Iteris, Inc. Online Privacy Policy

Last updated effective date: October 24, 2022

Introduction

Iteris, Inc. ( “Iteris”, “We”, “Our,” or “Us”) recognizes and values the privacy of personal information regarding an individual (“Personal Information”) received by Iteris from its website visitors, customers, contractors, suppliers, distributors, employees, and job applicants in online interactions. This Online Privacy Policy (“Privacy Policy”) explains what Personal Information that you may provide or that may be collected from you in applicable online interactions with Iteris and describes our policies and practices for collecting, using, sharing, protecting, and maintaining that Personal Information.

Applicability

This Privacy Policy is applicable to this website or any of our other websites, mobile applications, and online interfaces to our products and services (our “Websites”) that link to this Privacy Policy. Certain Iteris Websites may adopt different privacy policies, or notices that supplement this Privacy Policy, to better fit interactions taking place on those Websites. If an Iteris Website has its own privacy policy or a supplementary notice, the provisions of that policy or notice will take priority if conflicting with this Privacy Policy.

This Privacy Policy doesn’t apply to:

• Iteris solutions and services that have separate privacy policies that do not incorporate this Privacy Policy
• The information practices of other companies and organizations that advertise our services
• Services and products offered by other companies or individuals, including products or sites they offer that may include Iteris solutions or services to which the policy applies, or products or sites displayed to you linked from our applicable solutions or services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites. By accessing or using our Websites, you are consenting to the collection, use, and disclosure of the Personal Information in the manner set forth herein. This Privacy Policy may change from time to time (see Changes to Privacy Policy below). Your continued use of our Websites after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

What is Personal Information?

For the purposes of this Privacy Policy, Personal Information (sometimes called Personally Identifiable Information, or PII) is any information that may be used to identify a specific individual, such as first and last names, postal address, e-mail address, phone numbers, company/agency and job title, agricultural field locator, or any other identifier by which an individual may be contacted online or offline. Personal Information may also include, under certain applicable law, information about your internet connection, the equipment you use to access our Websites and usage details. Personal Information does not include anonymous or non-personal information that is about you but individually does not identify you, such as anonymized information about your interest in or use of our products and services, the pages you visited, etc.

How Do We Collect Personal Information?

Information You Provide Directly

• We collect information that you provide by filling in forms on our Websites. This includes information provided at the time you fill out one of our Contact Us forms, create an account, such as with our Iteris Resource Center, sign up to our newsletter, ask to receive email communications from us, or request information on our Investor Relations page.
• If you send us an email, your email address and the contents of your message will be collected. This includes text characters and any audio, video, and graphic information formats included in the message.

Applying for Employment

• We collect information you choose to provide when you apply to available Career Opportunities on our Websites via “Apply Now” or “LinkedIn”.

Information We Collect Automatically

• Our servers automatically log information as you navigate through our Websites. Information collected automatically may include usage details, search queries and results, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. For more information about information we collect through automatic data collection technologies see Certain Automatically Collected Information below.

Information From Third Parties

• We may receive additional information about you from other publicly and commercially available sources, as permitted by law.

We may combine all of the information we collect or receive about you and use or disclose it in the manner described in this Privacy Policy.

How We Use Your Personal Information

We use Personal Information that we collect about you or that you provide to us in a variety of ways depending upon how you interact with the Websites, including to:

• present our Websites and their contents to you
• provide you with information, products, or services that you request from us
• market and advertise our products and services
• allow access to your account information and service features
• notify you about changes to our Websites or any products or services we offer through them
• provide you with technical support, customer service and account maintenance
• analyze, support, and improve your user experience and the quality of our Websites, products, and services
• maintain the integrity of our networks and address security issues
• manage a job application
• deliver confirmations, account information, notifications, and similar operational communications
• respond to any questions or concerns you may bring to our attention
• enable you to share information with social networks and to interact with Iteris on social media sites
• investigate or take action regarding violations or suspected violations of law or our terms

We and our service providers also use the information you provide to send you communications, including promotional messages about Iteris and issues of interest, via email, postal mail, fax, text message and phone, as permitted by local law and subject to your contact preferences. Although we hope you will find our promotional communications of interest, you are able to opt out of receiving them by following the instructions for opt out included on each communication. Iteris does not sell your Personal Information or share your Personal Information with third parties for their own marketing or promotional purposes.

Your use of social media features will result in the collection or sharing of information about you, depending on the feature. The basic details we receive depends on your social network account privacy settings. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them. We encourage you to review the privacy practices and settings of the social media sites you use to make sure you understand the personal information that may be collected, used, and shared by those sites.

Information Sharing and Disclosure

Personal Information which we collect for a particular purpose will only be saved and used for that purpose, unless you consent to allow us to use it for some other purpose(s), as described in this Privacy Policy. We reserve the right to use or share on an aggregate, anonymized basis, any data collected or provided through our Websites.

We may disclose Personal Information that we collect or that you provide as described in this Privacy Policy:

• to our subsidiaries and affiliates
• to contractors, service providers, strategic partners, and other third parties we use to support our business, for example to distributors, resellers, installers, hosting websites, or maintenance providers for our products and services in your local area
• 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 Iteris’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Iteris about our Website users and customers is among the assets transferred. In such event, we cannot guarantee that any entity receiving such information in connection with any of these transactions will comply with all the terms of this Privacy Policy.

We may also disclose or use your Personal Information if required or permitted to do so by law or in the good-faith belief that such action is necessary to:

• conform to national security requirements, comply with legal process or respond to a governmental authority request for information
• protect and defend the rights and/or property of Iteris and its affiliates, licensors or licensees
• enforce our applicable service agreements
• protect the personal safety or interests of our employees and consultants, other Iteris members, or members of the public in urgent circumstances

We may also disclose any of your Personal Information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or, as we deem necessary in our sole discretion, in order to protect our legitimate legal and business interests.

Except as set forth in this Privacy Policy, we do not trade, share, rent, sell or give away your Personal Information to third parties.

Certain Automatically Collected Information

When you access our Websites, our servers may record your IP address. We may use IP addresses for system administration and troubleshooting, ensuring user compliance with our terms of service, investigating security breaches and compiling anonymous non-personal information such as how many users visited our Websites and accessed specific information about our products or services. Additionally, when you log into your account, your system specifications such as operating system, system configuration, etc. may be collected by us for the purposes of analyzing and optimizing your experience and customer service.

Cookies. Our Websites may contain “cookies”. Cookies are bits of electronic information generated by web servers and stored on your hard drive when you visit practically any website on the Internet. Cookies are often used to differentiate users, store user preferences and track user trends in general. We may use cookies to improve the quality of our Websites and to better understand how users interact with such Websites. You can adjust your web browser security settings to refuse all cookies or to indicate when a cookie is being sent. However, if you disable the use of cookies in your web browser, some features of our Websites we offer may not function properly.

Google Analytics. Our Websites uses Google Analytics. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. Google’s ability to use and share information collected by Google Analytics about your visits to our Websites is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. To learn more about how Google collects and processes data in connection with Google Analytics, visit http://www.google.com/policies/privacy/partners/.

Locally Stored Objects. Certain features of our Website may use locally stored objects (also known as “Flash Cookies”) to collect and store information about your preferences and navigation to, from, and on our Website. Locally stored objects are not managed by the same browser settings as are used for browser cookies.

Web Beacons. Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the web beacon, the IP address of your computer, and the URL of the web page from which the web beacon was viewed. These web beacons permit us, 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 website content and verifying system and server integrity).

Links to Other Websites and Third Parties

Some content, applications or links, including advertisements, on or accessible from our Websites are served by third parties, including advertisers, ad networks and servers, content providers, content distribution networks, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies to collect information about you when you access them through our Websites. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Our Websites may include social media features and widgets, such as the Facebook “Like” button and the “Share this” button, as well as other interactive apps that run on the Websites and enable certain features to work (e.g., content sharing and comments).

Iteris is not responsible for the collection of Personal Information or the security or privacy of such information on any such third-party websites or online services. If you have any questions about any such third-party website or online service, you should contact the responsible provider directly. Iteris disclaims any responsibility for any harm resulting from your use of third-party websites, online services, or any products or services offered through such websites or services. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Where and How We Store Your Personal Information; Data Security

NOTE TO EUROPEAN USERS: If you connect to our Websites or otherwise access our Websites from the European Union, please note that the Personal Information that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This may include staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your Personal Information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

Iteris makes reasonable efforts in protecting your Personal Information from unauthorized access through the use of network firewalls, physical security, and administrative measures. Iteris also utilizes Amazon Web Services (“AWS”) as a data hosting provider and to securely store Personal Information, including secured networking, encryption, and best security practices. We take appropriate security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, users’ information. We restrict access to your Personal Information to our employees, contractors, consultants and third-party service providers and strategic partners who need to know that information in order to operate, develop or improve our products and services and to fulfill the purpose for which you provided your Personal Information. We use Secure Socket Layer (SSL) technology for mutual authentication, data encryption and data integrity. While no computer is 100% safe from outside attacks, we believe that the steps we have taken to protect your Personal Information drastically reduce the likelihood of security problems to a level appropriate to the type of information involved.

The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for picking a robust and secure password along with keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Websites. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites.

If you have any questions regarding which measures and techniques we use, feel free to contact us as indicated below under Questions.

Children’s Privacy

Our products and services are intended to be used by adults and corporate/government entities interested in Iteris. Our Websites are not intended for children, and Iteris does not knowingly collect or store Personal Information about children under the age of 13, as defined by local law. If you believe that we have collected personal information about a child, please inform us as indicated below under Questions so that we can delete that information.

Changes to Privacy Policy

Iteris may at any time make changes to this Privacy Policy due to changes in technology, legal requirements and our Websites. Changes will be indicated by the “Last Updated” date at the top of this page and a notification of changes will be posted here, or by other appropriate means. We suggest that you bookmark this page so that you may check periodically to see if any changes have been made. Your continued use of our Websites signifies your acceptance of the revised Privacy Policy. In the event that we change our Privacy Policy, such changes will affect all of the information we collect after any such change. If you object to the change to our Privacy Policy, then you must contact us in writing as indicated below in Questions regarding your objection.

Accessing and Revising Information

We aim to keep our Personal Information about you as accurate as possible and encourage you to promptly update your information if it changes. If you have established an account, you may, at any time, access your Personal Information to update, modify or delete any inaccuracies in Personal Information you have provided us by accessing your account through the Websites. You may also request us by sending us an email at the email listed below in Questions to remove your account information or any Personal Information we hold about you from our databases. However, as we generally keep information related to past transactions for our records, we will not be able to completely remove your information. We may also not be able to accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Some Iteris entities may act as or be considered “data controllers”. When an Iteris entity is acting as a data controller, you can exercise your rights of access and request corrections, suppression, or deactivations under applicable data protection laws directly with that Iteris entity as described in the specific Website or specific service documentation.

Special Information for European Consumers

When we store and/or process data, it will be transferred to, and processed in, the United States of America. Countries other than the United States of America may have laws different to what you’re used to in the country you live. If you are a European resident, you may request access to your Personal Information including a list of certain third parties to which we have disclosed your Personal Information. In your request, please attest to the fact that you are a European resident and provide a current European address for your response. You may request this information in writing by contacting us as indicated below in Questions. Please allow up to thirty (30) days from the date the request is received for a response. In addition, Iteris commits to resolve complaints about your privacy and our collection/use of your personal information if you contact us as indicated below in Questions.

Your California Privacy Rights

In addition to other legal rights for California residents, California Civil Code Section § 1798.83 permits users of our Websites that are California residents to request certain information regarding our disclosure of any Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email or write us as indicated below in Questions.

What are Your Data Protection Rights?

We would like to make sure you are fully aware of all your Personal Information data protection rights. Every user of our Websites is entitled to the following:

The Right to Access – You have the right to request Iteris for copies of your Personal Information. Iteris reserves the right to charge a small fee for this service.

The right to rectification – You have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.

The right to erasure – You have the right to request that we erase your Personal Information, under certain conditions.

The right to object to processing – You have the right to object to Iteris processing your Personal Information under certain conditions.

The right to data portability – You have the right to request that transfer Personal Information that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have thirty (30) days to respond to you. If you would like to exercise any of these rights, please contact us at the email listed below in Questions.

Questions

If you have questions about this Privacy Policy and our privacy practices, please contact us at:

privacy@iteris.com

or at the address below.

Iteris, Inc.
Attn: Privacy Group
1700 Carnegie Avenue, Suite 100
Santa Ana, CA 92705-5551