Introduction

Cedar Electronics Holdings Corp. ("Cedar", "Company", "we", "our", or "us") respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy governs the ways Cedar Electronics Holdings Corp., its subsidiaries — including Cobra Electronics Corporation and Escort, Inc. — and affiliates collect, store, use, share and protect your information on the following websites: www.cobra.com, www.escortradar.com and any website owned by Cedar that links directly to this policy (collectively the "Sites") and related mobile applications including the 'Drive Smarter' mobile application, and the 'Drive-HD' mobile application (collectively the "Apps"). The Sites, Apps and the services provided within each are collectively known as the "Services".

This policy applies only to information we collect through our Services that link to this policy and in electronic communications between you and the Services. It does not apply to information collected by us offline or through any other means not linked to this policy, or by any third party (including our affiliates and subsidiaries) that does not link to this policy. Affiliates or subsidiaries that operate separate websites or applications are excluded from this policy unless those websites or applications expressly link to this policy. We may provide additional or supplemental privacy notices specific to certain features, services, or activities, which will supplement or, where indicated, control over this policy.

Updates to this Policy

We may update this Privacy Policy based upon evolving laws, regulations and industry standards, or as we may make changes to our business, including the Services. We will post changes to our Privacy Policy on this page and encourage you to review our Privacy Policy when you use our Services to stay informed. If we make changes that materially alter your privacy rights, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If you disagree with the changes to this Privacy Policy, you should discontinue your use of the Services. Your continued use of the Services following the posting of any revised Privacy Policy shall constitute your acceptance of such changes.

Children

You must be at least 18 years old to use the Services. The Services are not directed to or intended for use by minors. If you are under 18, do not use or provide any information through the Services. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at the information included below.

Personal Information We Collect

Personal information refers to information that identifies you or may be used to identify you as an individual. If you browse the Sites, you may generally do so anonymously without providing any personal data. However, there are cases in which we may ask you for Personal Information. Cedar collects different kinds of personal data from you when you use our Services. The types of Personal Information we collect or process include:

• Identity Data such as first name, last name and business name;
• Contact Data such as address, email address and telephone numbers; Emergency Contact information (all optional) includes first name, last name, mobile number and email;
• Profile Data such as your username and password;
• Payment Data such as credit card number and expiration date;
• Preferences Data such as car make/model/year and personal product interests (optional);
• Technical Data such as IP address and your login data (IP address may be used to infer your location); and
• Other Information includes information that, by itself does not individually identify you, such as browser type, operating system, the webpages you viewed and how long you viewed them.
• Insurance information, including policy details, provided voluntarily by you in connection with safety features and collision notification services.
• Inferences drawn from any of the above categories of Personal Information, including consumer profiles reflecting preferences, behavior, and interests.

Some of this information may be considered sensitive personal data under applicable law, including precise geolocation data. We collect and process sensitive personal data only as permitted by law and, where required, with your consent. Additionally, statistical and aggregated data that does not identify any individual is treated as non-personal data and may be disclosed without restriction. However, if any combination of non-personal or aggregated data is combined in a manner that directly or indirectly identifies an individual, such combined data will be treated as Personal Information and handled in accordance with this Privacy Policy.

Application Specific Information

Some of our Apps utilize specific types of information to provide you with the Services for which they are intended to address. For example, Drive Smarter uses GPS to power features like alerts and map context – this location data is stored anonymously and is not used for other purposes.

Marketing Messages

You may sign up to receive email marketing messages from us. You may opt out at any time by clicking the 'unsubscribe' button in the emails you receive. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any "Contact Us" request as well as administrative emails (for example, in connection with a details update request) that are necessary to facilitate your use of the Sites.

You may also choose to receive SMS/text messages from us through your mobile device. We will only send you marketing communications via SMS/text messages where we have obtained your consent to do so. These messages may be used to provide you with marketing promotions and transactional alerts. You may withdraw your consent at any time by unsubscribing and replying STOP. By opting into our SMS messaging, you consent to receive mobile text alerts using automatic telephone dialing systems. Standard messaging and data may apply depending on your mobile carrier and plan. After opting out you will no longer receive SMS messages, unless you opt back in. You may receive additional messages after opting out to confirm you have unsubscribed. We may continue to send you transactional or service-related SMS messages that are necessary for the performance of a contract with you, even after you have withdrawn your consent to marketing messages.

Shopify

Some of our Sites are hosted on Shopify, which collects and processes your Personal Information to provide and improve the Site. Information you submit on the Site may be transmitted to and shared with Shopify. To learn more about how Shopify uses your Personal Information and any rights you may have, you can visit the Shopify Consumer Privacy Policy. Depending on where you live, you may exercise certain rights with respect to your Personal Information here: Shopify Privacy Portal.

Payment Information

You may provide your credit card number and billing information when you make a purchase on our Site. We use this information for billing purposes and to fulfill your orders. If we have trouble processing an order, we may use this information to contact you. When you place an order on our Site we will share your payment information with payment processors such as Shop Pay, Paypal, and Google Pay. These payment processors will use and process your payment information according to their own privacy policies.

Information We May Automatically Collect

When you visit our Site and use our Services, we and third parties, including Meta, Google, Microsoft, and others, may automatically collect certain information about your device, including information about your web browser, IP address, and time zone by using cookies and similar technologies. Additionally, as you use our Services, we may collect information about the individual web pages and services that you view, what websites or search terms referred you to our Services, and information about how you interact with the Services. We use the following to automatically collect this information:

• "Cookies" are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit www.allaboutcookies.org.
• "Log files" track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• "Web beacons", "tags", and "pixels" are electronic files used to record information about how you browse the Sites.

We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). Your consent is required before non-essential cookies are placed on your devices.

Find out how to manage Cookies on popular browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

How We Use Your Personal Information

We do not sell or rent any of your personal data to third parties for their marketing purposes without your consent. However, we may disclose your personal data to our subsidiaries, which are either subject to this Privacy Policy or follow practices at least as protective of your rights as those described in this Privacy Policy. We use the Personal Information we collect from you in the following ways:

• To provide, operate, and maintain the Services and any content, features, or products available through them;
• To fulfill and manage subscriptions, purchases, orders, deliveries, payments, returns, and exchanges;
• To manage your account and provide you with customer service;
• For the performance of a contract and the development, compliance, and undertaking of any contract you may have with us;
• To personalize your experience on the Services;
• To comply with applicable laws, respond to lawful requests from government authorities, and detect, investigate, and prevent fraudulent transactions and other illegal activities;
• To carry out our obligations and enforce our rights arising from contracts between you and us, including for billing, collections, and auditing;
• For any other purpose described to you at the time the information is collected; and
• For any other purpose with your consent.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Our agents, contractors, service providers, and other third parties that support our business are bound by contractual obligations to keep personal data confidential and to use it only for the purposes for which we disclose it to them. A current list of third-party providers that have access to collected personal data includes: Meta, Google, Shopify, NetSuite, Yotpo, Avalara, Celigo, FreshDesk, Klaviyo, Hotjar, Stape, Clearer Address Validator, Top Growth Marketing, Joyryde Marketing, StoreView, Rakuten, Gleam, ID.me and Amazon AWS.

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

Third Party Websites and Links

Our Sites may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party.

Application Marketplaces

Your use of the Apps may be subject to terms and privacy practices that are separate from this Privacy Policy, including, but not limited to terms in the Apple App Store and Google Play store or other similar service that lawfully enables download of the Apps (each an "App Store"). Please review the respective App Store you use to download our App for more information.

Use of Artificial Intelligence Services

We may use artificial intelligence ("AI") and machine learning tools and services provided by third parties in connection with our business operations, including but not limited to customer support, content generation, data analysis, customer relationship management, and internal process optimization. Additionally, AI tools may summarize, analyze, and aggregate data derived from your Personal Information (including your email address, phone number, and other contact details) for internal business purposes, including reporting, trend analysis, and operational optimization. No decisions regarding your eligibility for services, employment, or any other material determination are made solely by AI without human review and oversight. Any AI service providers that process your Personal Information on our behalf are bound by contractual obligations to maintain the confidentiality and security of such data and to process it only in accordance with our instructions and applicable laws.

Data Retention

We keep the categories of personal data described in this Privacy Policy for as long as reasonably necessary to fulfill the purposes described herein, or as otherwise legally permitted or required, such as maintaining and operating the Services, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention purposes. We consider our legal and business obligations, potential risks of harm, and the nature and sensitivity of the information when deciding retention periods. At the end of the applicable retention period, personal data will be deleted, destroyed, or de-identified in accordance with our internal data retention schedule. We reserve the right to retain anonymized and aggregate information indefinitely.

Data Security

We have implemented commercially reasonable administrative, physical, and technical measures designed to protect your Personal Information from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. These measures include, without limitation, appropriate technical and organizational security policies and procedures, security controls, and employee training. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.

If you make any purchases through the Services, we may use a third-party payment processor such as ShopPay to assist with securely processing your payment information. Your payment data will be encrypted and handled in accordance with applicable industry standards. Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information will be deleted, unless you choose to save it as part of your profile.

You are responsible for maintaining the security of your account credentials that relate to the Services. We will treat access to the Services through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

Account Information

If you would like to review or change the information in your account or terminate your account you may log into your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshooting problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

California 'Shine the Light' Law

California Civil Code Section 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of the information you provide through the website to third parties for their direct marketing purposes. To make such a request, please contact us at the information included in the Contact Us section.

Notice to European Users

If you are located in the European Economic Area or the United Kingdom, the General Data Protection Regulation ("GDPR") and the United Kingdom General Data Protection Regulation ("UK GDPR"), as applicable, provide you with certain rights in relation to your Personal Information. These rights may include:

• Right of Access – the right to access the Personal Information we process about you.
• Right to Rectification – the right to request that we amend or update your Personal Information where it is inaccurate or incomplete.
• Right to Erasure – the right to request that we delete your Personal Information.
• Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your Personal Information, to the extent permitted by law.
• Right to Object – the right to object, on grounds relating to your particular situation, to any processing of your Personal Information carried out on the basis of our legitimate interests. Where we process your Personal Information for direct marketing purposes, you have the right to object at any time without having to provide any specific reason.
• Right to Data Portability – the right to request transferring your Personal Information to another controller, to the extent possible.
• Right Not to be Subject to Automated Decision-Making – the right to not be subject to a decision based solely on automated decision making, including profiling. Automated decision-making currently does not take place on our Services.
• Right to Withdraw Consent – where we rely on your consent as the legal basis for processing your Personal Information, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

You also have the right to lodge a complaint with a supervisory authority in the jurisdiction in which you reside or in which an alleged infringement of applicable data protection law has occurred. For individuals in the United Kingdom, the relevant supervisory authority is the Information Commissioner's Office (ICO), which can be contacted at ico.org.uk. For individuals in the European Economic Area, you can find a list of national data protection authorities at edpb.europa.eu.

For the purposes of the GDPR and the UK GDPR, Cedar (located at 1701 Golf Road, Tower 3, Suite 900 Rolling Meadows, IL 60008) is the data controller responsible for your Personal Information. To exercise these rights, you may email us at contactus@cedarelectronics.com. You may also use our Personal Data Removal Request form to delete your Personal Information stored in our Services. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request.

Please note that we are based in the United States and process Personal Information in the United States and other countries where our service providers operate. If you are located in the European Economic Area or the United Kingdom, your Personal Information may be transferred to and processed in countries outside your jurisdiction that may not provide the same level of data protection as your home country.

Contact Us

If you have questions or concerns about our policies concerning privacy, data collection, data processing, or data transmission, please e-mail us using the contact us page.