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Last Updated January, 2021
This Privacy Statement covers our privacy practices with respect to the collection, use, and disclosure of information obtained: (i) through the Locus website at www.locusrobotics.com and our other websites and digital properties that link to, or expressly adopt or refer to, this Privacy Statement (hereinafter, collectively our “Websites”); (ii) in connection with the use of our autonomous robotics solution (the “Subscription Service”) and related support services, including customer success and other professional services (the “Support Services”) that we provide to Customers, and (iii) in connection with human resource functions for our employees and prospective employees, as described below.
For the purposes of this Privacy Statement:
When you interact with the Websites or the Services, you consent to the collection, use and disclosure of information as described in this Privacy Statement. If you do not consent to the terms of this Privacy Statement, do not continue to interact with or use the Websites or the Services.
European and UK Residents: Please see our European Privacy Policy for residents of the European Union, the European Economic Area, United Kingdom or Switzerland.
For all Visitors, Locus operates as the controller of your Personal Data. The following information applies to the Personal Data collected by Locus from Visitors of our Website. For information with regard to the Cookies we collect on our Visitors, please refer to Cookie Settings below.
The following information reflects Personal Data that we have collected about you over the past 12 months. Personal Data Collected Directly from you
When you access, use and/or interact with our Websites, we directly collect information you voluntarily provide us, such as when you download content or contact us, which includes:
Locus may collect and use information we receive from third parties in connection with your use of the Websites. For instance, Locus may use a third party for reporting and analytics to measure the effectiveness of our Websites and marketing efforts, and to identify areas for improvement.
We also obtain business information and your Personal Data (such as your name, title, company name and email) from third party sources, as permitted by applicable law, such as the following:
As you navigate through the Website, we also collect details about your visits to our Website including, but not limited to, your IP address, usage patterns, traffic data, location data, logs and other communication data and the resources that you access, as well as information about your computer and internet connection, including your operating system, mobile device and browser type.
A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return Visitor to the Websites. We may use cookies, log files, pixel tags, web bugs, web beacons, clear GIFs, Local Storage Objects (LSOs) such as HTML5 and Flash or other similar technologies to collect information about the ways you interact with and use the Websites, to support and enhance features and functionality, to monitor performance, to personalize content and experiences, for marketing and analytics, and for other lawful purposes.
When you visit our Websites, we, or an authorized third party may place a small text file called a “Cookie” on your computer’s browser directory. Cookies are designed to collect information, which includes Personal Data, about your online activities over time and across different sites.
Session-based cookies exist only during one session and disappear from your computer when you close your browser or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but choosing to disable cookies may limit your use of certain features or functions on our Websites. The following describes how we use different categories of cookies and similar technologies and your options for managing our collection of Cookies.
The Cookies that Locus uses fall into the following categories:
The Cookies we collect help us facilitate a safe interaction for you on our Website, enhance the function, performance and services on the Website, provide social media features, and analyze our Website traffic. We also allow authorized third parties to use Cookies to enhance your use of our Website with social media, advertising, and our analytics partners. We use both session-based and persistent cookies on our websites.
We use third-party pixels or web beacons on our Website to track activity for web analytics and for re-marketing activities. “Re-marketing activities” means that our third parties will continue to show ads to you across the internet but we will not be collecting any identifiable information about you through this remarketing system. The third-party vendors we use will place cookies on web browsers in order to serve ads based on past visits to our Website. This allows us to make special offers and continue to market our services to those who have shown interest in our service.
For more information, visit the help page for your web browser or see http://www.allaboutcookies.org or visit www.youronlinechoices.com for more information about behavioral advertising and online privacy.
Please refer to your browser tools for specific instructions. Here are a few of the more popular browsers:
Google ChromeFirefoxSafariMicrosoft Edge
We may use Personal Data that we collect about Visitors for the following purposes:
If you ask us to contact you about our Services, we may use your Personal Data or permit selected third parties to use your Personal Data to provide you with such information. Visitors may withdraw consent for use of such personal data, at a later time by clicking on the “unsubscribe” or “Update Subscription Preferences” links located in the emails sent by Locus, or exercising their applicable data access rights as laid out in the European Privacy Policy or the CCPA Privacy Notice.
Subject to any applicable data privacy law, or regulation, we may share, disclose or transfer Personal Data that you provide to us via this Website, to the following third parties:
We do not sell, rent or trade information collected through the Website or the Services to third parties.
We may retain a Visitor’s Personal Data for the period of time which is consistent with the original purposes of collection, as determined in our sole discretion, and in accordance with our record retention policies. When determining the retention of your Personal Data, we will evaluate the amount, nature, and sensitivity of such Personal Data processed, the potential risk of harm from the unauthorized use or disclosure of your Personal Data, and whether we can achieve the purposes of the processing such personal data through other means, as well as applicable legal requirements. Upon the expiration of the applicable retention period, your Personal Data will be deleted. Any information we are unable to delete entirely from our systems will have measures in place to prevent any further access and use of such data.
For all Customers and Users, Locus operates as the processor of applicable Customer Data. The following information applies to the Personal Data collected by Locus from Customers and Users of our Services. Data subject requests for Customer Data must be made through the applicable Customer as the controller of the Customer Data. Locus will comply with all data subject access requests in accordance with the provisions of the applicable contract between the applicable Customer and Locus.
We collect the following Customer Data from and/or about our Customers and Users (collectively, the “Customer Data”), including:
We also collect information that is not defined as Personal Data in providing the Services to Customers such as: (1) task data from the Customers’ warehouse management system including Task ID, Task Description, Task Type, Task Location and Quantities associated with the task; (2) performance or statistical data derived and/or generated from the operation of the Service, including pick/activity rates, location of picks/activities and timing of when the work is completed (the “Derived Data”). Such Derived Data may include User IDs if Customer chooses to store and report on Derived Data by User, however, the User ID can be pseudonymized or anonymized. Other than fulfilling specific data processing and/or reporting obligations for our Customers pursuant to Customer Agreements, all of this Derived Data collected, used, and disclosed will be in aggregate form only and will not identify any Customer or its Users, unless otherwise provided in a Customer Agreement.
We use Customer Data to provide, maintain and improve the Services, including providing Support Services. Notwithstanding anything else to the contrary in this Privacy Statement, we will not use, disclose, review, share, distribute, transfer or reference any Customer Data except as permitted in the Customer Agreement, or as required by law.
When you use the Subscription Service, we use Cookies to:
A User may refuse to accept the “remember me” cookie, which will then require a User to provide their username and password to log into the Subscription Service.
As a processor of Customer Data, we only share the Personal Data collected in accordance with the Customer’s instructions, as permitted in the applicable Customer Agreement. Subject to any applicable data privacy and protection law and regulation, we may disclose Customer Data to third parties solely to:
We do not sell, rent or trade Customer Data with third parties.
We may keep Customer Data for the period of time which is agreed upon in the applicable Customer Agreement.
Since each Customer is the controller of the Personal Data submitted to Locus as a processor, Users and such individuals must contact the applicable Customer administrator with any inquiries about how the Customer uses and discloses Personal Data and how to access or correct Personal Data contained in Customer Data. Locus will comply with all obligations agreed to between the relevant Customer and Locus to effectuate any data access rights a User may have with respect to the Locus’s processing of the relevant Personal Data.
As a controller of our employees’ personal information, we collect personal information and sensitive personal information provided to us by you which may include, without limitation, name, address, email address, date of birth, gender, ethnicity, physical address, phone number, birth date, citizenship, education, employer (current or former), job title, passport number, driver’s license number, spouse or dependents, compensation, personal health information, payment instructions, credit card information, and EEOC data, in each case, collected only for Locus’ legitimate business purposes, including (1) the management and operations of our company, its functions and activities, (2) employee communications, including employee surveys, (3) maintaining a global directory, (4) carrying out obligations under employment contracts and employment, tax and benefits laws, and in connection with other working relationships or arrangements, (5) development and training programs, (6) assessing employee qualifications and performance, (7) managing employee performance, (8) determining employee compensation or payment, (9) managing the employee termination process, and (10) other general human resources purposes. Our European Union and Swiss Employees at the time of their employment are notified in detail how their personal information will be used. Employee information on health, performance evaluations, and disciplinary actions and other sensitive employee matters, whether it is stored manually or electronically, is accessible by other Locus employees only if necessary with respect to legitimate human resource functions or issues, and in accordance with applicable laws. Locus will obtain affirmative consent from an employee before using such employee’s personal information for any purpose other than as described above. Employees may decline to provide this consent, and employees may withdraw their consent at any time.
Employees may choose to voluntarily disclose personal information about family members, in which cases, such personal information shall be treated, for the purposes of this Privacy Statement, the same as an employee’s personal information. Employee personal information is never sold, leased, or rented to any third party.
In accordance with applicable law, employees may have the right to opt-out of disclosing their personal information provided that Locus does not need such personal information for a legitimate business purpose. Employees can contact our Human Resources Team at hr@locusrobotics.com or our Privacy Team at privacy@locusrobotics.com if they wish to exercise these rights.
As a controller of our prospective employees’ personal information, we collect personal information and sensitive personal information provided to us by applicants or indirectly from third parties (e.g., LinkedIn, recruitment agencies or referrals from other third-parties) which may include, without limitation, name, address, email address, date of birth, gender, ethnicity, physical address, phone number, birth date, citizenship, education, employer (current or former), title, driver’s license number, spouse or dependents, compensation, payment instructions, and EEOC data only for legitimate business purposes, including (1) the recruiting and hiring of job applicants, (2) performing background checks and verifying references, (3) communications with the applicant, (4) assessing applicant qualifications and performance, (5) determining applicant compensation or payment, (6) other general human resources purposes. For information with respect to any applicable data access rights, please refer to “Your Rights and Choices with Locus as a Controller of your personal data”.
Employee personal information will never be disclosed to third parties except as follows: (1) to those retained by Locus as agents for the purposes set forth above, (2) where required pursuant to an applicable law or regulation, governmental or judicial order, or to protect the rights or property of Locus, (3) where authorized in writing by the employee, and (4) where the employee voluntarily provides personal information and the context makes it clear that such information will be provided to a third party.
Applicant personal information will only be disclosed to third parties as follows:
We may retain an employee’s personal information for the period of time which is consistent with the original purposes of collection, as determined in our sole discretion, and in accordance with our record retention policies; provided, however, that the use of such data is retained in accordance with a legitimate business purpose. When determining the retention of your personal information, we will evaluate the amount, nature, and sensitivity of such personal information processed, the potential risk of harm from the unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing such personal data through other means, as well as applicable legal requirements. Upon the expiration of the applicable retention period, your personal information will be deleted. Any information we are unable to delete entirely from our systems will have measures in place to prevent any further access and use of such data.
We may retain an applicant’s personal information for the period of time which is consistent with the original purposes of collection, as determined in our sole discretion, and in accordance with our record retention policies. When determining the retention of your personal information, we will evaluate the amount, nature, and sensitivity of such personal information processed, the potential risk of harm from the unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing such personal data through other means, as well as applicable legal requirements. Upon the expiration of the applicable retention period, your personal information will be deleted. Any information we are unbale to delete entirely from our systems will have measures in place to prevent any further access and use of such data.
Your information may be transferred by us, our affiliates and/or third parties outside the country in which you are located, including the United States. Such countries may not offer the same level of protection as in other parts of the world in terms of data protection and privacy regulations. By providing us your information and confirming your consent, you agree to such transfer and/or processing. When we transfer your data outside of EEA, we will ensure that your data is transferred and processed securely in a manner which provides a degree of protection of your personal data similar to the EU. For further information, please see our Please see our European Privacy Policy for residents of the European Union, the European Economic Area, United Kingdom or Switzerland.
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at: privacy@locusrobotics.com. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority. The services of EU DPAs are provided at no cost to you.
To prevent Personal Data from loss, misuse and unauthorized access, disclosure, alteration or destruction, to maintain data accuracy, and to ensure the appropriate use of Personal Data, we employ administrative, technical and organizational measures that are reasonably designed to help safeguard the information we collect. Only authorized Locus personnel have access to the Personal Data, including server logs and cookie utilization data, that we collect. These individuals are required to follow strict security policies and procedures. Locus may use encryption, secure socket layer, firewall, password protection and other physical and logical security measures to help prevent unauthorized access to such. Locus may also place internal restrictions on who in the company may access data to help prevent unauthorized access to such information.
Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Therefore, despite our efforts, we cannot guarantee its absolute security. We do not warrant or represent that Personal Data you will be protected against, loss, misuse, or alteration by third parties.
If you use the Websites or the Services, you are responsible for maintaining the confidentiality of any of your access credentials, including any password. You are responsible for restricting access to your computer, and you agree to accept responsibility for all activities that occur under your access credentials. We cannot secure any Personal Data that you release on your own, that you request us to release or that is released through another third party to whom you’ve given access. Where required under applicable law or by contract, we will notify the appropriate parties or individuals of any loss, misuse and unauthorized access, disclosure, alteration or destruction of Personal Data so that such parties or individuals can take the appropriate actions for the due protection of their rights. If such Personal Data is information of a Locus Customer, we will notify such Customer and coordinate with them regarding any required notices to particular individuals, including any Users. Please report any known or suspected security violations at privacy@locusrobotics.com.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Data to third parties for their direct marketing purposes. To learn more about your California privacy rights, please read our CCPA Privacy Notice.
The Website or Services may link to other websites or resources that are not owned or controlled by Locus (“External Websites”). Such links do not constitute an endorsement by Locus of those External Web Sites. You acknowledge that Locus is providing these links to you only as a convenience, and further agree that Locus is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the applicable External Web Site. We encourage you to be aware when leaving our Websites or Services and to read the privacy statements of External Web Sites that collect your personal information.
We recognize the importance of protecting the privacy and safety of children. The Websites and Services are not intended for children under 13 years of age. We do not knowingly collect Personal Data from children under 13. Anyone under 13 should not use the Locus Services. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us as set forth below.
YOU AND WE AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR OUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.
Locus reserves the right to update or change this Privacy Statement from time to time. If Locus’s Privacy Statement is updated, we will notify you by posting the new Privacy Statement on this web page and updating the revision date below (and obtain your consent where required). Except where express consent is required by applicable law, Customer Agreements or End User License Agreements, your continued use of the Website and/or Services is deemed to be acceptance of any updates or changes we make to this Privacy Statement. Accordingly, we ask that you review the Privacy Statement periodically for any updates or changes that we may have made.
If you have any questions about this Privacy Statement or our privacy practices contact us at:
Locus Robotics Corporation
301 Ballardvale St.
Wilmington, MA 01887
Attn: Data Privacy
Email: privacy@locusrobotics.com