your child has provided us with Personal Information, we urge you to promptly contact us at hello@smartspray.io. Upon verification, we will promptly take steps to remove and delete such information from our records. 10. HOW CAN YOU EXPRESS YOUR COMPLAINTS AND CONCERNS? 10.1. Customer satisfaction is central to our business, and we are committed to resolving privacy-related questions and concerns promptly and fairly. If you have a complaint or concern regarding our handling of your Personal Information, please contact us using the details in the “How Can You Contact Us” section below. We will acknowledge your complaint, investigate it, and respond to you within a reasonable time. 10.2. If you are not satisfied with our response, U.S. residents may contact their state Attorney General's office or the Federal Trade Commission, and Canadian residents may contact the Office of the Privacy Commissioner of Canada, as further described in the Schedules to this Policy. 10.3. Please also be aware that we will never ask you to share your OTP, PIN, card number, or bank account details through unsolicited calls, texts, or emails. If you receive a suspicious request purporting to be from Smart Spray, please do not respond and report it to us at hello@smartspray.io. 11. CHANGES TO THIS POLICY 11.1. Your privacy matters to us, so please do take the time to get to know and familiarize yourself with our policies and practices. Please understand that we reserve the right to change any of our policies and practices at any time, or as required by changes in applicable law,, but you can always find the latest version of this Privacy Policy here on this page. 11.2. Unless otherwise stated, changes are effective upon posting to the Platform. Your continued access to or use of the Platform and/or Services after such changes constitutes your acceptance of the revised Policy. Where required by applicable law, we will provide additional notice of material changes, such as by email. 12. CONTACT US If you have questions or concerns regarding this policy or our processing of your Personal SMART SPRAY TECHNOLOGIES, LLC., Attn: Privacy, 3801 Meadowknolls rd, Marion, IA, 52302, or by email at hello@smartspray.io. We aim to respond to all privacy inquiries within thirty (30) days, or such shorter period as required by applicable Data Protection Laws.

    Schedule I: United States Residents We are dedicated to adhering to the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), and other relevant state privacy regulations. If you are a resident of California, Colorado, Connecticut, Delaware, Iowa, Montana, Nevada, Oregon, Texas, Utah, Vermont, Virginia, or Washington, or you otherwise fall under the protections offered by privacy laws in those states, this Schedule serves as an addition to our primary Privacy Policy, detailing your specific rights and protections. According to the CCPA, "Personal Information" encompasses any data that can identify, relate to, describe, or be reasonably associated with a specific consumer or household. This includes a variety of information types such as names, addresses, and online identifiers, among others. We make every effort to ensure that the Personal Information we gather is precise, relevant, and utilized correctly. You have the right to access, delete, and request disclosures regarding your Personal Information. For any questions or to exercise these rights, please reach out to us using the contact details provided below. A. YOUR PRIVACY RIGHTS: ● Right to access: You can access the information that has been provided by you by reaching out to us at hello@smartspray.io. ● Right to withdraw consent: The consent that you provide for the collection, use, and disclosure of your Personal Information will remain valid until such time it is withdrawn by you in writing. If you withdraw your consent, we will stop processing the relevant Personal Information except to the extent that we have other grounds for processing such Personal Information under applicable laws. We will respond to your request within a reasonable timeframe. You may withdraw your consent at any time by contacting us; and ● Right to Opt-Out: You have the right to opt out of certain processing activities, such as the sale of Personal Information or the use of Personal Information for targeted advertising purposes. Firm will respect your preferences and refrain from such activities upon your request. ● Right to correction: You are responsible for maintaining the accuracy of the information you submit to us, including but not limited to your Contact Information. For any necessary updates or corrections to your Personal Information, Users can easily modify details using the provided Platform functionalities or by reaching out to us at hello@smartspray.io. ● Right of Access and Portability: In some jurisdictions, applicable law may entitle you to request certain copies of your Personal Information or information about how we handle your Personal Information, request copies of Personal Information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider, where technically feasible. ● Right of Erasure: In some jurisdictions, you can request that your Personal Information be deleted. B. DATA CONTROLLER AND PROCESSOR: Under various U.S. privacy laws, including but not limited to the California Consumer Privacy Act (CCPA) and other state-specific regulations, we act as the “Data Controller” as well as “Data Processor” of Personal Information. To ensure compliance, we operate our services in a manner that guarantees: Personal Information is processed fairly, lawfully, and transparently; and it is collected and used only for legitimate and specified purposes. C. APPEAL PROCESS: If you disagree with the Firm's response to your privacy rights request or believe your rights have not been adequately addressed, you have the right to appeal. You can submit your appeal in writing to our Data Protection Officer at hello@smartspray.io with the subject line "Appeal of Privacy Rights Request" D. DATA RETENTION AND DE-IDENTIFICATION: We are committed to retaining Personal Information only for as long as necessary to fulfil the purposes for which it was collected, as outlined in our main Privacy Policy (see Section 6). We may also take measures to de-identify Personal Information in accordance with applicable laws and regulations. E. LODGING A COMPLAINT If you believe your rights have been violated or are dissatisfied with our response, you have the right to lodge a complaint with the federal agencies such as the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB). You may also contact the State Attorney General’s Office of your residential state. These organizations are responsible for handling complaints related to data protection and ensuring compliance with the privacy laws. F. ADDITIONAL INFORMATION: For more detailed information on how we handle your Personal Information, including our data collection practices, security measures, and third-party disclosures, please refer to our main Privacy Policy available. Schedule II - European Union Residents We are committed to ensuring compliance with the European Union General Data Protection Regulation (GDPR). Although our Privacy Policy explains how we meet all of our obligations for United State Users, we also have some Users who are habitually located in the European Union (‘EU Residents’) who have additional rights with respect to their Personal Data. Personal Data is defined as: “Any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier”. The term “Personal Data” should be considered fundamentally interchangeable with the expression “Personal Information” for the purposes of this Privacy Policy. Under the GDPR, we are the “Data Controller” and “Data Processor” of Personal Data. As part of our GDPR compliance, we provide and operate the Platform in a way that ensures: Personal Data (i.e. Personal Information) is processed fairly, lawfully, and in a transparent manner; and collected and processed only for specified and lawful purposes. We ensure that the Personal Data we collect about you is accurate, complete, and used for its intended purpose. You may access, review, correct, and update your Information by contacting us by email at the contact details below. EUROPEAN UNION RESIDENTS In certain circumstances, you have certain rights regarding your Personal Information. A summary of each right and how you can exercise it is detailed below. To exercise any of these rights, please contact us at hello@smartspray.io. Such requests should include information to allow us to verify your identity (e.g. your name, address, email address, or other information reasonably required). Where we receive your request to exercise one of these rights, we will respond without undue delay and within the time required by applicable law. This may be extended in certain circumstances, e.g. where requests are complex or numerous. We will provide the information free of charge, except where requests are manifestly unfounded or excessive, e.g. because of their repetitive character. In these circumstances, we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request. We may ask for additional information to verify your identity before carrying out a request. HOW CAN YOU EXERCISE YOUR RIGHT?

    1. Right to access and/or correct your Personal Data You have the right to access the Personal Data we hold about you, and to be provided with a copy of the information (in most circumstances). You also have the right to correct any information we may hold about you that is inaccurate.
    2. Right to restrict the use of your Personal Data You have the right to ask us to restrict the processing of your Personal Data where one of the following applies: ● The processing is unlawful, but you want us to restrict the use of the data instead of deleting it; ● Where you contest the accuracy of your Personal Data, the restriction will apply until we have verified the accuracy or corrected your Personal Data; ● We no longer require the Personal Data for the purposes of the processing, but are required to keep it in connection with a legal claim; ● You have exercised your right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.
    3. Right to withdraw consent and request deletion of your Personal Data ● You have the right to ask us to delete your Personal Data in most circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal Data is required to comply with a legal obligation or for the establishment, exercise, or defence of legal claims. ● You may object to our use of your Personal Data for marketing purposes, and you can let us know via the provided email address. ● Further, you may also object to the processing of your Personal Data in cases where we have used legitimate interests as the basis for processing. In such cases, we will stop processing your Personal Data until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise, or defence of legal claims.
    4. Data retention and anonymization We are committed to retaining Personal Information only for as long as necessary to fulfil the purposes for which it was collected, as outlined in our main Privacy Policy (see Section 6). We may also take measures to de-identify Personal Information in accordance with applicable laws and regulations.
    5. Right to data portability In most cases, you have the right to receive all Personal Data you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, where technically feasible.
    6. Right to lodge a complaint with a supervisory authority If you are a resident of the EU, you have the right to make a complaint at any time to the regulator in your jurisdiction. To find out how to contact your local regulator, please visit https://edpb.europa.eu/about-edpb/about-edpb/members_en. We will allow and assist Users who are EU Residents to exercise these rights unless we have compelling and legitimate legal grounds not to (e.g. a legal obligation under United Kingdom legislation, or if the Personal Data has been fully anonymized).