Privacy & Security Policy - Mooni US

Privacy Policy

Forward Industries, the authorized distributor of Mooni, is committed to keeping any and all personal information collected
of those individuals that visit our website and make use of our online facilities and services
accurate, confidential, secure and private. This privacy policy will inform you as to how we look
after your personal data when you visit our website (regardless of where you visit it from) and tell
you about your privacy rights and how the law protects you. Our privacy policy has been designed and
created to ensure those affiliated with Forward Industries (as defined below) of our commitment and realization of
our obligation to meet existing privacy standards.

THEREFORE, this Online Privacy Policy shall apply to Forward Industries and it shall
govern any and all data collection and usage thereof. Through the use of www.mooni.com/us, you are herein consenting to the following data procedures expressed within this privacy policy.

Table of Contents

Purpose of this Privacy Policy

This privacy policy aims to give you information on how Forward Industries collects and processes your personal
data through your use of this website, including any data you may provide through this website when
you sign up to our newsletter, pursue a career opportunity with Forward Industries or submit a “Connect With Us”
inquiry using our website.

Controller

Intelligent Product Solutions Inc. is the controller and responsible for your personal data
(collectively referred to as “Forward Industries,” “the company,” “we,” “us” or “our” in this privacy policy).

We have appointed a Sr. Director of IT who is responsible for overseeing questions in relation to
this privacy policy. If you have any questions about this privacy policy, including any requests to
exercise your legal rights, please contact the Sr. Director of IT using the details set out below.

Collection of Information

Personal data, or personal information, means any information about an individual from which that
person can be identified. It does not include information where the identity has been removed
(anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have
grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar
    identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and
    telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data,
    browser type and version, time zone setting and location, browser plug-in types and versions,
    operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website, products and
    services.
  • Marketing and Communications Data includes your preferences in receiving
    marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data could be derived from your personal data but is not considered
personal data by law as this data will not directly or indirectly reveal your
identity. For example, we may aggregate your Usage Data to calculate the percentage of users
accessing a specific website feature. However, if we combine or connect Aggregated Data with your
personal data so that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership, information about your health, genetic and
biometric data). Nor do we collect any information about criminal convictions and offenses.

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling
    in forms or by corresponding with us by postal mail, phone, email or otherwise. This includes
    personal data you provide when you:

    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • inquire and/or pursue a career opportunity using our website;
    • inquire about our services; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we
    will automatically collect Technical Data about your equipment, browsing actions and patterns. We
    collect this personal data by using cookies, web beacons, server logs and other similar
    technologies. We may also receive Technical Data about you if you visit other websites employing
    our cookies. See our Cookie Policy.
  • Third parties or publicly available sources. We will receive Technical Data
    about you from analytics providers such as Google.

Please rest assured that this website shall only collect personal information that you knowingly
and willingly provide by way of completed forms, and emails, or  information about the type of
browser you are using, IP address or type of operating system to assist us in providing and
maintaining superior quality service. It is the intent of this website to use personal information
only for the purpose for which it was requested and any additional uses specifically provided on
this website.

It is highly recommended and suggested that you review the privacy policies and statements of any
website you choose to use or frequent as a means to better understand the way in which other
websites garner, make use of and share information collected.

Use of Information Collected

We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your
    interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis
that we will rely on to process your personal data.

Note that we may process your personal data for more than one lawful basis depending on the
specific purpose for which we are using your data. Please contact us if you need details about the
specific legal basis we are relying on to process your personal data where more than one basis has
been set out in the table below. Generally, we do not rely on consent as a legal basis for
processing your personal data although we will get your consent before sending third party direct
marketing communications to you via email or text message. You have the right to withdraw consent to
marketing at any time by contacting us.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate
interest
To register you as a new contact, potential customer or partner of Forward Industries (a) Identity

(b) Contact

(a)  Performance of a contract with you

(b) Necessary for our legitimate interests (to keep our records updated and to grow our
business)

To register you as a recipient of the Forward Industries newsletter (a) Identity

(b) Contact

(c) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to keep our records updated, to grow our
business and to inform you of our marketing strategy)

To direct you to job openings and other related recruiting functions of Forward Industries (a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to keep our records updated and to grow our
business)

To manage our relationship with you which will include notifying you about
changes to our terms or privacy policy(ies)
(a) Identity

(b) Contact

Necessary to comply with a legal obligation
To administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of
data)
(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision
of administration and IT services, network security, to prevent fraud and in the context of a
business reorganization or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or
understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Usage
(d) Marketing and
Communications
(e) Technical
Necessary for our legitimate interests (to study how customers use our
products/services, to develop them, to grow our business and to inform you of our marketing
strategy)
To use data analytics to improve our website, products/services, marketing,
customer relationships and experiences
(a) Technical
(b) Usage
(c) Marketing and Communications
Necessary for our legitimate interests (to define types of customers for our
products services, to keep our website updated and relevant, to develop our business and to
inform you of our marketing strategy)
To make suggestions and recommendations to you about goods or services that may
be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Marketing
and Communications
Necessary for our legitimate interests (to develop our products/services and
grow our business)

Promotional Offers from Us

At times, we may find it necessary to use personal data as a means to keep you informed of other
possible products and/or services that may be available to you from https://intelligentproduct.solutions/. Forward Industries may also be in contact with you with
regards to completing surveys and/or research questionnaires related to your opinion of current or
potential future services that may be offered. You will receive marketing communications from us if
you have requested information from us or purchased goods or services from us and you have not opted
out of receiving that marketing.

Third-Party Marketing

Forward Industries does not now, nor will it in the future, sell, rent or lease any of our contact lists and/or
names to any third parties.

Forward Industries may feel it necessary, from time to time, to make contact with you on behalf of our external
business partners with regards to a potential new offer which may be of interest to you. We will get
your express opt-in consent before we share your personal data with any third party for marketing
purposes. You can ask us or third parties to stop sending you marketing messages at any time by
contacting us at any time pursuant to the Unsubscribe/Opt-Out procedure below.

Where you opt out of receiving these marketing messages, this will not apply to personal data
provided to us as a result of a product/service purchase, product/service experience or other
transaction(s).

Disclosures of Your Personal Data

Forward Industries may find it beneficial to share specific data with our trusted partners in an effort to conduct
statistical analysis, provide you with email, text messages and/or postal mail and/or deliver
support or otherwise for the purposes set out in the table above. Any third parties shall be
strictly prohibited from making use of your personal data, other than to deliver those services
which you requested, and as such they are thus required, in accordance with this privacy policy, to
maintain the strictest of confidentiality with regards to all your information. We may share your
personal data with Internal Third Parties (as set out in the Glossary) or
External Third Parties (as set out in the Glossary).

Forward Industries may deem it necessary to follow websites and/or pages that our users may frequent in an effort
to gleam what types of services and/or products may be the most popular to customers or the general
public.

Forward Industries may disclose your personal information, without prior notice to you, only if required to do so
in accordance with applicable laws and/or in a good faith belief that such action is deemed
necessary or is required in an effort to:

  • Remain in conformance with any decrees, laws and/or statutes or in an effort to comply with any
    process which may be served upon Forward Industries and/or our website;
  • Maintain, safeguard and/or preserve all the rights and/or property of Forward Industries; and
  • Perform under demanding conditions in an effort to safeguard the personal safety of users of https://intelligentproduct.solutions/ and/or the general public.

Forward Industries may also disclose your personal information to third parties to whom we may choose to sell,
transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other
businesses or merge with them. If a change happens to our business, then the new owners may use your
personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in
accordance with applicable law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with the
original purpose. If you wish to get an explanation as to how the processing for the new purpose is
compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.

International Transfers of Data from the European
Union

Forward Industries has its headquarters in the United States. Information we collect from you will be processed in
the United States. The United States has not sought or received a finding of “adequacy” from the
European Union under Article 45 of the General Data Protection Regulation (“GDPR”).
Forward Industries relies on certain derogations for specific situations as set forth in Article 49 of the GDPR. In
particular, Forward Industries collects and transfers to the United States personal data only: with your consent,
to perform a contract with you, or to fulfill a compelling legitimate interest of Forward Industries that does not
outweigh your rights and freedoms. Forward Industries endeavors to apply suitable safeguards to protect the privacy
and security of your personal data and to use it only consistent with your relationship with the
company and the practices described in this privacy policy. Forward Industries also enters into data processing
agreements and model clauses with its vendors whenever feasible and appropriate.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you,
and you fail to provide that data when requested, we may not be able to perform the contract we have
or are trying to enter into with you (for example, to provide you with goods or services). In this
case, we may have to cancel a product or service you have with us but we will notify you if this is
the case at the time.

Cookies

Please note that certain information about your computer hardware and software and browsing actions
and patterns may be collected by Forward Industries through automatic data collection technologies as you navigate
through and interact with Forward Industries’ website. This information is used by Forward Industries for operation of our website
and Forward Industries’ business, to maintain quality of the website and Forward Industries’ business, and to provide general
statistics regarding use of the Forward Industries website. The technologies we use for this automatic data
collection may include:

  • Cookies (or browser cookies). Unless you have adjusted your browser settings so
    that it will refuse cookies, our system will issue cookies when you direct your browser to our
    website. Please review this “Cookies” section and specifically the “Use of Cookies” subsection
    below for more information on cookies and how you can manage your cookies settings.
  • Flash cookies. Certain features of our website may use local stored objects (or
    Flash cookies) to collect and store information about your preferences and navigation to, from,
    and on our website. Flash cookies are not managed by the same browser settings as are used for
    browser cookies. For information about managing your privacy and security settings for Flash
    cookies, see the “Choices About How We Use and Disclose Your Information” subsection below.
  • Web Beacons. Pages of the website and our e-mails may contain small electronic
    files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs)
    that permit Forward Industries, 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).

Use of Cookies

The Forward Industries website uses “cookies” to help personalize your online experience. A cookie is a text file
that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or
deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a
web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The
purpose of a cookie is to tell the web server that you have returned to a specific page. For
example, if you visit certain Forward Industries pages, a cookie helps Forward Industries to recall your specific information on
subsequent visits. When you return to the same website, the information you previously provided can
be retrieved.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to
decline cookies if you prefer. Please see the “Choices About How We Use and Disclose Your
Information” subsection below for more information about managing your computer’s settings for
cookies.

Third-Party Use of Cookies and Other Tracking
Technologies

Some content or applications on the Forward Industries website are served by third parties, including servers,
content providers, 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 use our website. 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.

We do not control these third parties’ tracking technologies or how they may be used. If you have
any questions about an advertisement or other targeted content, you should contact the responsible
provider directly. For information about how you can opt out of receiving targeted advertising from
many providers, see the “Choices About How We Use and Disclose Your Information” subsection below.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. Certain
mechanisms are available to you on your browser settings that provide you with the following control
over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all
    or some browser cookies, or to alert you when websites set or access cookies. To learn how you can
    manage your Flash cookies settings, visit the Flash player settings page on Adobe’s website. If
    you disable or refuse cookies, please note that some parts of this website may become inaccessible
    or not function properly. For more information about the cookies we use, please see our Cookie Policy.
  • Promotional Offers from Forward Industries. If we have sent you a promotional email, you may
    send us a return email asking to be omitted from future email distributions.

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 NAI’s website.

Children Under the Age of 13

Forward Industries does not knowingly collect personal data from children under the age of thirteen
(13)
without verifiable parental consent. If it is determined that such information has
been inadvertently collected on anyone under the age of thirteen (13), we shall immediately take the
necessary steps to ensure that such information is deleted from our system’s database. Anyone under
the age of thirteen (13) must seek and obtain parent or guardian permission to use this website.

Unsubscribe or Opt-Out

All users and/or visitors to our website have the option to discontinue receiving communications
from us and/or reserve the right to discontinue receiving communications by way of email, text
messages or newsletters. To discontinue or unsubscribe to our website please send an email that you
wish to unsubscribe to mooni@forwardindustries.com. If you wish to
unsubscribe or opt-out from any third party websites, you must go to that specific website to
unsubscribe and/or opt-out.

Data Security

Forward Industries has put in place appropriate security measures and shall take every precaution to maintain
adequate physical, procedural and technical security with respect to our offices and information
storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure or
modification of the user’s personal information under our control. In addition, we limit access to
your personal data to those employees, agents, contractors and other third parties who have a
business need to know. They will only process your personal data on our instructions and they are
subject to a duty of confidentiality.

Forward Industries also uses Secure Socket Layer (SSL) for authentication and private communications in an effort
to build users’ trust and confidence in the internet and website use by providing simple and secure
access and communication of personal information.

We have put in place procedures to deal with any suspected personal data breach and will notify you
and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting
or reporting requirements. We may retain your personal data for a longer period in the event of a
complaint or if we reasonably believe there is a prospect of litigation in respect to our
relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and
sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of
your personal data, the purposes for which we process your personal data and whether we can achieve
those purposes through other means, and the applicable legal, regulatory, tax, accounting or other
requirements.

Details of retention periods for different aspects of your personal data are available in our
retention policy which you can request from us by contacting us.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your
personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in relation to your request
to speed up our response.

Time Limit To Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer
than a month if your request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.

Changes to Privacy Policy and Your Duty to Inform Us of
Changes

Forward Industries reserves the right to update and/or change the terms of our privacy policy, and as such we will
post those changes to our website homepage at https://intelligentproduct.solutions/,
so that our users and/or visitors are always aware of the type of information we collect, how it
will be used, and under what circumstances, if any, we may disclose such information. If at any
point in time Forward Industries decides to make use of any personal data on file, in a manner vastly different
from that which was stated when this information was initially collected, the user or users shall be
promptly notified by email. Users at that time shall have the option as to whether or not to permit
the use of their information in this separate manner.

We keep our privacy policy under regular review. This version was last updated on January 21, 2019.

It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.

Acceptance of Terms

Through the use of this website, you are hereby accepting the terms and conditions stipulated
within this privacy policy. If you are not in agreement with our terms and conditions, then you
should refrain from further use of our website. In addition, your continued use of our website
following the posting of any updates or changes to our terms and conditions shall mean that you are
in agreement and have accepted such changes.

How to Contact Us

If you have any questions or concerns regarding this privacy policy or our privacy practices,
please feel free to contact our Information Technology department at the following email, telephone
number or mailing address:

Mailing Address:

477 S. Rosemary Ave., Suite 219
West Palm Beach, Florida, USA
Email address: mooni@forwardindustries.com
Telephone number: (561) 465-0030

Glossary

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing
our business to enable us to give you the best service/product and the best and most secure
experience. We make sure we consider and balance any potential impact on you (both positive and
negative) and your rights before we process your personal data for our legitimate interests. We do
not use your personal data for activities where our interests are overridden by the impact on you
(unless we have your consent or are otherwise required or permitted to by law). You can obtain
further information about how we assess our legitimate interests against any potential impact on you
in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request before entering
into such a contract.

Comply with a legal obligation means processing your personal data where it is
necessary for compliance with a legal obligation that we are subject to.

Third Parties

Internal Third Parties are other companies in the Forward Industries company group acting as
joint controllers or processors and who are based in the United States and provide IT and system
administration services and undertake reporting.

External Third Parties are:

  • Service providers acting as processors based in the United States who provide IT and system
    administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers based in the United
    States who provide consultancy, banking, legal, insurance and accounting services.
  • Marketing providers, including public relations specialists, advertisers, and sales.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data
subject access request”)

This enables you to receive a copy of the personal data we hold about you and to check that we are
lawfully processing it.

Request correction of the personal data 

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data

This enables you to ask us to delete or remove personal data where there is no good reason for us
continuing to process it. You also have the right to ask us to delete or remove your personal data
where you have successfully exercised your right to object to processing (see below), where we may
have processed your information unlawfully or where we are required to erase your personal data to
comply with local law. Note, however, that we may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to you, if applicable, at the time of your
request.

Object to processing of your personal
data

In cases where we are relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to processing on this
ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to
object where we are processing your personal data for direct marketing purposes. In some cases, we
may demonstrate that we have compelling legitimate grounds to process your information which
override your rights and freedoms.

Request restriction of processing of your personal data

This enables you to ask us to suspend the processing of your personal data in the following
scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish,
    exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding
    legitimate grounds to use it.

Request the transfer of your personal data to you or to a third
party

We will provide to you, or a third party you have chosen, your personal data in a structured,
commonly used, machine-readable format. Note that this right only applies to automated information
which you initially provided consent for us to use or where we used the information to perform a
contract with you.

Withdraw consent

At any time where we are relying on consent to process your personal data. However, this will not
affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw
your consent, we may not be able to provide certain products or services to you. We will advise you if
this is the case at the time you withdraw your consent.

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