Privacy Policy

Effective Date: September 7, 2023

If you are a California resident, refer to Section 13 for more information about your specific privacy rights.

If you are a resident of the European Economic Area (including European Union Member States, Iceland, Liechtenstein, and Norway), Switzerland, or the UK, refer to Section 14 for more information about your specific privacy rights.

1. Introduction

Ungerboeck Systems International, LLC, including all its affiliated companies including but not limited to WeTrack Software Ltd. and Ungerboeck Systems International, GMBH (“Momentus”, “us,” “we,” or “our”) collects and processes information about you as described in this Privacy Policy. We are committed to protecting your privacy. This Privacy Policy contains details about how we collect, use, and share Personal Information that we obtain from and about you when you interact with us on our website, via email, and through other online and offline interactions. Please read this Privacy Policy carefully.

This Privacy Policy describes how we handle personal information that we collect in the following circumstances:

through our websites https://gomomentus.com/ or https://www.wetrack.com/ and any other digital properties that link to this Privacy Policy (the “Site”);
through the Momentus Technologies software platforms we provide pursuant to an order form or proposal (the “Platform”) where and to the extent we use your personal information for our own purposes (e.g., account creation);
through social media, our marketing activities, our live events and other activities described in this Privacy Policy, (collectively, the “Marketing Activities”).

This Privacy Policy does not apply to:

information that we process on behalf of our business customers while providing the Platform to them. We use personal information we receive from our business customers solely on the instructions of our business customers, as governed by our agreements with those business customers. If you have concerns regarding personal information that we process on behalf of a business, please direct your concerns to that business; and/or
information we obtain from third-party sources that does not constitute “personal information,” “personally identifiable information,” and/or “personal data” for the purposes of applicable The majority of data we receive from third-party sources in order to develop and enhance our Offerings does not constitute personal information, personally identifiable information, and/or personal data.

Our Platform and the Marketing Activities are designed for businesses and their representatives. We do not offer products or services for use by individuals for personal, family, or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as business representatives and not their individual capacities.

Momentus may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

2. Personal information we collect

Information you provide to us. Personal information you may provide to us through the Marketing Activities or otherwise may include:

Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
Professional information, such as your work history, city, state, country of residence, postal code, IP address, browser type, age and links to your profiles on social networks.
Communications that we exchange with you, including when you contact us through the Marketing Activities, social media, by phone or video platform or otherwise, and recordings of the same.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Payment information needed to complete transactions, including payment card information or bank account number.
Promotional information, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may obtain personal information about you falling within one or more of the categories identified above from third-party sources and we may combine that information with other information we have about you. For example, we may obtain personal information about you from:

Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
Private sources, such as our business customers, data providers/data licensors, information services, social media platforms and other third-party platforms/services that may be used to log into, or may otherwise be integrated with or connected to, the Marketing Activities, and other similar private sources.
Marketing partners, such as joint marketing partners and event co-sponsors.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Platform, our communications and other online services, such as:

Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Site, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Location data, such as city, state, and Country.

For more information concerning our automatic collection of data, please see our Cookies Policy.

3. How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery.

We may use your personal information to:

provide, operate, and improve this website, the Platform, and our business,;
enable security features of the Platform, such as by remembering devices from which you have previously logged in;
communicate with you about the Platform including by sending announcements, updates, security alerts, and support and administrative messages;
understand your needs and interests, and personalize your experience with the Platform and the Marketing Activities and our communications; and
provide support for the Platform, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, such as to analyze and improve the Platform and our business, including through the use of analytics. For example, we may use analytics in connection with the Site to understand user activity on the Site such as which pages are most and least visited and how visitors move around the Platform, as well as user interactions with our emails.

Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

Direct marketing. We may send our business customers and prospects direct marketing communications. You may opt-out of our marketing communications as described in Section 6 below.
Interest-based advertising. We and our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that we think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in our Cookies Policy.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated, or de-identified data from your personal information and other individuals whose personal information we collect. We may use this anonymous, aggregated, or de- identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service, develop new services, and promote our business.

4. Data retention

Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

5. How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Third parties that provide services on our behalf or help us operate the Platform or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research, and website analytics).

Payment processors. Any payment card information you use to make a purchase on the Platform is collected and processed directly by our payment processors.

Our business customers. We may enhance or supplement data we receive about you from a business customer with data we receive from other sources and provide the enhanced data back to such business customer. Our business customers may combine the personal information we share with other data they have and may process your personal information for their own purposes, including their own marketing and advertising purposes. This Privacy Policy does not apply to, and we are not responsible for, our business customers’ (or any other third party’s) processing of personal information. If you have questions concerning the processing of your information by one of our business customers, please contact the relevant business customer.

Advertising partners.

We may provide information regarding our business customers and prospects to third-party advertising companies for the internet-based advertising purposes described above.
We may also work with third-party advertising companies in connection with the provision of the Marketing Activities to our business customers to enable our business customers to target advertising. As noted, this Privacy Policy does not apply to, and we are not responsible for, our business customers’ or any third party’s processing of personal information.

Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Linked third-party services. If you log into the Platform with, or otherwise link or connect your account to, a social media, customer relationship management, or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Momentus or our affiliates (including, in connection with a bankruptcy or similar proceedings).

With your consent. We may share your personal information with any third parties where you have consented to such sharing.

6. Your choices

Access or update your information. If you have registered for an account with us through the Platform, you may review and update certain account information by logging into the account.

Opt-out of marketing communications. You may opt-out of marketing-related emails from us by following the opt-out or unsubscribe instructions at the bottom of the email or by contacting us, see Section 12. Please note that if you choose to opt-out of marketing- related emails, you may continue to receive service-related and other non-marketing emails. You may have the right to opt-out of receiving marketing or advertising calls, in which case you may do so during any such call or by contacting us, see Section 12.

Cookies. For information about cookies and other tracking technologies employed by the Platform and how to control them, including your choices with respect to interest-based advertising, see our Cookies Policy.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Platform through, or link or otherwise connect the Platform with, your social media account, customer relationship management platform or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us, see Section 12.

7. Other sites and services

The Platform and our Marketing Activities may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Functions of the “Twitter” or “X” service may be integrated into our Site. These features are offered by X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. When you use Twitter and the “Retweet” function, the websites you visit are connected to your X account and made known to other users. In doing so, data will also be transferred to X. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by X.
- For more information on X’s privacy policy, please go to https://twitter.com/privacy. Your privacy preferences with X can be modified in your account settings at https://twitter.com/account/settings .
Our Site may use plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited. If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO/GDPR. Further information about handling user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.
On our blog, we may publish various articles on relevant topics and allow you to make public comments. If you submit a comment, it will be published with the corresponding contribution and the (possibly pseudonymous) user name you entered will be displayed. Comments will not be reviewed before publication. However, we do check these on a random basis and can delete them if they contain unlawful content. The commenting function uses the Disqus plug-in, which is operated by Big Head Labs, , http://www.disqus.com (“Disqus”). As a registered user, you can use it to make comments on all Disqus-using websites and to log in to Facebook (via Facebook Connect), Twitter/X, Yahoo and OpenID via existing accounts. When registering via the latter providers, these providers also collect, store and use your data. For further details, please refer to the data protection regulations of the respective provider. Disqus will send us the data provided by the comment form as well as any data provided by third parties. The entity responsible for collecting and processing the above data in the United States is Big Head Labs, Inc, San Francisco, USA.

- Terms of Use: http://help.disqus.com/customer/portal/articles/466260-terms-of-service/
- Privacy Policy: http://help.disqus.com/customer/portal/articles/466259-privacy-policy

This website may use various Google Services, provided or operated by the following party responsible: If you are located within the EU or Switzerland the party responsible for the services provided is Google Ireland Limited
(“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. If you are located outside the EU the party responsible for the services provided is Google LLC. (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

This website may use Google Analytics, a web analytics service. Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google Analytics cookies are stored based on Art. 6 (1) (f) DSGVO/GDPR. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising.
This website may use Third-party information: Jobvite, Inc.1300 S El Camino Real, Ste 400 San Mateo, CA 94402, United States;
- Privacy policy: https://jobvite.com/privacy-policy/
This website may use Zendesk. Third-party information: Zendesk, Inc.1019 Market Street, San Francisco, CA 94103, United States;
- Privacy policy: https://zendesk.com/company/customers- partners/privacy-policy/

8. Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

9. International Data Transfer

We are headquartered in the United States and may use service providers or affiliates that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

For more information on how we transfer personal information from the European Economic Area, United Kingdom, and Switzerland, please see the European Notice in Section 14.

10. Children

The Platform and our Marketing Activities not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us, see Section 12. If we learn that we have collected personal information through the Platform or our Marketing Activities from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

11. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Website, the Platform or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Platform and/or this Website after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

12. How to contact us

Email: privacy@gomomentus.com
Mail: Ungerboeck Systems International, LLC
100 Ungerboeck Park, O’Fallon, MO 63368 United States

13. California Privacy Rights Notice

This section describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, (“CPRA”) and their rights with respect to that Personal Information. For purposes of this section, the term “Personal Information” has the meaning given in the CPRA but does not include information exempted from the scope of the CPRA. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

Your California privacy rights. California residents have the rights listed below under the CPRA with respect to their Personal Information. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with which we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
Access. You can request a copy of the Personal Information that we have collected about you.
Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-out.
- Opt-out of certain processing of Personal Information for targeted advertising purposes. You can opt-out of certain processing of personal information for targeted advertising purposes.
- Opt-out of other sales of personal data. You can opt-out of other sales of your Personal Information.
Opt-in. As the Services are intended for users 18 years of age or older, we do not intentionally collect or sell Personal Information regarding individuals between the ages of 13 and 15.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CPRA.

Exercising your right to information/know, access, correction and deletion. You may submit requests to exercise your right to information/know, access, correction or deletion at Privacy@gomomentus.com

Notice of right to opt-out of the “sale” or “sharing” of your Personal Information. Certain data sharing we engage in may be classified under California law as a “sale” or “sharing” of your Personal Information. You can request to opt-out out of this “sale” or “sharing” of your personal information here: via email at: Privacy@gomomentus.com

Verification of identity; authorized agents. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity to process your information/know, access, correction and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require government identification, a declaration under penalty of perjury or other information.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CPRA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.

Financial Incentives. We may offer financial incentives as permitted by the CPRA. These incentives may result in different prices, rates, levels, or quality of services. The terms and conditions of any such financial incentive shall be provided separately to you at the time of the offering.

Personal information that we collect, use and disclose. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CPRA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. The terms in the chart refer to the categories of information, sources, purposes and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. In addition to the disclosures described in the chart below, we disclose Personal Information as described in Section 5, above.

Statutory category / Personal information we collect in this category

Source of PI

Business / commercial purpose for collection

Categories of third parties to whom we “disclose” PI for a business purpose

Categories of third parties to whom we “sell” or “share” PI

Identifiers

Contact data Professional information Device data

Third-party sources Automatic data collection

Service delivery Research and development Compliance and protection With your consent

To create anonymous, aggregated or de- identified data

Affiliates

Service providers Customers Advertising partners

Business and marketing partners

Linked third-party services

Professional advisors Authorities and others Business transferees With your consent

Customers

Statutory category / Personal information we collect in this category	Source of PI	Business / commercial purpose for collection	Categories of third parties to whom we “disclose” PI for a business purpose	Categories of third parties to whom we “sell” or “share” PI
Inferences May be derived from: Contact data Professional information Communications Transactional data Marketing data Promotional information Device data Online activity data	Third-party sources Automatic data collection	Service delivery Research and development Marketing and advertising Compliance and protection With your consent To create anonymous, aggregated or de- identified data	Affiliates Service providers Customers Advertising partners Business and marketing partners Authorities and others Business transferees With your consent	Customers
Internet or other electronic network activity information Marketing data Device data Online activity data Location data	Automatic data collection Third-party sources	Service delivery Research and development Compliance and protection With your consent To create anonymous, aggregated or de- identified data	Affiliates Service providers Customers Authorities and others Business transferees With your consent	Customers
Geolocation data Location data	Automatic data collection Third-party sources	Service delivery Research and development Marketing and advertising Compliance and protection With your consent To create anonymous, aggregated or de- identified data	Affiliates Service providers Customers Advertising partners Business and marketing partners Linked third-party services Authorities and others Business transferees With your consent	Customers

Statutory category / Personal information we collect in this category

Source of PI

Business / commercial purpose for collection

Categories of third parties to whom we “disclose” PI for a business purpose

Categories of third parties to whom we “sell” or “share” PI

Professional or Employment Information

Professional information

Third-party sources

Service delivery Research and development Compliance and protection

With your consent

To create anonymous, aggregated or de- identified data

Affiliates

Service providers Customers

Linked third-party services

Authorities and others Business transferees With your consent

Customers

14. European Notice

The information provided in this European Notice section applies only to individuals in the United Kingdom (“UK”), Switzerland, and the European Economic Area (“EEA”) (hereafter collectively referred to as “Europe”).

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation, including the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”) and the EU GDPR as it forms part of UK law (“UK GDPR”)). Under the GDPR, personal data is information about an individual, from which that individual is either directly identified or can be identified. It does not include ‘anonymous data’ (i.e., information where the identity of the relevant individual has been permanently removed and that individual is no longer identified or identifiable).

Our GDPR Representatives. For users in the EEA or UK, our representatives appointed under the EU GDPR and UK GDPR respectively are:

EU representative:

Ken Bell, CISO

Matt Epps, General Counsel

Inquiries: privacy@gomomentus.com

UK representative:

Ken Bell, CISO

Matt Epps, General Counsel

Inquiries: privacy@gomomentus.com

Legal bases for processing. We use your personal information for the purposes listed below. In respect of each of the purposes for which we use your personal information, European data protection legislation requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).

Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).

We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information.

Processing purpose	Categories of personal information involved	Legal basis
Service delivery	Contact data Professional information Account data Communications Transactional data Payment information Device data Online activity data	Contractual Necessity Legitimate Interests Consent
Research and development Marketing and advertising purposes Compliance and protection purposes Sharing your personal information as described in this Privacy Policy	Contact data Professional information Account data Communications Transactional data Payment information Marketing data Promotional information Device data Online activity data	Contractual Necessity Legitimate Interests Consent
To comply with applicable law	Any data relevant to comply with applicable law	Compliance with Law
With your consent	Any data for which we are required to obtain consent by applicable law	Consent

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention. We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.

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

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Services, or otherwise to us.

If you provide us with any sensitive personal information to us when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Services.

Your rights. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Provide you with information about our processing of your personal information and give you access to your personal information.
Update or correct inaccuracies in your personal information.
Delete your personal information.
Transfer a machine-readable copy of your personal information to you or a third party of your choice.
Restrict the processing of your personal information.
Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
Consent withdrawal. Where we rely on your consent and/or explicit consent to process your personal information you may withdraw that consent at any time.

You may submit these requests by email to Privacy@gomomentus.com or our postal address provided in Section 12. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Cross-border data transfer. We may share your personal information with third parties or affiliates who are based outside Europe. In such circumstances, those parties’ processing of your personal information will involve a transfer your personal information outside of Europe.

We endeavor to ensure that people to whom we provide your personal information hold it subject to the standards required by European data protection legislation. So, whenever we transfer your personal information out of Europe, we try to ensure a similar degree of protection is afforded to it by making sure at least one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal data by the European Commission or UK Government (as and where applicable) from time to time.
Transfers to territories without an adequacy decision.
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide an adequate level of protection for Personal Data by the European Commission or UK Government (as and where applicable).
- What this means is that the relevant authority(ies) have not adopted an ‘adequacy decision’ to confirm that the relevant laws and practices in that country or territory are sufficient to ensure an adequate level of protection for personal data to the standards required by the GDPR – for example, there is currently no such decision in respect of the United States.
- However, in these cases:
  - we may use specific appropriate safeguards approved by the European Commission, the UK Information Commissioner’s Office or UK Government (as and where applicable), which are designed to give personal information the same protection it has in Europe – for example, requiring the recipient of personal information to enter into the relevant form of the so-called ‘Standard Contractual Clauses’ issued or approved from time to time; or
  - in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that

You may contact us using the details under Section 12 if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

Cookie Policy

Notice last updated: September 7, 2023

1. Information on how we use cookies

This Cookies Policy describes the various cookies and similar technologies that Ungerboeck Systems International, LLC, including all its affiliated companies including but not limited to WeTrack Software Ltd. and Ungerboeck Systems International, GMBH (“Momentus,” “we“, “us” or “our“) uses on https://gomomentus.com/ or https://www.wetrack.com/ (“Website,” or “Site”) which allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

We use cookies to provide the content and functionality of this Site (strictly necessary cookies) and, with your permission, to personalize the content and advertisements that appear when you visit our site and to analyze the traffic on the site. In addition, we share information about your use of our site with our advertising partners and analysts, who may combine this information with other data that you provide to them or that they have collected when you use their services. You have the right to withdraw your consent at any time.

You do not need to allow cookies to visit most of the Website. However, enabling cookies may allow for a more tailored browsing experience and is required for certain parts of the Website to work. In the majority of cases, a cookie does not provide us with any of your personal information.

For further information about this Cookies Policy, please contact us at privacy@gomomentus.com

If you are in the European Economic Area (“EEA”) or the United Kingdom (“UK”), you can change the cookie settings that will be placed when you visit our website by changing the settings on your browser or by visiting the Cookie Preference Centre by clicking on the cookie button at the bottom of this policy or on any page on our website. If you are outside the EEA or the UK, you can delete, block or disable cookies via your browser (see ‘Changing your cookie settings’ below).

Key Concepts

First-party cookies are those set by a website that is being visited by the user at the time (e.g. cookies placed by www.gomomentus.com).

Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website, this would be a third-party cookie.

Persistent cookies are cookies that remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.

Session cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

2. Other technologies

In addition to cookies, our Sites and Apps may use other technologies to collect information automatically, such as:

Browser Web Storage. We may use browser web storage (including via HTML5), also known as locally stored objects (“LSOs”), for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than Your web browser may provide functionality to clear your browser web storage.
Flash We may use Flash cookies (which are also known as Flash Local Shared Object (“Flash LSOs”)) on our Sites to collect and store information about your use of our Sites. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash LSOs stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Sites.
Web Beacons. We may also use web beacons (which are also known as pixel tags and clear GIFs) on our Sites and in our HTML formatted emails to track the actions of users on our Sites and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Sites, so that we can manage our content more effectively.

3. Changing your cookie settings

You can change your cookie preferences when you visit our website by clicking on the floating cookie on the page. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access all or parts of our site.

Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. In order to understand these settings, the following links may be helpful.

Otherwise you should use the ‘Help’ option in your internet browser for more details:

Cookie settings in Internet Explorer / Microsoft Edge - https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11- 0753-043d-7c16-ede5947fc64d
Cookie settings in Firefox - https://support.mozilla.org/en-US/kb/cookies-information- websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies
Cookie settings in Chrome - https://support.google.com/chrome/answer/95647?hl=en
Cookie settings in Safari - https://support.apple.com/en-us/HT201265

You can limit our use of your information for interest-based advertising by:

Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the website may not work properly. For more information about cookies, including how to manage and delete cookies on your device, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of the website. For example, we may not be able to recognize your computer and you may need to log in every time you visit the website.

Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug- ins, you may be able to block certain tracking technologies.
Platform settings. You can opt-out of interest-based advertising through certain third parties by using such third party’s opt-out tool or by otherwise contacting such third For example, Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:
- Google: https://adssettings.google.com/
- Facebook: https://facebook.com/about/ads

Ad industry tools. You may opt out of interest-based ads from companies participating in the following industry opt-out programs:
- Network Advertising
  Initiative: http://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance: https://optout.aboutads.info/?c=2&lang=EN.

You will need to apply these opt-out settings on each device from which you wish to opt- out.

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

4. Your consent

Strictly necessary cookies do not require your consent.

For performance, functional and targeting cookies, we request your consent before placing them on your device if you are in the EEA or UK. You can give your consent by clicking on the appropriate button on the banner displayed to you, or by going to the Cookie Preference Centre.

5. Can I withdraw my consent?

If you do not wish to give consent or wish to withdraw your consent to any performance, functionality or targeting cookies at any time, you will need to delete, and block or disable cookies via your browser settings; see below for more information on how to do this or by changing your settings in the Cookie Preference Centre. Please note that disabling these cookies may affect the functionality of the website and may prevent you from being able to access certain features on the website.

6. What cookies do we use and why?

We use “strictly necessary”, “performance”, “functional” and “targeting” cookies:

6.1 Strictly Necessary cookies:

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

We use these strictly necessary cookies to identify you as being logged in to the website and to authenticate you, to make sure you connect to the right service on the website when we make any changes to the way it works and for security purposes.

6.2 Performance cookies:

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site and gather information on error messages. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

We use performance cookies to perform web analytics and for error management purposes, by measuring any errors that may occur.

6.3 Functional cookies:

These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

We use functional cookies to enable us to provide you with enhanced functionality and personalization. These cookies may be set by third party providers whose services we have added to our pages.

6.4 Targeting cookies:

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

7. Retention

A cookie or similar technology will exist for different periods of time depending on the purpose of the cookie. For example, a session cookie which enables the website to operate will only exist on your device whilst you browse our website, but other cookies will remain on your device for longer such as some functionality cookies which need to stay on your device so that the website can recognise you when you return. For more information about how long a cookie remains on your device, please see the cookie table below.

8. Keeping our Cookies Policy up to date

We may need to update our Cookies Policy from time to time if we decide to use cookies differently. Any changes will be updated here.

For more information about how we process personal data collected from cookies please refer to our website Privacy Policy.

If you have any questions or would like more information about the ways we use cookies please contact us at privacy@gomomentus.com