Effective date: April 29, 2022
Policy number: 1.3

Valet Market Privacy Policy

The following terms (“Privacy Policy”, “Policy”) describes how Accel Robotics Corporation and its affiliates (collectively “Accel,” “we,” “us”) collect, use, disclose, store, transfer, and generally process our customers’ (“Shoppers”, “you”) information obtained from the use of the Accel Robotics website, Valet Market website, Valet Market Mobile Application (“App”), and Valet Market physical shopping locations (“Store(s)”) (collectively, “Accel Services”).

By either agreeing to these terms explicitly or by using or otherwise accessing any of the above defined Accel Services, you hereby acknowledge that the following Policy applies to you and you consent to and authorize the data collection, retention, and use policies explained below. Moreover, your use of Accel Services is also governed by our Terms and Conditions.

About Accel Robotics

Accel Robotics Corporation is a Delaware-based corporation with its headquarters in San Diego, California and offices located at 9160 Kearny Villa Court. The Valet Market website, App and the Accel System (as defined in our Terms and Conditions) in Stores are the sole property of Accel Robotics Corporation and are offered to you under license by Accel Robotics Retail LLC, a wholly-owned subsidiary of Accel Robotics Corporation.

Our approach to personal information integrity

Accel places an absolute priority on securing your personal information (“PI”, “Data”) and limiting its use to what is essential for us to improve our product and provide you with the best customer experience that we can. Accordingly, we strive to implement industry standard PI collection and protection protocols.

Please note that we do not sell any information that you provide, directly or indirectly, to third-parties for marketing purposes. All personal information provided to us, to the extent it is shared outside of Accel, is solely for the purpose of providing Accel Services.

Information that we collect about you

Accel Robotics collects three types of information about you in order to provide our Accel Services. The first type is information that you provide directly to us. The second type is information that we indirectly collect about you through your general use of Accel Services. The third type is information we receive about you from third-parties. Each of those is described in detail below as are the individual categories of information collected under each method.

  • Information that you provide: There are certain categories of information that you provide directly to us. For example, when you create an account or update your account, you directly provide us with information that we use to provide Accel Services. While certain categories of information are optional (see below at Information that you provide), other information is required as necessary for us to be able to serve you.
  • Information we collect from your use of Accel Services: Our Services are a combination of physical stores, sensors, and cameras; cloud-based machine learning and Artificial Intelligence components; and traditional human observation. When you use Accel Services in any form, whether accessing a Store in-person or through the App to purchase products (“Shopping Session”), we automatically collect information about you. See below at Information that we collect from your use of Accel Services for the categories of information collected through your use of our Services.
  • Information collected from third-party sources: In very limited circumstances, we collect and retain information about you from third-party service providers. This type of information is used to provide you with access to Accel Services. Please see below at Information collected from third-party sources to learn more.

Information that you provide

When you create an account to access Accel Services (“Shopper Account”, “Account”) or otherwise communicate directly with us about your Account, you provide us with the following information:

  • Name (first and last)
  • E-mail address (which is optional if you choose to provide it to us during Account creation)
  • Mobile phone number
  • Your physical address including unit number
  • Customer support inquiries and substance of those communications

Information that we collect from your use of Accel Services

As explained above, you interact with numerous sources of Data collection when you use or access Accel Services. Information is collected both from the App and from within Stores. The following is the information we collect from those sources:

From a Shopping Session:

  • Time of scanning of your unique QR code
  • The times at which you enter and exit a Store
  • The time at which we deliver your receipt to you
  • Selected payment method
  • Store identification
  • Shopper trajectory within a Store
  • Physical movements (consisting of when you remove or replace individual items within a Store)
  • Images and/or videos

Information collected from third-party sources

As explicitly stated, the extent of information collected about you from third-party service providers is extremely limited and consists of the following:

  • Identification number provided by Square, Inc. (our third-party service provider for all transactions)
  • Order numbers automatically generated from each Shopping Session consisting of total value of purchased items, an itemized list of purchased items, and total sales tax applied to each item (created and furnished to us by Square, Inc.)

Information collected about non-registered shoppers

Individuals accessing Store locations who have Shopper Accounts are permitting to extend access to friends, family members, and/or colleagues (“Guests”). We still collect information about your Guests, regardless of whether they themselves have created and maintain Shopper Accounts.

Guests are admitted using your unique QR code and any personal information that they create is associated with your account. Moreover, categories of information collected about Guests and identified in this Policy, namely video and/or image information, shall be stored and otherwise used according to these terms. Please see our Terms and Conditions to learn more about how to admit Guests.

How Accel uses and shares your personal information

Our goal is to provide you with the best customer service possible in your use of Accel Services. Importantly, we do not sell your information to third-parties for any direct or indirect marketing activities. Below are the enumerated ways in which we use information collected about you:

  • Delivering Accel Services as described in our Terms and Conditions including, but not limited to, processing all purchases, payments, and deliveries ordered or requested through the app; communicating with you about those orders; and promotional offers.
  • To communicate with you for any reason, including but not limited to: responding to your technical support inquiries, our direct marketing efforts, notices or disclosures about your account specifically or our services generally, and customer satisfaction surveys.
  • Developing new products or services.
  • Improving, refining, or correcting any errors within existing services.
  • Conducting internal research (consisting of tracking, analysing, and measuring aggregate shopper behavior).
  • Disclosure made to our third-party service providers in order to deliver, improve, market, and maintain Accel Services.
  • In certain cases, we may be required to make disclosures in response to a lawful court order or validly submitted request by a pertinent governmental agency.
  • Additionally, in circumstances where we believe that disclosure is required to establish, defend, or exercise our legal rights under our Terms and Conditions or otherwise, we reserve the right to disclose information about you required to do so.
  • Accel Robotics transfers to a third party the personal information of a consumer or consumers in the course of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business. In such an event, your information will continue to be collected, managed, and used according to this Policy and, should the third-party seek changes to the manner in which that information is collected, used or shared, you will be afforded notice and an opportunity to consent to those changes.
  • We may otherwise disclose information collected and retained about you with your consent.

How long we retain information about you

Generally speaking, we keep information about you for only as long as is required to provide you with Accel Services, further our business needs, or as required by law. The length of time for which we retain certain categories of information is not defined as it assists us with the continued refinement of our product and delivery of Accel Services. However, certain categories of information are held for a defined duration:

  • Images and/or videos from Store locations are retained for 14 days
  • Specific shelf video images are retained for up to six (6) months
  • Position tracking information is retained for up to six (6) months

If you have any questions about the length of time information is held about you, please contact us using the “Contact Information” at the end of this Policy.

Additional information about Cookies

We use various tracking tools made available by third-parties in order to more effectively target our services, refine our products and marketing campaigns, and tailor our product offerings. These third-party tracking tools are deployed on our Website and within our native mobile applications, made available through Google Play and the Apple App Store.  You can learn more about Cookies and how we deploy them through our Cookie Policy, which is incorporated by reference.

If you would like to know more about Google Analytics, please visit this website on "How Google uses data when you use our partners’ sites or apps."

Options available to you about your information

As explained above, you have the option to withhold from us certain information that is not critical to Accel Services. You have the option of editing or correcting any information that you provide to us through management of your Account. Moreover, you have the option of declining to receive marketing and promotional services about Accel Services using the “unsubscribe” link contained in any such marketing communication.

Finally, you may deactivate your Shopping Account in the manner prescribed in our Terms and Conditions. However, if you choose to do so, we are under no obligation to delete, remove, or otherwise destroy any information we collected about you during the existence of your Account unless as set forth in this Policy or as required by law.

Rights of California Residents

If you are a California resident, you have certain rights afforded to you by the California Consumer Protection Act (CCPA). It affords California residents with certains rights and protections including the right to know what personal information has been collected, disclosed, or sold to third-parties for their direct marketing purposes over the preceding twelve (12) months. As noted above, we do not share or sell (as defined by the CCPA) your information to third-parties for others’ direct marketing purposes or for any other purpose. These rights are enumerated below.

  • The right to know the categories of information collected and the purposes for which the categories of information are collected or used. Further, consumers have the right to know for how long each category of information is retained. If you would like to know this information, please email us at privacy@valetmarket.com.
  • The right to request that a business delete any personal information about the consumer which the business has collected from the consumer. If you have questions or would like to initiate a process to delete your information, please email us at privacy@valetmarket.com or fill out this form.
  • The right to opt-out of the sale or sharing of personal information. Please note, as explicitly stated above, that Accel Robotics does not sell or otherwise share your personal information as defined by the CCPA. Accordingly, in the twelve (12) months prior to the effective date of this Policy, Accel Robotics has not sold any information about its shoppers as defined by CCPA.
  • Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights. Accel Robotics will not discriminate against any individual for exercising any of their rights herein described.

If you or your authorized agent seeks information or to take action under any of the rights enumerated above, please contact us using the contact information below. In your inquiry, please include “California Privacy Rights” in the subject line and, in the body of the email, include the following information to enable us to validate your identity and your request: User ID. The User ID can be found by accessing your “Profile” through the App.

How we secure information collected about you

We have implemented commercially reasonable security measures such as anonymizing data, encrypting hard drives, installing firewalls on all development hardware and drives.

that store video, and adhering to best practices for Linux. We also follow generally accepted industry standards such as the use of 256-bit encryption, SSL and SSH protocols, and password protected logins on servers and local drives to protect personally identifiable information that we store as well as collect, both during transmission and afterwards.

However, despite our efforts to maintain the confidentiality and security of your information, no method of transmission over the Internet and no method of electronic storage is completely secure. Although we make every effort to protect your personal information, we cannot guarantee its absolute security.

Children

We are committed to protecting the privacy of children. In furtherance of this commitment, we restrict the use of our Website to persons eighteen (18) years of age or older. We do not knowingly or intentionally collect personal information from children under the age of thirteen (13).

As set forth in our Terms and Conditions, we will take immediate action should we independently discover or it is brought to our attention that an individual who is not eighteen (18) years of age has created a Shopper Account.

International Data Transfer

If you are accessing this Website from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that your personal information will be transferred to, stored, and processed in the United States.

If we are transferring personal information out of the European Union, please be advised that we will take such measures as are necessary to ensure that the transfer is in compliance with the EU General Data Protection Regulation (Regulation 2016/679 also known as the “GDPR”), including but not limited to transferring the personal data to a recipient in the United States that has certified compliance under EU approved Standard Contractual Clauses (SCCs) or to a recipient that has executed SCC adopted or approved by the European Commission. Moreover, in the event we do not have in place SCC to allow such transfer, we will seek your consent prior to said transfer.

We acknowledge and agree that we are liable for all onward data transfers.

Amendments to this Policy

We may amend this Policy at any time at our sole discretion and without prior notice. If we make any material amendments, we will advise you about those changes by notifying you in a prominent place on our Website, in the App, or through a direct communication with you. You should check back with us from time to time in order to confirm that there have been no significant changes.

Please note that the use of information that we gather is subject to the Policy then in effect at the time of use.

Contact

If you have any questions or concerns over this Privacy Policy or if you need further information regarding the access to your personal information, or how your personal information is used, you may contact us as listed below:

Attn.: General Counsel
Accel Robotics Corporation
9160 Kearny Villa Court San Diego, CA 92123
privacy@valetmarket.com