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SpartanLync X23 Manager — Privacy Policy

Effective date: July 28, 2026

This Privacy Policy explains how SpartanLync Technologies Corp. ("SpartanLync", "we", "us") handles information in connection with the SpartanLync X23 Manager ("X23-Mgr", the "App") for iOS, Android, Windows and macOS. It supplements the general SpartanLync Privacy Policy and, where they differ, this document governs the X23-Mgr App.

The X23-Mgr App is a fleet sensor-monitoring tool. When you are not signed in, the App works entirely on your own device — the only information it sends off the device is a check to confirm whether the SpartanLync service is reachable, so it can notify you if the service is temporarily inaccessible. No personal or vehicle data leaves your device unless and until you sign in and choose to use the authenticated Fleet-Share feature described below.

Section 1 — Data controller and contact

The controller responsible for the processing of personal data in connection with the X23-Mgr App is:

SpartanLync Technologies Corp.

Burlington, Ontario, Canada

Email: support@spartanlync.com

If you have questions about this Policy or your data, contact us at the address above.

Section 2 — Your rights

Subject to applicable law, you have the following rights regarding your personal data:

• Right to information;
• Right to rectification or erasure;
• Right to restriction of processing;
• Right to object to processing;
• Right to data portability.

You also have the right to lodge a complaint with a data-protection supervisory authority. To exercise any of these rights, contact us at support@spartanlync.com.

Section 3 — Information the App collects on your device

To perform its function, the X23-Mgr App stores the following on your device (and, when signed out, nowhere else):

• App configuration and preferences — Fleet and Group organization,

 vehicle (Train) layouts, sensor assignments, TPMS / TempTrac / Door
 configuration, and display preferences.

• Sensor and vehicle data read from GwNode hardware — see Section 4.
• Cached history — GwNode Logs, Statistics and real-time Alerts/Status

 are cached locally so the App works without connectivity.

When you are signed out, this information remains only on your device and is never shared off the device, except for the service-availability check noted above. Uninstalling the App removes this locally-stored data; on Desktop, the uninstaller also removes the App's configuration.

Device permissions the App requests:

• Bluetooth — to establish the J1939 link to GwNode hardware on phones

 and tablets.

• Location — on Android, the operating system requires location

 permission in order to perform Bluetooth (BLE) scanning. The App uses this
 permission solely to discover nearby GwNode Trains. The X23-Mgr App
 does not track, collect or store your device's GPS location, and
 contains no code or permission to do so.

• Camera — to scan a sensor's QR code or barcode when assigning sensor

 IDs. Camera images are used only for on-device scanning and are not stored or
 transmitted.

• Local network / USB (Desktop) — to communicate with wired RP1210 /

 USB-Serial CAN adapters.

Section 4 — Vehicle and sensor (TPMS) data

When connected to GwNode hardware, the App reads sensor and configuration data from the vehicle's J1939 / CAN bus, including:

• Tire pressure and temperature, and standard-pressure / temperature-warning

 status (TPMS);

• Reefer / zone temperatures (TempTrac);
• Door open/closed status (Door Status);
• Sensor identifiers, sensor battery voltage, and leak/fault indications;
• Vehicle configuration (Train layout, axle/zone configuration) and GwNode

 device identifiers;

• Diagnostic Logs and Statistics generated by the GwNode.

This data is used to display the health of your vehicles and to configure the sensor systems. While signed out, it stays on your device (Section 3).

Section 5 — Account sign-in and authentication

Fleet-Share and cloud history require a SpartanLync account. Authentication is handled through SpartanLync's centralized single sign-on (Keycloak). When you sign in, we process your account email, credentials and account role (for example User, Subscriber, Partner, Partner_Manager, Staff, Admin) to authenticate you and to determine which features and sharing capabilities are available to you. Your password is validated by the SpartanLync identity service and is not stored by the App or the X23-Mgr service.

Section 6 — Fleet-Share: sharing data with Producers and Consumers

Fleet-Share is optional and operates entirely behind an authentication wall. No Train data is shared with anyone unless you are signed in and choose to participate.

• Producers — signed-in users with sufficient privileges

 (Partner_Manager or higher) may publish live Train status, Alerts, and
 associated Logs and Statistics to their Fleet, so that other members of the
 same Fleet can view them.

• Consumers — signed-in members of a Fleet who do not have local

 CAN/BLE proximity to a GwNode Train may view the Train status and Alerts
 that a Producer has chosen to share.

• Owner control — a Producer decides which scanned GwNode Trains

 are visible to other members of the Fleet, and can change or revoke that
 visibility. Sharing is limited to members of the same Fleet.

Data shared through Fleet-Share is transmitted to SpartanLync's cloud service so it can be delivered to authorized Fleet members; it is not sold or shared with third parties for advertising.

Section 7 — Cloud archival, Logs and Statistics

Once you are signed in, GwNode Logs, Statistics and real-time Alerts/Status that were cached on your device may be uploaded to the SpartanLync X23-Mgr-Service. This enables Fleet-wide status display, historical archival, and query/reporting for your organization. This upload occurs only for authenticated users.

Section 8 — Information security

Data exchanged between the X23-Mgr App and the SpartanLync X23-Mgr-Service is protected in transit by SSL/TLS (HTTPS). The X23-Mgr-Service is a Laravel web application running on a LAMP stack.

Access to the service requires authentication. Signing in validates your credentials against SpartanLync's centralized single sign-on (Keycloak) over an encrypted (TLS) connection. The service then issues a session token to your device and stores only a one-way (SHA-256) hash of that token — never the token itself. Every request for shared Fleet data is authorized by that session token and is restricted to authorized members of the relevant Fleet according to your account role. Inactive sessions expire and are removed automatically.

Fleet data (status, alerts, logs and statistics) is stored in the X23-Mgr-Service database. This stored data is not additionally encrypted at rest; it is protected by the transport encryption, authentication, session and role-based access controls described above, together with the operational security of the hosting environment.

Section 9 — Data retention and deletion

• On-device data is retained until you delete it in the App or uninstall

 the App.

• Cloud data shared through Fleet-Share or archived via the X23-Mgr-Service

 is retained for as long as needed to provide the service to your
 organization, or as required by law. You may request deletion of your
 personal data by contacting support@spartanlync.com.

Section 10 — Children's privacy

The X23-Mgr App is a professional fleet-management tool and is not directed to children under 13. We do not knowingly collect personal data from children.

Section 11 — Changes to this Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the "Effective date" above and, where appropriate, through notice within the App or on this page.

Section 12 — Contact

For any privacy question or request, contact:

SpartanLync Technologies Corp.

Email: support@spartanlync.com