ATHENA ACCESSIBLE TECHNOLOGY, INC.

MOBILE APP PRIVACY POLICY

Last modified: January 30, 2023

Introduction

Athena Accessible Technology, Inc. (“Company” or “We”) respects your privacy and are

committed to protecting it through our compliance with this policy. This policy describes:

 The types of information we may collect or that you may provide when you download,

install, or use the Company’s mobile application (the “App”).

 Our practices for collecting, using, maintaining, protecting, and disclosing that

information.

This policy applies only to information we collect in this App and other electronic

communications sent through or in connection with this App.

This policy DOES NOT apply to information that:

 We collect offline or on any other Company apps or websites, including websites or other

media you may post or access through this App.

 You provide to or is collected by any third party (see Third-Party Information

Collection).

Our websites and apps, and these other third parties may have their own privacy policies, which

we encourage you to read before providing information or accepting tracking technology on or

through them.

Please read this policy carefully to understand our policies and practices regarding your

information and how we will treat it. If you do not agree with our policies and practices, do not

download, register with, or use this App. By downloading, registering with, or using this App,

you agree to this privacy policy. This policy may change from time to time (see Changes to Our

those changes, so please check the policy periodically for updates.

How Your Information Is Collected

We collect information from and about users of our App:

 Directly from you when you provide it to us.

 Automatically when you use the App.

Information You Provide to Us

When you use this App, we only collect personal information that you provide to us, such as:

 Records and copies of your correspondence (including email addresses) if you contact us.

 Your responses to surveys that we might ask you to complete for research purposes.

 The source of articles, web pages, and other writings that you post to our App.

Automatic Information Collection and Tracking

When you download, access, and use the App, it may use technology to automatically collect the

following information that does not identify you individually:

 Gaze Estimation (Eye Movement Tracking). We use automated technology to collect

data points of your eye movements, using your device’s front-facing camera, but do not

collect or receive video or photographic recordings on our servers or any other

information that identifies you personally.

 Usage Details. When you access and use the App, your device manufacturer and/or app

store provider may automatically collect certain details of your access to and use of the

App, including traffic data, location data, logs, and other communication data and the

resources that you access and use on or through the App and transmit this data to us on an

anonymous, aggregate basis. For more information, see Third-Party Information

Collection.

 Device Information. We may collect your device’s unique device identifier.

IF YOU DO NOT WANT US TO COLLECT THIS INFORMATION, DO NOT

DOWNLOAD THE APP, OR IMMEDIATELY DELETE IT FROM YOUR DEVICE.

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information

collection technologies to collect information about you or your device. These third parties may

include, without limitation:

 Your mobile device manufacturer.

 App store and platform providers.

 Analytics companies.

 Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use

this App. They may collect information about your location and/or your online activities over

time and across different websites, apps, and other online services websites. We do not control

these third parties’ tracking technologies or how they use the information collected.

They may use this information to provide you with interest-based (behavioral) advertising or

other targeted content. 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 opt out of receiving

targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

If you have any questions about an advertisement or other targeted content, you should contact

the responsible provider directly.

You can also choose whether or not to allow the App to collect and use real-time information

about your device’s location through the device’s privacy settings.

Children Under the Age of 13

We do not knowingly collect personally identifiable information from any users, including

children under 13. If you believe we might have any personally identifiable information from or

about a child under 13, please contact us at the e-mail address below.

How We Use Your Information

We use information that we collect about you or that you provide to us to:

 Provide you with the App and its contents, and any other information, products, or

services that you request from us.

 Fulfill any other purpose for which you provide it.

 Carry out our obligations and enforce our rights arising from any contracts entered into

between you and us.

The usage information we collect helps us to improve our App and to deliver a better and more

personalized experience by enabling us to:

 Estimate our audience size and usage patterns.

 Store information about your preferences, allowing us to customize our App according to

your individual interests.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify

any individual or device, without restriction.

Data Security

We have implemented measures designed to secure your information from accidental loss and

from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of

information via the internet and mobile platforms is not completely secure. Although we do our

best to protect your personal information, we cannot guarantee the security of your personal

information transmitted through our App. Any transmission of personal information is at your

own risk. We are not responsible for circumvention of any privacy settings or security measures

we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we

treat our users’ personal information, we will post the new privacy policy on this page and on our

website.

The date the privacy policy was last revised is identified at the top of the page. You are

responsible for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices or to register a

complaint or concern, please contact us at:

contact@athenahandsfree.com

We will do our best to address your concerns. If you feel that your complaint has been addressed

incompletely, we invite you to let us know for further investigation.