USEFULL INC. PRIVACY POLICY

2. INFORMATION WE COLLECT.  We seek to collect personal information that is reasonably necessary and proportionate to provide, operate, maintain, secure, and improve the Services and for the other purposes described in this Privacy Policy. Depending on how you interact with USEFULL, we may collect the following categories of information:

A.       Account, Contact, and Other Information You Provide.  We may collect information that you provide to us or that is associated with your account, including:

● name;

● email address;

● telephone number;

● account, user, campus card, institutional credential, or other access identifiers;

● information regarding the community, campus, employer, residential property, organization, or other entity through which you access or use the Services or with which your account is associated;

● account preferences and settings;

● information you provide when communicating with us or requesting customer or technical support; and

● other information you voluntarily provide to us.

B. Payment Information.  Payments made through the Services are processed by third-party payment processors. USEFULL does not receive or store complete payment card numbers. We may receive or retain limited payment and transaction information, such as the last four digits and type of a payment card, transaction amount and date, transaction or payment identifiers, and payment status.

C. Service and Container Transaction Information.  When you use the Services to check out, use, or return reusable containers, we may collect information regarding those transactions, including your account or user identifier, the unique identifier associated with the applicable container, the USEFULL location or station at which a container is checked out or returned, the date and time of the transaction, transaction or container status, and related Service usage information.

USEFULL does not collect precise geolocation information from your mobile device or use your mobile device to track your physical location. Information regarding a checkout or return location reflects the USEFULL location or station at which the transaction occurred and is derived from the transaction itself.

D. Communications Information.  When you communicate with us by email, telephone, text message, customer support channel, or other means, we may collect your contact information, the content and date and time of the communication, information you provide in connection with your request, and related delivery or technical information.

E. Information Collected Automatically.  When you access or use the Services, our systems or service providers acting on our behalf may automatically collect technical and usage information, including IP address, browser and operating system, device type and identifiers, application version, dates and times of access, pages, screens, or features accessed, usage information, diagnostic information, error logs, and crash reports.

F. Providing Personal Information. Certain personal information is necessary for USEFULL to establish and administer your account, provide and support the Services, process transactions, communicate with you regarding your use of the Services, maintain security, and comply with applicable legal obligations. If you choose not to provide personal information required for these purposes, some or all of the Services or certain features of the Services may not be available to you.

G. Sources of Personal Information. In addition to information collected directly from you, USEFULL may obtain personal information from service providers acting on our behalf; campuses, employers, residential properties, organizations, and other entities through which the Services are made available to you or with which your account or access credentials are associated; payment processors in connection with transactions; and other third parties where you direct them to share information with us or otherwise authorize such disclosure.

3. PERSONAL INFORMATION IS NOT SOLD.  USEFULL does not sell personal information, share personal information for cross-context behavioral advertising, or make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects concerning an individual.

4. TEXT MESSAGES AND OTHER ELECTRONIC COMMUNICATIONS.  If you provide USEFULL with a telephone number, we may use that number to send transactional or service-related text messages regarding your account or use of the Services. These may include messages concerning account registration or verification, container checkouts and returns, approaching or expired return deadlines, overdue or unreturned containers, fees or charges, account status, security or authentication, customer support, and other information reasonably necessary to provide, administer, or support the Services.

USEFULL does not use text messaging to send marketing or promotional messages.

We and service providers acting on our behalf may process your telephone number, message content and history, delivery and transmission information, timestamps, and related information as reasonably necessary to provide and administer text messaging services.

Your wireless carrier’s standard message and data rates may apply. Message availability and delivery depend on wireless networks and services outside USEFULL’s control.

You may opt out of text messages at any time by replying STOP to any message. If you opt out, you may not receive time-sensitive account or return-deadline reminders, which could result in late fees or other account consequences.

We do not share mobile phone numbers or text messaging consent with third parties or affiliates for their marketing purposes.

5. HOW WE DISCLOSE PERSONAL INFORMATION. We may disclose personal information in the following circumstances:

A. Business and Institutional Customers. Where you access or use the Services through a campus, employer, residential property, organization, or other business or institutional customer of USEFULL, we may disclose personal information relating to your account and use of the Services to that customer or its authorized representatives, including account information, container checkout and return records, transaction locations and times, container status, and related activity, as reasonably necessary to provide and administer the Services, manage user access, support the customer’s operations, and fulfill our contractual obligations to that customer.  Campuses, employers, and other institutional customers are independent of USEFULL, and their use of information they receive is governed by their own policies and practices.

B. Service Providers and Contractors.  We may disclose personal information to vendors, contractors, consultants, and other service providers that process information on our behalf or provide services to USEFULL, including providers of payment processing, cloud hosting and infrastructure, data storage and backup, software development and information technology, email and text messaging, customer support and customer relationship management, authentication and identity management, security and fraud prevention, and analytics and performance monitoring.

We require service providers and contractors that process personal information on our behalf to protect the information and process it for purposes of providing services to us, in accordance with our instructions and agreements, or as otherwise permitted or required by applicable law. Service providers may use subcontractors where permitted by their agreements with us and applicable law.

C. Professional Advisers.  We may disclose personal information to attorneys, accountants, auditors, insurers, financial advisers, consultants, and other professional advisers where reasonably necessary to provide services to us or protect our legal or business interests.

D. Legal Compliance and Protection.  We may disclose personal information where reasonably necessary to comply with applicable law or legal process; respond to governmental authorities, regulators, or law enforcement; investigate or prevent fraud, misuse, security incidents, or unlawful activity; enforce our agreements and policies; establish, exercise, or defend legal claims; or protect the rights, property, safety, or security of USEFULL, our users, or others.

E. Business Transactions.  In connection with an actual or proposed merger, acquisition, financing, investment, reorganization, bankruptcy, sale of assets or equity, change of control, or similar transaction, we may disclose or transfer personal information to actual or prospective purchasers, investors, lenders, financing sources, counterparties, advisers, and other transaction participants, subject to applicable law and appropriate confidentiality protections where applicable.

F. At Your Direction.  We may disclose personal information when you direct or authorize us to do so or request a feature or service that reasonably requires the disclosure.

6. COOKIES, SIMILAR TECHNOLOGIES, AND THIRD-PARTY SERVICES.  The Services may use cookies, local storage, software development kits (“SDKs”), pixels, and similar technologies to maintain sessions and preferences, authenticate users, provide functionality, maintain security, detect fraud, understand use of the Services, diagnose technical issues, and monitor and improve performance.

Where required by applicable law, USEFULL will obtain your consent before placing or using cookies, SDKs, pixels, or similar technologies that are not strictly necessary for the operation of the Services. You may manage your cookie preferences through available cookie settings, if provided, or through your browser or device settings. Disabling certain technologies may affect the availability or functionality of portions of the Services.

The Services may also contain links to or integrations with independently operated third-party services. Your interactions with those services are governed by their own privacy policies and practices. This does not affect our obligations with respect to service providers that process personal information on USEFULL’s behalf.

USEFULL does not track individuals’ online activities over time and across third-party websites or online services, and does not knowingly permit third parties to engage in such tracking through the Services. Accordingly, USEFULL does not currently respond to browser-based Do Not Track signals.

7. DATA RETENTION AND SECURITY.  We retain personal information for no longer than reasonably necessary and proportionate to fulfill the purposes for which it was collected or processed, including to provide the Services, maintain appropriate business records, comply with legal obligations, resolve disputes, prevent fraud, maintain security, enforce our agreements, and establish, exercise, or defend legal claims.

In determining appropriate retention periods, we consider factors such as the nature and sensitivity of the information, the purposes for which it is processed, the duration of our relationship with you, applicable legal and recordkeeping requirements, statutes of limitation, and security and dispute-resolution considerations. When information is no longer reasonably necessary, we delete or de-identify it in accordance with our applicable retention practices, except where continued retention is permitted or required by law.

USEFULL maintains commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized or unlawful access, acquisition, destruction, loss, alteration, disclosure, or use. However, no method of electronic transmission, storage, or information security is completely secure, and we cannot guarantee absolute security.

8. YOUR PRIVACY RIGHTS AND CHOICES.  Depending on where you reside and subject to applicable law, you may have certain rights regarding your personal information, including rights to access, correct, delete, restrict, or object to the processing of your personal information, obtain a portable copy of certain information, withdraw consent where processing is based on consent and exercise other rights provided by applicable law.  The availability and scope of these rights vary by jurisdiction and may be subject to exceptions and limitations.  You may submit requests concerning your personal information using the contact information provided in Section 12. We may take reasonable steps to verify your identity before responding to a request and may deny or limit a request where permitted or required by applicable law. We will respond to requests in accordance with applicable law.

9. ADDITIONAL U.S. STATE PRIVACY RIGHTS. Residents of certain states may have additional rights regarding their personal information under applicable law. Depending on your state of residence and subject to applicable law, these rights may include the right to confirm whether we process personal information about you; access, correct, delete, or obtain a portable copy of personal information; opt out of the sale of personal information, targeted advertising, certain profiling activities, or other processing activities where applicable; appeal certain decisions regarding privacy rights requests; and exercise other rights provided by applicable law.

USEFULL does not currently sell personal information, engage in targeted advertising, share personal information for cross-context behavioral advertising, or engage in profiling that produces legal or similarly significant effects concerning an individual. As a result, certain statutory opt-out rights may not apply to our current information practices.  If we decline to act on a privacy rights request, you may appeal by emailing support@usefull.us with “Appeal” in the subject line, and we will respond within the time required by applicable law.

We will process privacy rights requests in accordance with applicable law and may request information reasonably necessary to verify your identity before responding. You may submit a request using the contact information in Section 12.

10. CHILDREN’S PRIVACY.  The Services are not intended for or directed to individuals under eighteen (18) years of age, and individuals under eighteen (18) may not create an account or use the Services.

USEFULL does not knowingly collect personal information from individuals under eighteen (18). If we become aware that we have collected personal information from an individual under eighteen (18), we will take reasonable steps to delete the information, except where retention is permitted or required by applicable law.

If you believe that an individual under eighteen (18) has provided personal information to us, please contact us using the information provided in Section 12.

11. INTERNATIONAL USERS.  USEFULL is headquartered in the United States, and the Services are intended for use in the United States. The Services are not directed to individuals in the European Economic Area, the United Kingdom, or Switzerland. If you access the Services from outside the United States, your personal information will be transferred to, stored, and processed in the United States and other countries where USEFULL or its service providers operate, which may have data protection laws different from those where you live. Nothing in this Privacy Policy limits any rights you may have under applicable law.

12. CHANGES TO THIS PRIVACY POLICY; CONTACT US.  We may update this Privacy Policy from time to time to reflect changes in our Services, information practices, legal requirements, or other circumstances.

When we update this Privacy Policy, we will revise the Effective Date above. If we make material changes, we may provide additional notice where appropriate or required by applicable law.

If you have questions about this Privacy Policy or our privacy practices, or wish to exercise an applicable privacy right, please contact us at:

USEFULL Inc.

Email: support@usefull.us

Telephone: +1 (781) 650-8935

Mailing Address: 2 Oliver Street Ste 1003 Boston, MA 02109