PRIVACY NOTICE

1. About This Notice

This Privacy Notice explains how Smart Retail, LLC, a limited liability company formed in Delaware (“Company,” “we,” “us,” or “our”), processes information in connection with https://smartretail.group (the “Website”). The Website provides general institutional information about the Company.

2. Who Operates the Website

The Website is operated by Smart Retail, LLC from the United States. The Company’s subsidiaries and affiliated companies are separate legal entities and do not operate this Website merely because they are owned by or affiliated with the Company.

3. Information We Process

Information you do not submit through the current Website

The current Website does not provide forms, user accounts, newsletter subscriptions, chat, comments, job applications, gated downloads or a public email address. You therefore cannot intentionally submit personal information through those features on the current Website.

Technical information processed automatically

When you request a webpage, our hosting, content-delivery and security providers may automatically process limited technical information necessary to deliver, maintain and protect the Website. Depending on the production configuration, this information may include:

• Internet Protocol (IP) address and approximate network location;
• browser type, device type, operating system and language settings;
• date and time of a request;
• requested page, referring page or URL, and response status;
• security, fraud-prevention, bot-detection and diagnostic events; and

We do not use the current Website to create user accounts, identify named visitors or collect information through optional analytics tools. Technical records can nevertheless constitute personal information under some laws and are described here for transparency.

4. Cookies and Similar Technologies

The current Website does not use optional analytics cookies, advertising cookies, session-replay tools or behavioral-advertising technologies. The Website or its infrastructure providers may use strictly necessary cookies, local storage or similar technologies only if required to deliver, secure or balance Website traffic. Before publication, the Company will confirm the production cookie and browser-storage inventory and update this section if necessary.

5. How We Use Technical Information

We use limited technical information to:

• deliver the Website and requested content;
• maintain availability, performance and reliability;
• detect, investigate and prevent security incidents, malicious activity, fraud and abuse;
• diagnose errors and protect our systems and providers;
• comply with law, enforce our rights and respond to lawful requests; and
• maintain records reasonably necessary for the purposes above.

6. Sources of Information

We receive technical information automatically from your browser or device and from the hosting, content-delivery, network and security providers that support the Website.

7. How We Disclose Information

We may disclose limited technical information to:

• service providers that host, deliver, maintain, monitor or secure the Website, subject to appropriate contractual restrictions;
• professional advisers, auditors, insurers and authorities when reasonably necessary for legal, security or compliance purposes;
• a successor or potential successor in connection with a proposed or completed merger, financing, reorganization, sale of assets or similar corporate transaction, subject to appropriate safeguards; and
• other parties when required by law, legal process or a valid governmental request, or when reasonably necessary to protect rights, safety and security.

Under the Website’s current approved configuration, Mexican subsidiaries, Mexican personnel and Mexican systems do not receive Website visitor information and do not determine how it is used. This statement must be revised before any such access or transfer begins.

All service providers receiving personal information are contractually required to process such information only for legitimate business purposes and subject to appropriate confidentiality and security obligations.

8. Sale, Sharing and Behavioral Advertising

We do not sell personal information collected through the current Website. We do not share personal information through the current Website for cross-context behavioral advertising or use the Website to serve targeted advertising. These statements must be reverified before any analytics, advertising, social-media or embedded-content technology is enabled.

9. Browser Privacy Signals

The current Website does not use technology to track visitors over time and across third-party websites for behavioral advertising. Because we do not engage in that activity, the Website does not currently respond differently to legacy “Do Not Track” signals. If we later engage in a practice subject to a legally recognized opt-out preference signal, such as the Global Privacy Control, we will configure the Website to process that signal as required by applicable law.

10. Retention

We retain technical and security information only for as long as reasonably necessary to deliver, secure, maintain and troubleshoot the Website, comply with applicable law, and establish or defend legal claims. The retention period is determined by the type of log, its operational or security purpose, and applicable legal requirements.

11. Security

We use administrative, technical and physical safeguards designed to protect information processed in connection with the Website. No method of transmission, storage or security is completely secure, and we cannot guarantee absolute security.

12. Children

The Website is a general corporate information site and is not directed to children under 13. We do not knowingly collect personal information online from children under 13 through the current Website. If we learn that such information has been collected, we will take reasonable steps to delete it as appropriate.

13. Third-Party Links

The Website may link to websites operated by third parties, including subsidiaries or portfolio companies. We do not control those websites or their privacy practices. Review the privacy notice of any third-party website you visit.

14. International Visitors

The Website is operated from the United States. If you access the Website from another country, limited technical information may be processed in the United States and in other locations where our service providers operate. Access from another country does not change the identity of the Website operator described above.

15. Changes to This Notice

We may update this Privacy Notice to reflect changes in the Website, our practices or applicable requirements. We will post the updated Notice on this page and revise the Last Updated date. We will provide additional notice when required by applicable law.

16. Privacy Rights and Requests

Depending on your jurisdiction, you may have privacy rights regarding personal information, including rights to access, correct, delete or obtain information about how personal information is processed. To submit a privacy-related inquiry or request, contact:

Smart Retail, LLC
Privacy Officer
privacy@smartretail.group

We may request information reasonably necessary to verify the identity of the requestor before responding.

17. Security Incidents

If the Company becomes aware of a security incident involving personal information that requires notification under applicable law, notice will be provided in accordance with applicable legal requirements.

18. Contact Us

Questions regarding this Privacy Notice may be directed to:

Smart Retail, LLC
Privacy Officer
privacy@smartretail.group