End‑User Privacy and Data Use Policy

This Privacy Policy (the “Policy”) explains how Footmarks, Inc. (“Footmarks”, “we”, “us”, or “our”) collects, uses, and protects information in connection with our technology and services. By using Footmarks technology, you agree to this Policy and any updates posted here.

We value transparency, accountability, and your choice. If you prefer that we do not collect information about you or your activities, please do not use Footmarks‑enabled functionality or disable it where available. This Policy covers data collected by Footmarks technology. Apps powered by Footmarks (“Apps”) may have their own privacy policies and practices.

What Is Footmarks Technology?

Footmarks enables personalized experiences within certain third‑party Apps that include our SDKs and/or work with our beacons. To determine whether an App you use includes Footmarks, consult that App’s privacy policy and settings.

Apps can disable Footmarks functionality. If disabled (in‑App or at the device level), we do not collect the information described below. This Policy applies to Footmarks’ collection and use of data, not to the broader practices of the Apps themselves.

Information We Collect

“Proximity information” is data that can determine your approximate or precise location (for example, via beacons) but, by itself, does not identify you personally. “Personal information” is data that can identify a specific person (for example, name or email address). Footmarks does not collect personal information from consumers through our technology. If you voluntarily submit personal information via our website (e.g., a contact form), we handle it according to this Policy.

We do not collect your name, phone number, email address, contacts, or call/text details.

Categories of Data (depending on App settings)

• Location/Proximity: If enabled, we may collect coarse GPS coordinates and/or precise proximity by detecting your device near one of our Bluetooth beacons. Timestamps and a device identifier may be stored with location events. Beacons can be placed in known physical spaces (e.g., retail stores) or attached to transient assets; in those cases, location may be associated with known places.
• Interests (SmartProfiles): If enabled by an App or Partner, we may receive demographic or interest information (e.g., approximate age range, general location, high‑level interests) to improve the service experience.
• Device Information: We collect device metadata (e.g., make, model, OS version). We do not collect or store your phone number.

California Privacy (CCPA)

Under the CCPA, California residents have the right to know what personal information is collected, used, disclosed, or sold; to request deletion (subject to exceptions); and to opt out of sale. We honor these rights as applicable and do not require you to create an account to exercise them.

Making a Request

Because we do not generally collect direct identifiers, we verify requests through our mobile application. Download the “Tracking It” app and follow the in‑app process: iOS Tracking It app.

Changes to This Policy

We may update this Policy periodically. If material changes occur, we will provide appropriate notice (for example, via our website or in‑app). Your continued use of Footmarks technology constitutes acceptance of the current Policy.

Other

This Policy applies to information collected by Footmarks online or offline. We limit collection to what is relevant for stated purposes and take steps to keep data accurate and up‑to‑date, purging stale data when appropriate. You may request to view, correct, or remove certain information by contacting us.

Dispute Resolution

We maintain an internal dispute resolution process. To submit a complaint, contact us via the methods on our Contact page and include “Privacy Dispute” in the subject, details of the issue, your contact information, and verification of identity. Indicate whether you consent to share details with third‑party arbitrators.

Contact Us

Questions or comments about this Policy? Visit our Contact page or write to:

Clients and Partners

Our use of personal information may also be governed by agreements with clients and partners. Where applicable, those agreements may control.

Last updated: September 21, 2025