Safe Fleet Privacy Policy

PRIVACY POLICY FOR SAFE FLEET’S NORTH AMERICAN BUSINESSES

(Last modified February 13, 2023)

Safe Fleet Privacy

Policy Last modified: February 13, 2023

Introduction

This is the privacy policy (this “Policy”) of Safe Fleet Acquisition Corp. (“SFAC”) and its North American subsidiaries (other than American Van Equipment, LLC (“AmVan”)), which include (but are not limited to) the operations of Specialty Manufacturing, Inc., FleetMind Seon Solutions Inc., Seon System Sales Inc., Seon Design (USA) Corp., COBAN Technologies, Inc., SF Mobile-Vision, Inc., Elkhart Brass Manufacturing Company, LLC, Fire Research Corp. (also d/b/a FoamPro), Roll Rite, LLC (also d/b/a PullTarps Manufacturing), ROM Acquisition Corporation (d/b/a ROM Corporation), IEM, Inc. (d/b/a Prime Design), Randall Manufacturing LLC, Rear View Safety LLC (also d/b/a RVS), American Midwest Manufacturing, Inc. (d/b/a American Midwest Fleet Solutions), Kerr Holdings Delaware, Inc., Kerr Industries of Texas, Inc., Kerr Industries of Michigan, Inc., Crown North America, Inc., Kerr Mexico LLC, and Kerr Industries Limited, as well as SFAC’s MobileView business unit (also d/b/a Safe Fleet Transit Bus & Rail) (SFAC, together with all such North American subsidiaries other than AmVan, collectively, the “Company” or “we” or “us”). Please note that the privacy policy of AmVan may be found at www.americanvan.com/privacy-policy.

We are committed to protecting the privacy of the information you share with us, online and offline, when you inquire or otherwise communicate with or interact with us about, order, purchase, access, register for, participate in, and/or use (any of the foregoing, “Use”) our websites, applications, products, services and/or other offerings (collectively, “Products & Services”). This Policy describes the types of information that we may collect from you or you may provide us when you Use our Products & Services and our practices for collecting, using, maintaining, protecting, and disclosing (collectively, “Managing”) that information. This Policy does not apply to any information collected by any third party not listed herein, including through any such third party’s website or other application, advertising, or other content that may link to or be accessible from or on any of the Products & Services.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. By Using our Products & Services, you agree to this Policy and the way we manage and process your information as defined and described below. In some cases, we may also independently ask you to confirm your knowledge of the terms of this Policy; however, we are not obligated to do so. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued Use of our Products & Services after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates. In addition, this Policy may be supplemented by additional privacy terms or notices disclosed to you in connection with your Use of specific Products & Services.

Children’s Personal Information

Our Products & Services are directed at business professionals and vocational workers in the industries we serve; they are not intended for children under 16 years of age. We do not knowingly collect Personal Information (as defined below) from users in this age group and reserve the right to delete such information if we become aware of having collected, processed or received it without verification of parental/guardian consent.

Information We Collect About You and How We Collect It

In the course of your Use of our Products & Services, we collect or receive from you information (“Your Information”, or “Information”) including: (i) information by which you may be directly or indirectly personally identified (including, for example, name, postal address, e-mail address, telephone number or any other identifier by which you may be contacted online or offline) (“Personal Information”), or (ii) that is about you but by itself does not specifically identify you individually, whether directly or indirectly (including, for example, the company or business that employs you and your professional title, or details of your Internet connection, the equipment you use to access our Products & Services, and related transactional and usage details).

We may collect Your Information, including Personal Information, directly from you when you provide it to us or automatically as you navigate through one of our websites, mobile applications, or other digital or electronic offerings (collectively, “Information Platforms”). Information collected automatically may include usage details, Internet Protocol (IP) addresses, and information collected through cookies, web beacons, and/or other tracking technologies.

In order to offer you a more consistent and personalized experience in your interactions with us, Your Information, including Personal Information collected or processed in connection with one of our Products & Services, may be combined with Your Information and Personal Information collected or processed in connection with our other Products & Services.

We also may receive information about you from external sources that are not affiliated with us (such as public information or information you provided to others with authorizations to share it with third parties) and add that to Your Information separately provided to us via your Use of our Products & Services.

Information You Provide to Us

Your Information and Personal Information may include:

Information that you provide by filling in forms on our Information Platforms when registering for, subscribing to, or otherwise requesting or Using Products & Services, entering into a contest or promotion sponsored by us, or reporting an issue with any of our Information Platforms. • Records and copies of your correspondence (including contact information), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions and activities you carry out through our Information Platforms and of the fulfillment of your orders for Products & Services.
Information that you provide when posting comments, feedback or other content on any of our Information Platforms, where applicable.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Information Platforms, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including, for example:

Details of your visits to and interactions with our Information Platforms, including traffic and location data, activity logs, and other communication and access data.
Information about your computer and Internet connection, including your IP address, operating system, and browser type.

Information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways via our Information Platforms, or otherwise through our offerings of Products & Services to you, such as our registration of participants in webinars or podcasts that we host or sponsor or our collection of attendee information at trade shows. These activities help us (i) improve your experience of certain areas of our websites and other digital applications, including the use of specific functionality like social media page sharing, (ii) improve our Information Platforms and Products & Services offerings, and (iii) otherwise deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Information Platforms and Products & Services according to your individual interests.
Speed up your searches.
Recognize you when you return to our Information Platforms.
Offer you new or other Products & Services that may be of interest to you.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Information Platforms. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the applicable Information Platform.
Flash Cookies. Certain features of some of our Information Platforms may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on that Information Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons. Portions of our Information Platforms and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain content and verifying system and server integrity).

Cookies that we use include (but are not limited to) the following, provided that any addition to or removal from this list does not require updating this Policy:

Google Analytics (including: __utma; __utmb; __utmv; __utmz; and _utmc);
Mouseflow (including: mf_3324fa8f-b066-4fec-917a-9fe9fb2b9efe; and mf_user);
Website cookie acceptance (including: website_cookiesAccepted); • Content Management System cookie (including: exp_last_activity; exp_last_visit; exp_perpage; exp_tracker; exp_sessionid; exp_expiration; and exp_flash); • Get Clicky (including: _jsuid; and first_pv_66399447); and
Third Party Cookies (including: _hstc; and _hssc).

Please note that you may delete and block all cookies from any of our websites, but as a result, parts of such website may not work as intended. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Third-Party Use of Cookies and Other Tracking Technologies

From time to time, we may sponsor webinars, podcasts or other offerings that are hosted by third parties (“Third-Party Offerings”), who serve the related content or applications, including advertisements, to the participants in those Third-Party Offerings. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect Information about you when you participate in or otherwise Use these Third-Party Offerings. The Information they collect may include your Personal Information or they may collect Information, including Personal Information, about your online activities over time and across different online services. They may use this Information to provide you with interest based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use Your Information, including any Personal Information:

To create, maintain, customize, and secure your account with us.
To provide you with Products & Services, access to and interaction with our Information Platforms, and information, content, and business opportunities that you have requested from us or that we think may be of interest to you. You may be required to provide identifying government registration numbers and/or financial information before placing an order, which we may use to complete credit approvals and/or comply with record-keeping requirements in connection with your orders.
To process your requests, purchases, transactions, and payments, and to fulfill any other purpose for which you provide the Information.
To help maintain the safety, security, and integrity of our Information Platforms, Products & Services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Information Platforms and Products & Services.
To notify you about changes to our Products & Services or our Information Platforms and/or ask for your input to help our research about them.
To send you account-related notices or respond to your requests, inquiries, comments, or concerns.
To fulfill our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To comply with applicable laws, rules, regulations, court orders or other legal, governmental or administrative process (collectively, “Legal Requirements”), including to respond to any government, regulatory or other law enforcement request, or to defend against legal claims.
In any other way that we may disclose when you provide us with the Information.
Whenever required or allowed by applicable law.

If you do not want (or no longer want) us to use Your Information to contact you about Products & Services that may be of interest to you, you may use one of the opt-out methods described below under Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our customers and other users, and information that does not identify any individual, without restriction.

We may disclose Your Information (including Personal Information which, as described in this Policy, we collect or you provide to us):

To our subsidiaries and other affiliates.
To contractors, service providers, and other third parties we use to provide Products & Services and support our business.
To comply with Legal Requirements, including to respond to any government, regulatory or other law enforcement request, or to defend against legal claims.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding.
To enforce our legal rights between us and you, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us or our affiliates, our customers, or others. (This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.)
To fulfill the purpose for which you provide the information.
For any other purpose disclosed by us when you provide the information.
Whenever required or allowed by applicable law.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of our web-based services may then be inaccessible or not function properly.
Promotional Offers from the Company. If you do not (or no longer) wish to have your contact information used by the Company to promote our Products & Services, you can opt out at any time by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may click the “Unsubscribe” link included in that email to be omitted from future email distributions. Your opt-out by either of these methods does not apply to Information provided to the Company as a result of your purchase, warranty registration, or other Use of any Products & Services or other transactions.

California residents may have additional Personal Information rights and choices. Please see Your California Privacy Rights section for more information. Nevada residents who wish to exercise their sale opt-out rights under

Nevada Revised Statutes Chapter 603A may send us an email stating your request to [email protected]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Information Security

We have implemented a variety of technical, physical, and administrative measures designed to secure your Personal Information and to protect it from accidental loss and unauthorized access, use, alteration, destruction and disclosure. However, due to the design of the Internet and other online and wireless technology systems and other factors outside our control, we cannot guarantee that communications between you and our servers or other systems will be free from unauthorized access by third parties or by government entities. The safety and security of Your Information also depends on you. You remain responsible for protecting your user name and passwords and for the security of information in transit to us over these systems. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures implemented in connection with our Information Platforms and Products & Services.

Changes to Our Privacy Policy

It is our policy to post any changes we make to this Policy on this page. The date this Policy was last revised is identified at the top of the first page of this Policy. You are responsible for periodically reviewing this Policy to stay informed about its contents. Your continued Use of our Products & Services after we make changes is deemed to be acceptance of those changes.

Your California Privacy Rights

Additionally, this section of the Policy (titled “Your California Privacy Rights”) (this “California Section” of the Policy) applies solely to all visitors, users, and other individuals who reside in the State of California (collectively, as used in this California Section, “consumers” or “you”).

If you are a California resident, California law, in particular the California Consumer Privacy Act of 2018, as amended (the “CCPA”), may provide you with additional rights regarding our Use of your Personal Information. We have adopted this section to comply with the requirements set forth by the CCPA, and any terms defined in the CCPA have the same meaning when used in this section of the Policy.

Information We Collect

The description of Information We Collect is included in the section of this Policy titled “Information We Collect About You and How We Collect It.”

In this California Section, Personal Information does not include:

Publicly available information from government records;
Deidentified or aggregated consumer information; and
Information excluded from the CCPA’s scope.

In particular, we have collected the following categories of Personal Information within the last 12 months:

Category Examples Collected

Personal Information Category	Business Purpose Disclosures
A: Identifiers.	Service providers / operating systems and platforms, but only in the course of providing you with Products and Services.
B. California Customer Records Personal Information categories.	Service providers / operating systems and platforms, but only in the course of providing you with Products and Services.
C: Protected classification characteristics under California or federal law.	Service providers / operating systems and platforms, but only in the course of providing you with Products and Services.
D: Commercial information.	Service providers / operating systems and platforms; and internet cookie data recipients, like Google Analytics, but in each case only in the course of providing you with Products and Services.
E: Biometric information.	Not applicable.
F: Internet or other similar network activity.	Internet service providers; operating systems and platforms; and internet cookie data recipients, like Google Analytics, but in each case only in the course of providing you with Products and Services.
G: Geolocation data	Service providers / operating systems and platforms, but only in the course of providing you with Products and Services.
H: Sensory data	Not applicable.
I: Professional or employment-related information.	Service providers / operating systems and platforms, but only job title when provided by you and only in the course of providing you with Products and Services.
J: Non-public education information.	Not applicable.
K: Inferences drawn from other Personal Information.	Service providers / operating systems and platforms, but only in the course of providing you with Products and Services.

CCPA Right to Delete

Under the CCPA, you have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or any of our service providers to:

Complete the transaction for which we collected the Personal Information, provide any Products & Services that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with applicable Legal Requirements, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another party to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with customer or user expectations based on your relationship with us.
Comply with any legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete from (or de-identify in) our records your Personal Information not subject to one of the above exceptions and will direct our service providers to take similar action.

Exercising Your CCPA Rights to Know or Delete

To exercise your rights to know or delete described above (a “CCPA Request”), send us an email at [email protected] specifically stating the request or requests being made. Please note that you may submit a right-to-know request only twice within any 12-month period.

You may designate someone else to make a CCPA Request on your behalf, but to protect your information, we will ask for a signed permission from you authorizing the other person to do so. We will contact you to verify your identity before we respond to your authorized agent’s request.

Your CCPA Request must:

Provide sufficient information to allow us to reasonably verify that the requestor is either (i) you (i.e., the person about whom we collected the Personal Information at issue) or (ii) your authorized agent.
Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it. We cannot respond to your CCPA Request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will use Personal Information provided in the CCPA Request only to verify the requestor’s identity or authority to make the request.

Right to Request Accessible Alternative Format

If you need to access this Policy in an alternative format due to having a disability, please send us an email to that effect at [email protected].

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

Processing Personal Information According to the GDPR

Additionally, if the processing of your Personal Information falls within the scope of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (the “GDPR”), then such processing will also be performed in accordance with GDPR requirements. Therefore, in addition to the above terms, we provide you with the following information:

(a) The contact information for the Company Data Privacy Officer is provided in the “Contact Information” section of this Policy, below;

(b) Personal Information is processed only for the express purposes set forth in this Policy;

(c) Personal Information may be transferred to processors located around the world, and in such a case, we enter into European contractual clauses, or use any other mechanism provided by the GDPR to make such transfer legal;

(d) You are entitled to:

Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it;

Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate Personal Information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information, where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
Object to processing of your Personal Information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

(e) You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

(f) You may at any time lodge a complaint with a supervisory authority located in the European Union having jurisdiction over processing; and

(g) Company does not perform automated decision-making, including profiling.