PRIVACY POLICY

Last updated: May 11, 2023

This Privacy Policy applies to Aten International Co., Ltd., and our affiliates (“Aten,” “IOGear,” “we,” “our,” “us”). Please read this Privacy Policy carefully to learn how we collect, use, share, and otherwise process your information (“personal information”), and to learn about your rights and choices regarding your personal information.

This Privacy Policy explains how we collect, use, and share the personal information that we gather on the subdomains and websites on https://www.aten.com and https://www.iogear.com (the “Sites”) or through your use of our products and services. By continuing to use our Sites, you agree to the terms of this Privacy Policy. A reference to “Aten,” “IOGear,” “we,” “us,” “our,” or the “Company” is a reference to Aten and its relevant affiliates involved in the collection, use, sharing, or other processing of personal information.

Please click the following links to learn more about our Privacy Policy:

1. Processing Activities Covered
2. Information We Collect
3. How We Use Your Information
4. How We Share Your Information
5. How We Respond to 'Do Not Track' Signals
6. Cookies
7. Children's Privacy
8. Change of Control
9. Data Security
10. Data Retention
11. Policy Updates
12. Contact Information
13. Region-specific Disclosures
13.1. Privacy Rights & Additional Disclosures for Certain U.S. Residents
13.2. Privacy Rights & Additional Disclosures for EEA & UK Individuals
13.3. Privacy Rights & Additional Disclosures for Residents of Taiwan

1. Processing Activities Covered

This Privacy Policy applies to the processing of personal information collected by us when you:

• Visit our websites that display or link to this Privacy Policy;
• Visit our branded social media pages;
• Receive communications from us, including emails, phone calls, texts, or faxes;
• Use our products or services; and
• Apply for employment opportunities with us.

Third Party Links and Websites. Our Sites may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

2. Information We Collect

Information You Give Us. You may give us information by signing up for an online account, entering information through our online forms or surveys, inputting information while using our services, contacting us through our chat service, contacting us by phone or email for information or customer service, or using our products and features.

The categories of information include:

• Identifiers, such as name, postal address, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.
• Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, passport number, or driver's license or state identification card number.
• Characteristics of protected classifications under federal law, such as gender or national origin - or under California law, such as marital status or age (if job applicants choose to provide this information).
• Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement
• Geolocation data.
• Visual information, such as photographs.
• Professional or employment-related information (if job applicants choose to provide this information).
• Inferences drawn from the above categories of information.

The categories of sensitive information include:

• Account log-in, financial account, debit card, or credit card number, in combination with any required security or access code, password, or credentials allowing access to the account.

Information We Automatically Collect.

• Sites: Like many website operators, we collect information that your browser sends whenever you visit our Sites. This includes log data, such as your computer's IP address, browser type, browser version, the pages of our Sites that you visit, the time and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing and Facebook Pixel. You can control cookies in your browser to enable or disable them. Learn more in our Cookie Policy.
• Products: Some of our devices will collect IP address, log-in credentials, connectivity details and locations. This is used for device control and management.

Information We Collect From Third Parties. If you access our Sites through third parties (e.g., Facebook or Google), or if you share content from our Sites to a third-party social media service, the third-party service will send us certain information about you if the third-party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.

3. How We Use Your Information

We use your personal information for the following purposes:

• To provide you with the services on our Sites, which includes:
  • maintaining and servicing accounts,
  • providing customer service,
  • processing and fulfilling orders and transactions,
  • verifying customer information,
  • processing payments, and
  • providing advertising or marketing services to you.
• To enable your use and management of our Products, such as device control and management.
• To provide analytic services, such as analyzing customer usage and improving services offered.
• To conduct market research and project planning.
• To detect security incidents, protect against fraudulent or other criminal activity, debug and repair errors, and maintain the overall quality and safety of our Sites.
• To share your website visitor activity, through website cookies, with third-party marketing partners to market our services on our Sites and other websites that you may visit.
• To fulfill our legal and financial obligations.
• To provide you with employment opportunities.

Marketing: We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Information” section below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).

4. How We Share Your Information

To Users or the Public with Your Consent. We may share your information with other users or the public with your consent.

Affiliates and Service Providers. We may share your information with our third-party service providers, vendors, agents, and any subcontractors as required to offer you our products and services. The service providers we use help us to:

• Run, operate, and maintain our Sites through third-party platforms and software tools;
• Perform content moderation and crash analytics;
• Run email and mobile messaging campaigns;
• Perform marketing analytics;
• Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
• Provide payment attribution; and
• Provide technical and customer support.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like credit card number, with us, but may share limited information with us related to your purchase, like your zip code.

Aggregated Data. We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. This data does not personally identify you and helps us to measure the success of our Sites and its features and to improve your experience. We reserve the right to make use of any such aggregated data as we see fit.

Third Party Marketing and Advertising Organizations. With respect to website cookies, we share your information with third-party marketing and advertising partners to market our services on our Sites and other websites that you may visit. Learn more in our Cookie Policy.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal information to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

5. How We Respond to 'Do Not Track' Signals

Some browsers provide you with a way to signal that you do not want your browsing activity to be tracked. We may not currently respond to all Do Not Track (“DNT”) or similar signals, as we are awaiting consensus from the Internet policy and legal community on the meaning of DNT and the best way to respond to these signals.

California and certain other U.S. state residents may opt out of tracking technologies by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us.

6. Cookies

To make our Sites and services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another. To learn more, please see our Cookie Policy.

Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve the Sites. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google's Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

You may wish to restrict the use of cookies. Please be aware that some of the features of our Sites may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

• Cookie settings in Chrome
• Cookie settings in Firefox
• Cookie settings in Microsoft Edge
• Cookie settings in Safari web and iOS

Personalized Advertising. We may also use targeted advertising cookies, such as Google Ads, to deliver tailored advertising on our Sites and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative's Consumer Opt-Out link, the DAA's Consumer Opt-Out link for browsers, or the DAA's opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

7. Children's Privacy

The Sites are not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us using the contact details provided at the end of this Privacy Policy. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information.

8. Change of Control

Personal information may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of the business, part of the sale may include your personal information.

9. Data Security

We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be appropriate technical and organizational measures to protect the confidentiality, security, and integrity of personal information obtained through the Sites, we cannot ensure or warrant the security of any information you transmit to us.

10. Data Retention

We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

11. Policy Updates

This policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting personal information to our Sites. The date the Privacy Policy was last updated is indicated at the top of this page.

12. Contact Information

If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at the following contact details:

DPO@aten.com
or by postal service to
Data Protection Officer, Aten International Co., Ltd.,
3F, No.125, Sec. 2, Datung Road,
Sijhih District, New Taipei City 221, Taiwan.

Alternatively, you can contact the Data Protection Officer's designated representative in the United States at

1-949-428-1111, ext. 1114
[or toll free at 1-888-999-ATEN (2836), ext. 1114]

13. Region-specific Disclosures

This Privacy Policy is designed to apply to our website visitors, users of our Services, and other companies and users on a global basis. In addition, this Privacy Policy will apply to employees, where applicable. Please refer below for additional disclosures that may be applicable to you.

Exercising Your Rights. If you wish to exercise any rights listed below, you must, unless otherwise directed by a specific right, submit a request by emailing our Data Protection Officer (DPO) at DPO@aten.com.

Alternatively, you can contact the DPO in Taiwan at 886-2-8692-6789 or his designated representative in the United States at 949-428-1111, ext. 1114 [or toll free at 1-888-999-ATEN (2836), ext. 1114].

13.1. Privacy Rights & Additional Disclosures for Certain U.S. Residents

Several jurisdictions within the United States grant state residents rights and disclosures. We provide the following information to further help you understand your potential privacy rights.

Request for Information or Deletion. Residents of certain U.S. states have the right to know whether we process your personal information and, in some instances, to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide to you:

• The categories of personal information we collect about you.
• The categories of sources from which your personal information is collected.
• The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your personal information, and the categories of personal information disclosed for such purpose(s).
• The categories of third parties with whom we share your personal information.
• The categories of personal information we have sold, if any, about you and the categories of third parties to whom your personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
• The specific pieces of personal information we have collected about you.

In addition, you may have the right to request we delete your personal information.

Request for Correction. Residents of certain U.S. states have the right to request the correction or rectification of inaccurate information in the resident's personal information.

Request for Portable Data. Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their personal information that allows the data to be transmitted to another entity.

Do Not Sell or Share My Personal Information. Residents of certain U.S. states have the right to opt out of the sale or sharing of the consumer's personal information. We do not sell your personal information. However, we may use your personal information to provide personalized or targeted advertising. In such circumstances, you may have the right to direct us not to share your personal information for such purposes. If you wish to opt out of this sharing of your personal information for personalized or targeted advertising, please visit this webpage: Do Not Sell or Share My Personal Information.

Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive personal information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive personal information for any purpose other than providing our goods and services to you, or as otherwise minimally permitted under applicable law.

Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties' direct marketing purposes. To make such a request, please contact us using the contact details provided in the “Contact Information” section.

Automated Processing & Profiling. Residents of certain U.S. states have the right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Right to Equal Service & Price. You have the right to receive equal service and price, even if you exercise a privacy right.

Verification Process for Exercising Rights. To protect your privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us and provide us with a copy of the consumer's written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Appeal Process. If we do not decide to act in response to your request to exercise a right, we will provide a timely response detailing the reasons for not taking the action and, depending on your jurisdiction, any rights that you may have to appeal our decision.

13.2. Privacy Rights & Additional Disclosures for EEA & UK Individuals

Lawful Bases for Processing (EEA and UK Individuals). If you are from the European Economic Area (EEA) or United Kingdom (UK), our legal bases for collecting and using your personal information is as follows:

• The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration.
• Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and improvement of our services.
• Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your personal information to record your requests to exercise your rights and to verify your identity for such requests.
• Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
• In some limited cases, we may also have a legal obligation to collect personal information from you in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in the “How We Share Your Information” section.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at the end of this Privacy Policy.

EEA or UK Individuals' Rights. If you are from the EEA or UK, you have the right, under certain circumstances, to:

• Access your personal information;
• Correct inaccurate information in your personal information;
• Request erasure of your personal information without undue delay;
• Request restriction of, in certain circumstances, the processing of your personal information;
• Request receiving a portable copy of your personal information held by us, and to have that portable copy transmitted to another controller; and
• To object to the processing of your personal information.

To exercise any of these rights, contact us using the contact details provided at the end of this Privacy Policy, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor your request.

International Transfers of Data. Any data that you provide to us may be accessed, shared, or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).

This may entail a transfer of your personal information across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal information transferred internationally.

Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information at the bottom of this Privacy Policy.

Our Data Protection Officer. As part of our commitment to protecting your Personal Data, we have appointed a DPO to monitor compliance and provide advice. Our DPO's contact information is DPO@aten.com.

13.3. Privacy Rights & Additional Disclosures for Residents of Taiwan

If you are a Taiwan resident, you have the following rights under the Personal Data Protection Act:

• Inquiry or review your personal information (fees may be charged);
• Request a copy of your personal information (fees may be charged);
• Request to supplement or correct your personal information;
• Request to cease collecting, processing or using your personal information; and
• Request to erase your personal information.

Please note that if you request us to cease collecting, processing, or using or request us to erase your personal information, the use of this website or our provision of products and services or our securing of products and services from you, in each instance as applicable, may not be possible. We shall not be responsible for any of your losses arising therefrom.