PRIVACY POLICY

We created this Privacy Policy in order to demonstrate our firm commitment to disclose our current policies regarding privacy and the confidentiality of personal information. In addition, we take further measures to enhance the protection of privacy and personally identifiable information, as outlined in this Privacy Policy. This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. Please contact us via info@revoway.com if you have questions about our privacy practices that are not addressed in this Privacy Policy. This Privacy Policy is incorporated by reference into the Terms and Conditions Agreement made available on the Site. By using the Services, you agree to the terms of this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately stop using the Services. All terms used herein and not specifically defined shall have the meaning ascribed to them in the Terms and Conditions.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Application means the software program and web application provided by the Company which is accessible from the internet or downloaded by You on any electronic device, named www.revoway.com.
• Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Revoway Inc., 17000 Ventura Blvd ste 206, Encino, CA 91316.
• Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
• Personal Data is any information that relates to an identified or identifiable individual. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
• Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to www.revoway.com.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Address, State, ZIP/Postal code, City
• Payment information for credit and/or debit cards
• Above information if another individual overseeing the vehicle

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (i.e., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

This information would be collected to facilitate the Services we provide. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device. Your activity and interaction with our application will be monitored and used by our software to improve the service and machine learning services.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
• Web Beacons. Certain sections of our Service and our emails 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.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies - Type: Session Cookies, Administered by: Us. Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features.
• Cookies Policy / Notice Acceptance Cookies - Type: Persistent Cookies, Administered by: Us. Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
• Functionality Cookies - Type: Persistent Cookies, Administered by: Us. Purpose: These Cookies allow us to remember choices You make when You use the Website.
• Tracking and Performance Cookies - Type: Persistent Cookies, Administered by: Third-Parties. Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To train our software application, your activity on the site will be used to train the software and categorize the difficulty level for other users.
• To manage Your Account to manage Your registration as a user of the Service.
• For the performance of a contract the development, compliance and undertaking of the purchase contract for the services You have purchased.
• To contact You To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication.
• To provide You with news, special offers and general information about other goods, services and events which we offer.
• To manage Your requests To attend and manage Your requests to Us.
• For business transfers We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale.
• For other purposes We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns.

Sharing of Your Personal Information

We may share Your personal information in the following situations:

• With Service Providers We may share Your personal information with Service Providers to monitor and analyze the use of our Service.
• For business transfers We may share or transfer Your personal information in connection with any merger, sale of Company assets, financing, or acquisition.
• With Affiliates We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
• With business partners We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users when You share personal information or otherwise interact in the public areas with other users.
• With Your consent We may disclose Your personal information for any other purpose with Your consent.
• With other third parties to protect us or others We may share information about you with other parties for our business purposes.
• With other parties as permitted or required by law and regulations We may share information about you with other parties if we need to do so to comply with a law, legal process or regulations.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic.

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing. We will not store or collect Your payment card details.

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Us recognize Your Device.

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following categories may be collected:

• Category A: Identifiers - Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name. Collected: Yes.
• Category B: Personal information categories listed in the California Customer Records statute - Name, signature, address, telephone number, financial information. Collected: Yes.
• Category C: Protected classification characteristics - Age, race, color, ancestry, national origin, citizenship. Collected: No.
• Category D: Commercial information - Records and history of products or services purchased or considered. Collected: Yes.
• Category E: Biometric information - Genetic, physiological, behavioral characteristics. Collected: No.
• Category F: Internet or other similar network activity - Interaction with our Service or advertisement. Collected: Yes.
• Category G: Geolocation data - Approximate physical location. Collected: Yes.
• Category H: Sensory data - Audio, electronic, visual, thermal information. Collected: No.
• Category I: Professional or employment-related information - Current or past job history. Collected: No.
• Category J: Non-public education information - Education records. Collected: No.
• Category K: Inferences drawn from other personal information - Profile reflecting preferences, characteristics, behavior. Collected: No.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information:

• The right to notice - You have the right to be notified which categories of Personal Data are being collected.
• The right to request - You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information.
• The right to say no to the sale of Personal Data (opt-out) - You have the right to direct Us to not sell Your personal information.
• The right to delete Personal Data - You have the right to request the deletion of Your Personal Data, subject to certain exceptions.
• The right not to be discriminated against - You have the right not to be discriminated against for exercising any of Your consumer's rights.

Do Not Sell My Personal Information

We do not sell any personal information. Under the CCPA, You have the right to opt-out of the sale of Your personal information.

"Do Not Track" Policy

Our Service does not respond to Do Not Track signals. However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked.

Links to Other Websites

Our Service will not contain links to other websites that are not operated by Us.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us via email: info@revoway.com.