Privacy Policy

This is the privacy policy of LIGHTMETRICS, INC., a a Delaware corporation, having its place of business at 1636 Tawnygate Way, San Jose, CA 95124 (“LightMetrics”) who is engaged in the business of providing advanced video telematics to its customers (“Services”).

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This privacy policy (“Privacy Policy”) succinctly describes how we collect and use your information through a variety of means, from time to time, including without limitation, the following:

• our website https://www.lightmetrics.co from which you are accessing this Privacy Policy;
• our software applications, devices and solutions made available by us for use on or through computers and/or other electronic devices to our customers, including end users or data subjects of such customers (“Solutions”);
• our social media pages that we control from which you are accessing this Privacy Policy (“Media”);
• HTML-formatted email messages that we send to you that link to this Privacy Policy; and
• offline means such as when you place a purchase order or request for any maintenance and support services over the phone or e-mail.

(Points above are hereinafter collectively referred to as the “Platform”).

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You are advised to read the Privacy Policy carefully. This Privacy Policy applies to current and former users of the Services and all users of the Platform. By availing our Services, accessing and/or using the Platform, you consent to our Privacy Policy.

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For the purposes of this Privacy Policy, “we”, “our” and “us” shall mean LightMetrics and “you” and “your” shall mean any visitor to the Platform and/or user of the Services.

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This Privacy Policy is incorporated into, and is subject to, the Terms of Use available on our website at www.lightmetrics.co/company. Further this Privacy Policy shall apply irrespective of any other similar terms relating to the subject matter, under any written contract or agreement executed between LightMetrics and the customers.

We may collect the following personal data from the Platform, including but not limited to:

• Contact data and business contact information: name including first and last name of yourself, your employees and/or your contractors (“Representatives”), email address, mobile number and contact details of yourself and your Representatives, your address and postal code;
• Targeted data: your Representatives’ behavioral patterns;
• your Representatives’ records relating to violation of applicable laws;
• your Representatives’ location using GPS and driving routes;
• Biometric data: photographs, videos, voice recordings and images/footage captured on CCTV or other audio video systems when you access our Solutions;
• such other information about you as we may request, from time to time

We may also collect information pertaining to:

• the links you click on the Platform;
• the number of times you access the Platform’s page/portal;
• the number of times you have interacted on the Platform; and
• the duration and extent of interactions on the Platform.

We may collect your information for design and testing our Solutions, its application in real life environment, for research, analysis and/or verifications. Similarly, drivers or passengers reactions in the car can be studied during test phases and but this data will never be related to you as an individual, nor used in relation to you, as a data subject but used for statistical purposes in order to develop products that are adapted to the highest number of end users.

We may collect information specified in Clause 1 above from you, either actively through our Platform in the process of rendering our Services to you, or passively. We use tracking tools including, but not limited to, Google Analytics, browser cookies and web beacons for collecting information about your usage of the Platform. We may get information about you from third parties such as, including without limitation, our affiliates, associates, public authorities, vendors and suppliers. We shall, however, use all such information in accordance with this Privacy Policy.

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If you provide us with any personal data of another person, you are responsible for ensuring that such person is made aware of the terms of this Privacy Policy and that the person has given you his/her consent for sharing the information with us.

We may use your personal data for reasons including, but not limited to, the following:

• to provide you and/or the end users, our Services in accordance with agreed terms;
• to help us recognize and verify that the person driving a vehicle is an authorized individual;
• to help us provide personalized features;
• to tailor the Platform to suit your interests;
• improve and/or optimize the Platform for you based on your usage pattern;
• to get in touch with you when necessary;
• to facilitate communication with you to ensure business continuity, including for the purpose of providing you with necessary information, references and recommendations about our Services and Solutions, and to develop business with prospective customers;
• for legal purposes;
• to preserve browsing history as governed by applicable law or policy; and
• for security purposes: to protect us, other users or our Platform and applications.

We use contact information internally to:

• to send you confirmations, acknowledgments and other details pertaining to continuing our Services or our Solutions that may be of interest to you;
• direct our efforts for improvement of the Platform and its contents;
• contact you as a survey respondent;
• notify you of any developments in this Privacy Policy; and
• send you promotional materials regarding: (i) offers, promotions and details of new Solutions; (ii) newly uploaded Platform content; and/or (iii) any information that we deem material in order for you to be a fully informed user of and visitor to the Platform.

We may use your information as otherwise permitted by law.

We collect and process information about users like you who use our Platform. We consider that we have a legal basis to do so where:

• you have given us consent to do so for the specific purposes of using our Platform pursuant to an agreement entered into by your company or yourself with us, wherein we will process your data to fulfill the terms of the said agreement;
• it is necessary for us to do so to enable us to provide you with the Services that you have requested from us in using the Platform;
• it is necessary in order to fulfil our legitimate interests (or those of a third party) to protect the safety and security of our services and Platform, operating and improving the Platform, supporting our customers, marketing and promoting the Platform, and protecting our interests; or
• the law otherwise permits or requires it.

Your personal data will only be seen or used by our employees, officers or contractors who have a legitimate business need to access such information personal data for the purposes set out in this Privacy Policy.

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We take your privacy seriously and have implemented appropriate physical, technical and organizational security measures designed to secure your personal data against accidental loss, destruction or damage and unauthorized access, use, alteration or disclosure.

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We may also share your personal data with our affiliates and third-party service providers, to enable the efficient and secure provision of Services to you. Except as set forth in the Terms of Use, we do not rent, sell or share your personal data and we will not disclose any of your personal data to third parties unless:

• we have your permission;
• it is with the concerned regulatory authority/body for the purposes of compliance with applicable law;
• it is with organizations or companies who may contact you for the purpose of availing supplementary or related services;
• it is to provide products or Services you have requested;
• it is to help investigate, prevent or take action regarding unlawful and illegal activities, suspected fraud, potential threat to the safety or security of any person, violations of our Terms of Use or to defend against legal claims;it is with a successor to all or part of our business;
• special circumstances such as compliance with court orders, requests/order, notices from legal authorities or law enforcement agencies compel us to make such disclosure; or
• it forms a part of the anonymous information we share with our partners and/or advertisers on an aggregate basis.

We may share your information for reasons not described herein. However, the same shall be done only upon obtaining your consent.

You may be required to procure third party services or directed to third-party links, devices or applications from our Platform which we do not control. This Privacy Policy solely and exclusively governs your usage and experience of our Platform.

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Accordingly, we undertake no liability whatsoever as regards your usage of these third-party applications, services, products and websites and you may visit them or use any of their products and/or services at your own risk. We strongly encourage that you read the privacy policies of any third-party service providers you are directed to before using the same.

If you would like to disable our access to any passive information we receive from the use of various technologies, you may do so by disabling cookies in your web browser, which may affect the complete use of our Platform, products and Services.

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Please be aware that LightMetrics will still receive information about your usage and also your personal data, such as your email address. If you choose to terminate your engagement with LightMetrics, we will store information about you for such period as permitted under applicable law, after which time the information may be deleted partially or fully as deemed fit at the given time.

We will keep your data for as long as we provide access to our Platform. We will then keep data for a limited period when we no longer provide services to you to deal with any queries or complaints or as required under applicable law.

This Clause only applies to you if we process your data while you are in the EEA. It explains that you have a number of rights in relation to your personal data under the EU General Data Protection Regulation 2016/679 (“GDPR”), the Data Protection Act, 2018, UK GDPR or any other applicable data protection laws following Brexit. However, the additional rights only apply when we process your personal data while you reside within the EEA or UK, as the case may be. If the additional rights do apply, you have the right to request that we:

• provide you with a copy of the information we hold about you;
• update any of your personal data if it is inaccurate or out of date;
• delete the personal data we hold about you – if you are using our Platform, and you ask us to delete personal data we hold about you then we may be unable to continue providing access to our Platform to you;
• restrict the way in which we process your personal data;
• stop processing your personal data if you have valid objections to such processing; and
• transfer your personal data to a third party.

In providing Services to you, you understand that we may transfer your information to different locations around the world. For users resident in the EEA or UK, where your personal data is transferred from the EEA or UK to a recipient outside the EEA or UK to a third country not recognized as providing an adequate level of protection for personal data, such transfer shall be covered by a framework recognized by the relevant authorities or courts as providing an adequate level of protection for personal data, including, but not limited to, Standard Contractual Clauses (as formulated under the European Commission’s decision of February 5, 2010 for the transfer of personal data to processors established in third countries, also used under the UK GDPR), the terms of which shall be incorporated by reference.

This section only applies to you if you are a California resident and we process your personal data. If that is the case, you have certain additional rights in relation to your personal data under the California Consumer Privacy Act (CCPA), Cal. Civ. Code § 1798.100 et seq. If the CCPA applies to you, you have the right to request that we:

• disclose or provide copies to you, no more than twice in a 12-month period, the personal data about you that we have collected, used, or disclosed during the preceding 12 months; or
• delete the personal data we hold about you, but please note that if you are using our Platform, and you ask us to delete personal data we hold about you then we may be unable to continue providing access to our Platform to you;

We may not be required to delete your personal data if it is necessary to:

• complete any transaction for which it was provided;
• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• exercise any right provided to us by law;
• comply with a legal obligation; or
• otherwise use your personal data internally in a lawful manner compatible with the context in which you provided

As we do not sell your personal data, we do not offer an opt-out to the sale of personal data.

To correct or update any information you have provided, you may do so online. In the event of loss of login credentials, you can use any of the following options:

• Send an e-mail to: support@lightmetrics.co; or
• Call the following telephone number: +18339884422.

This Privacy Policy was last updated on 18th April 2022. We reserve the right to change or update this Privacy Policy at any time. Such changes shall be effective immediately upon posting on this Platform. We will notify you of any material changes as required by law, but we advise to periodically check the Platform for updates.

In accordance with applicable data protection laws, the name and contact details of the grievance redressal officer are provided below:

• Pushkar Patwardhan
• dpo@lightmetrics.co

If you have any other questions about this Privacy Policy or other privacy concerns, you can also email us at info@lightmetrics.co.

Regardless of where you live, you consent to have your personal data transferred, processed and stored in the U.S. or other parts of the world, as may be required to perform our obligations hereunder, in compliance with applicable laws. Any disputes arising under this Privacy Policy shall be governed by the laws of the state of California and the courts at San Jose, or the appropriate United States District Court, shall have exclusive jurisdiction.

Your use of and access to the Platform and any disputes arising therefrom, is subject to this Privacy Policy as well as our Terms of Use. Please read our Terms of Use carefully in order to obtain information on the terms governing the use of and access to the Platform.