PRIVACY POLICY

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

• names
• phone numbers
• email addresses
• usernames
• passwords
• billing addresses
• debit/credit card numbers
• contact or authentication data
• mailing addresses

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's bluetooth, social media accounts, camera, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

Information automatically collected

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Vehicle Telematics, Video, and Location Data (via ELD and Lytx Devices). When you or your organization install and operate our electronic logging devices (ELD) or the LytxOne AI Video Gateway and dashcam Devices in a vehicle, those Devices automatically record and transmit, depending on configuration:
  • Telematics data — vehicle speed, RPM, engine status, fuel level, odometer, diagnostic trouble codes, ignition state, and other CAN/OBD-II signals.
  • Location and route data — GPS coordinates, heading, time-stamped travel history, stops, and route information.
  • Driving behavior and event data — acceleration, deceleration, harsh braking, cornering, lane weaving, tailgating, speeding, collisions, and other driving events, including data from the Device's gyroscope, accelerometer, and compass used to detect and classify such events.
  • Video and audio — road-facing and/or driver-facing video and in-cabin audio captured by the Device cameras and microphones. Such footage may capture the vehicle, the vehicle's interior (including the face, body, expressions, speech, and behavior of the Driver and Passengers), and the vehicle's surroundings (including pedestrians, cyclists, and other Other People in the public domain).
  • Driver identification and HOS data — driver name, employee/contractor ID, carrier and vehicle (VIN, unit number, plate), duty status, and hours-of-service (HOS) logs required by the FMCSA ELD mandate.
  • Devices data — information about the AI Video Gateway, dashcam hardware, firmware version, and network status used to ensure proper operation.
  • Usage, logs, and analytics — device information and identification numbers, operating system information, IP address, browser and session information, configuration information, file metadata, and usage information (such as screen views, clicks, and usage time).
  Not all video, audio, and sensor data captured by the Devices is transmitted to FIRST ELD or the LytxOne Platform. Customers (fleets) configure on the Application the means and triggers for data collection and retention for each Device, and some data may remain stored locally on the Device's memory under the Customer's sole control. Drivers and passengers should direct questions about in-cab video, audio, or telematics data first to their employer (the Customer and Data Controller).

Information collected from other sources

2. HOW DO WE PROCESS YOUR INFORMATION?

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see " WHAT ARE YOUR PRIVACY RIGHTS? " below.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To post testimonials. We post testimonials on our Services that may contain personal information.
• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visitGoogle Analytics Opt-out. For more information on the privacy practices of Google, please visit theGoogle Privacy & Terms page.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Lytx, Inc. (LytxOne Platform and Devices). We rely on Lytx, Inc. ("Lytx") as a hardware manufacturer, software-as-a-service provider, and data processor for our AI dashcam, video telematics, and fleet management offering. Video, audio, telematics, GPS, driving-behavior, and Device data captured by Lytx Devices installed in your vehicles is transmitted to and processed on the LytxOne Platform on behalf of your organization. Lytx processes this data as a Processor under its own Lytx Privacy Policy and LytxOne License Agreement. Lytx hosts customer data primarily on Amazon Web Services (AWS) in the United States and maintains R&D and customer support functions in additional countries, including Israel and India. Lytx may engage its own sub-processors (including hosting and backup providers such as AWS, analytics providers, telecommunication services, media transmission services, security technology, IT and system administration, payment processing, technical support, research and analytics, telecommunication vendors, and customer support) on a need basis for the performance of the Platform and Devices.
• Other Subprocessors. We may disclose information to additional third-party service providers acting on our behalf, such as hosting, analytics, customer support, payment, telecommunications, and security vendors, under written contracts requiring appropriate confidentiality and security obligations.
• Law Enforcement, Courts, and Government Authorities. We may disclose your information to law enforcement agencies, courts of law, and other governmental organizations when ordered to do so by competent bodies and according to applicable law, or where we or our Customers reasonably believe disclosure is necessary to protect rights, property, or safety, or to respond to accidents, insurance claims, or legal proceedings.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

• In Short: We aim to protect your personal information through a system of organizational and technical security measures.
• We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

Account Information

• Contact us using the contact information provided.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

12. DO WE MAKE UPDATES TO THIS NOTICE?

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

15. TCR Privacy Policy

1. Introduction

2. Information We Collect

• Personal Information: Name, address, phone number, email address, date of birth, and other information you provide during registration or purchase.
• Usage Data: Information about how you use our services, including your internet protocol (IP) address, browser type, access times, and pages viewed.
• Financial Information: Payment details and transaction history.

3. How We Use Your Information

• To provide and manage our services.
• To process transactions and send you related information, including purchase confirmations and invoices.
• To communicate with you, including responding to your comments, questions, and requests.
• To send you technical notices, updates, security alerts, and support messages.
• To improve our website and services.

4. Sharing Your Information

5. Data Security

6. Your Rights

• Access and request a copy of your personal information.
• Request correction or deletion of your personal information.
• Object to the processing of your personal information.
• Withdraw your consent to our processing of your personal information at any time.

7. Cookies and Tracking Technologies

8. Opt-In and Opt-Out Information

9. Data Collection and Use

16. LYTX PLATFORM, DEVICES, AND DATA PROCESSING

16.1. Who Lytx Is and What They Do

16.2. Controller / Processor Relationship

• The Customer (the fleet, carrier, or other organization that purchases and deploys the Devices) is the "business" / "data controller" with respect to personal data captured through its Devices and processed on its LytxOne Account. The Customer decides what data to collect, how long to retain it, who within its organization may access it, and for what purposes.
• FIRST ELD and Lytx are "service providers" / "data processors" that process personal data on the Customer's behalf, only according to the Customer's instructions as configured in the LytxOne Application and as permitted by the LytxOne License Agreement and this Privacy Policy.
• If you are a Driver, Passenger, or other individual whose data has been collected via a Device installed in a Customer vehicle, please direct any request to access, correct, delete, restrict, object to, or port your personal data first to your employer or fleet operator (the Customer and Controller). We and Lytx will support the Customer in responding to such requests to the extent required by applicable law.

16.3. Categories of Personal Data Processed via Lytx Devices

• Identification and contact details of Users, Drivers, and recipients of shared data, such as name, employee/contractor ID, ID number, title, car plate / VIN number, gender, profile photo, username and password, phone numbers, and email addresses;
• Video and audio recordings of the vehicle, the vehicle's surroundings (which may include pedestrians and cyclists in the public domain), and the vehicle's interior (including face and body video, expressions, speech, and behavior of the Driver and Passengers);
• Detailed location, travel, and route information, including GPS signals combined with a time-stamp and other information from the Device;
• Telematics data on the vehicle, including performance, speed, engine status, fuel levels, and driver behavior;
• Devices data, including information on the AI Video Gateway, the dashcam Devices, and network status;
• Driving data — such as speed, acceleration, deceleration, braking, turns, lane weaving, tailgating, stops, and collisions — and sensory and motion data from the Devices, including information from gyroscope, accelerometer, and compass, used to calculate and detect driving events and behaviors (Lytx may use a third party to collect such data);
• Any personal data contained in videos, media, or other files uploaded by Devices, Customers, or Users;
• Usage, logs, analytics, and other technical data, including device identifiers, operating system, IP address, browser and session information, configuration information, metadata of files, and usage information.

16.4. Purposes of Processing

16.5. Disclosure to Third Parties via the Lytx Platform

16.6. International Transfers

16.7. Retention

16.8. Your Rights With Respect to Lytx-Processed Data

16.9. Children

16.10. References