Privacy Statement – Empower

Track Group, Inc. (“Track Group”) is committed to protecting your privacy. This Statement of Privacy applies to Track Group’s IntelliTrack software system and smartphone application, Empower (collectively the “Track Group Products”) and governs data collection and usage. By using the Track Group Products, you consent to the data practices described in this statement.

Collection of your Personal Information

Some personal, identifiable information, such as your e-mail address, name, home or work address or telephone numbers will be inputted into the IntelliTrack software system by authorized personnel, if you agree to the service.

There is also information about your cell phone that is automatically collected by Track Group. This information can include: your location, phone operating system and phone version and is used by Track Group for the operation of the service and to maintain quality of the service. In addition Track Group collects your location data through the Empower app. All such personal and location data is known herein as “Personal Information.”

Use of your Personal Information

Track Group collects and uses your Personal Information to operate the Track Group Products and deliver the services you have requested. Track Group may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

Track Group does not sell, rent or lease its customer lists to third parties. Track Group does not use or disclose sensitive personal information, without your explicit consent.

Track Group web sites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Track Group or the site; (b) protect and defend the rights or property of Track Group; and, (c) act under exigent circumstances to protect the personal safety of users of Track Group, or the public.

Security of your Personal Information

Track Group secures your personal information from unauthorized access, use or disclosure. Track Group secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. 2

Changes to this Statement

Track Group will occasionally update this Statement of Privacy to reflect Company and customer feedback. Track Group encourages you to periodically review this Statement to be informed of how Track Group is protecting your information.

Contact Information

Track Group welcomes your comments regarding this Statement of Privacy. If you believe that Track Group has not adhered to this Statement, please contact Track Group at info@trackgrp.com. We will use commercially reasonable efforts to promptly determine and remedy the problem.