WELCOME

Letstrack ("Letstrack", "we", "our", or "us") is committed to protecting and respecting your privacy.

Letstrack operates a service that allows you to speak to and share your location with other users in your family or friendship group (each group, a "Circle"), which we make available through our apps and our website https://www.Letstrack.com (the "Service").

This Privacy Policy explains our practices regarding the collection, use, disclosure, transfer, storage, and protection of personal information that is collected through our Service, as well as your choices regarding the collection and use of information.

Our Service is available in many countries, which may have different standards and requirements in respect of the information we provide in the Privacy Policy and how we use personal information.

This Privacy Policy is therefore made up of two parts:

• Part 1 sets out information applicable to users outside the European Economic Area, Switzerland or the UK; and
• Part 2 sets out information applicable to users in the European Economic Area, Switzerland or the UK.
• If you are a resident of the State of California in the United States, please see below for additional California-specific privacy information.

Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that is relevant to you.

Part 1 – Privacy Policy for non-EEA users

This Part 1 of our Privacy Policy explains how we collect, use, disclose and protect information that is collected through our Service from users outside the European Economic Area,  Switzerland or the UK, as well as your choices regarding the collection and use of information.

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1. HOW WE COLLECT AND USE INFORMATION

Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use.

We collect the following types of information about you:

Registration and Profile Information. When you create an account, we may collect your personal information such as your username, display name, first and last name, email address, mobile phone number. We may collect a photo, if you or a Circle member associate a photo with your account. If you want to add a family member’s name to your account, we collect the family member’s name, email address, and mobile phone number.

For processing orders and paid subscription services, we may need to collect some or all of the following information from you: Your Name, Company Name, Address, Email address, Credit or Debit card or Paypal details.

Data collected through use of the Service. After you set up your account, we may ask for other profile and demographic information, such as personal emergency instructions and information, and nickname. You may also customize your map by labelling locations, such as “work” and “home,” to make it easy to spot your favourite places and to provide alerts when family members leave and arrive.

Geolocation. We collect your location information through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. If you enable the mobile app to use your Bluetooth signal, we may be able to determine location based on nearby Bluetooth-enabled devices, which helps us to improve location accuracy, identify other Letstrack users and devices that have been in proximity to each other, and improve location updates for all devices in the Letstrack network. Depending on your device settings, we collect location information in the background, even when you are not actively using the app. We collect and maintain location data to provide you the features and functionality of the Service.

We may also share location information with our partners for tailored advertising, attribution, analytics, research and other purposes, as described in Section 2 “Sharing of Your Information” below. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the app’s access to your location data. Please see “Your Choices About Your Information” below to learn more.

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Sharing of Information to third-parties

We may share your data (including Personal Information) with our affiliates or Data Processing Partners, for example:

• IT Services and Infrastructure Providers
  • Google Cloud
  • Amazon (AWS)
• Order Fulfillment Services
  • DHL Express
  • DPD
  • Royal Mail
  • Amazon
• Analytics Providers
  • Google Analytics
• Third Party Advertising Providers
  • Facebook
  • TikTok
  • Microsoft Advertising
  • Instagram
  • Twitter
  • Google
• Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information in accordance with our acceptable business practices.
• We cannot guarantee that the Data Processing Partners will adhere to the contractual obligations or acceptable business practices. We strive to protect the information provided to our Data Processing Partners. We have no direct control over their use of the collected information. Therefore, you acknowledge that we are not liable for any third-party privacy breach and that our liability for Data Processing Partners is limited to the amount we are able to receive as indemnification from Data Processing Partners.
• We may also release your information as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection.

Information from third-party services

We collect information from third party services that you connect to your Letstrack account. For example, if you link your Letstrack account to a voice assistant platform to enable interaction with our service through voice commands, such as such as through the Letstrack Google Action (“Action”) available on Google Assistant-enabled devices, we will collect the queries and commands applicable to Letstrack that you make through the voice assistant platform.

Driving Event Data. We collect, and may use a third-party partner to collect, sensory and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass and Bluetooth, in order to calculate and detect driving events such as speeding, hard braking, crash detection and other events. Your mobile device provider may refer to this information as “Motion and Fitness” data (description may vary according to device and platform). We may also share this information with third party partners for marketing, research, analytics and other purposes. If you want to opt-out of the collection of your sensory and motion, please adjust your settings in your mobile device to limit the app’s access to your sensory and motion data. Please see “Your Choices About Your Information” below to learn more.

Messages and User Content. We collect information when you message other members of your Circle through use of the service. We may also retain any messages you send to us.

We use this information to operate, maintain, and provide to you the features and functionality of the Service and to communicate directly with you, such as to send you alerts on the movements within your team or Circle.

Social Media. When you interact with our site through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Letstrack’s website or Service.

Identity verification. In limited circumstances, we may use identity verification services provided by a third-party provider to verify your age and/or to obtain verifiable parental consent for your child to use the Service. When identity verification is required, we will ask you to upload an image of your valid government-issued ID along with a selfie image. Our identify verification provider will use a combination of machine learning tools and optical scans to authenticate your identity document, and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a "match." Letstrack does not receive the biometric identifier generated from the images. It is generated and held by our identity verification provider until the biometric identifier is no longer needed for the purposes described in this paragraph, which will occur no later than 60 days after your last verification interaction with us.   For identity verification and security purposes, Letstrack may have access to the information extracted from the identity scan of the ID document (such as a name and partial driver’s license number) as well as the results of the identity verification process. We may use this process and associated information to verify your identity, authenticate your identity documents, confirm appropriate parental consent, and protect against fraud and misrepresentation.  We do not use, disclose or retain your biometric information for any other commercial purpose. Our third-party provider processes this information on our behalf strictly in accordance with our contractual agreements. Please note this service may not be available in all jurisdictions.

Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information, such as:

• Information about how you access the Service, for example, referral/exit pages, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.
• Information about how you use the Service, for example, the features you use, the links you click, the ads you view and click on, purchase transaction information, your location when you access or interact with our Service, and other similar actions.
• Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/ model/ manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, and other such information. With your permission, we may also access your photo or camera roll.

We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

We use this information to (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide custom, personalized content and information, including targeted content and advertising; (iii) track your location and movements; (iv) identify and contact you across multiple devices; (v) provide and monitor the effectiveness of our Service and our marketing campaigns; (vi) monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns; (vii) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs; and (viii) detect or prevent fraud or other harmful activities; (xi) automatically update our mobile application on your system and related devices; and (x) otherwise plan for and enhance our Service.

If you prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. These browser settings that block cookies may have no effect on non-cookie technologies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Although we do our best to honour the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time.

If you have an account and you log into this site, we will set a temporary cookie to determine if your browser accepts cookies.  This cookie contains no personal data and is discarded when you close your browser.

We and our third-party partners may also use information collected through tracking technologies for advertising purposes. Please see “Third Party Tracking and Online Advertising” below to learn more.

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2. SHARING OF YOUR INFORMATION

Personal Information:  We share your personal information with third parties outside the Company and its controlled subsidiaries and affiliates in some circumstances, as follows:

• We share your personal information, including name, email, precise location and driving event data, with others within your Letstrack Circles. Depending on the features and functionality enabled, we may also share other information about your use of the Service with members of your Family Circle, such as whether you have logged in on a new device.
• We may share your personal information, including your precise location data, driving sensor data, unique identifiers or AD IDs and other data with our partners, for their marketing and business purposes, including without limitation, to inform and improve tailored advertising, attribution, analytics or research purposes. These third-party partners may use this information according to their own privacy policies. Please see “Your Choices About Your Information” to learn how you may be able to limit some third-party data sharing.
• We may share your personal information with third party driving analytics providers, who enable us to provide certain functionalities of the Service, such as driving event history and crash detection. We may share geolocation and movement data, mobile device information (such as information generated by the gyroscope and accelerometer in your device) and application analytics, including IP address and device identifiers, driving event data and information provided by you during your registration of a Letstrack account or as part of your use of our Services. These providers may use this information to analyze your driving behaviours, such as speed, change in speed and other aspects of how, how much, where and when you drive in order to predict driving risk and calculate a driving risk score.
• We share personal information with third-party partners that provide certain features and services you may use in connection with our Service. For example, depending on the features of the Service you have enabled, we provide your personal information and location data to emergency responders in the event we detect a crash. We also share personal information with third party partners that provide services and features available through our Premium subscriptions, such as Emergency Dispatch services. The third parties that provide Premium service features may ask you for additional information in order to provide the full range of services to you. Any information provided to these third parties will be governed by that third party’s own privacy policy.
• We share personal information with third parties that you have connected to your Letstrack account to facilitate the features or services. For example, if  you enable the Letstrack Action on any Google Assistant-enabled device or use other voice-assistant services, Letstrack will respond to any query received through the action and disclose your personal information as well as the personal information (such as name, current location, and other data) of your Circle members through screen display or audio response. Google and the equipment the Google Assistant is installed on, may record your interactions with the Action and the response data in accordance with your agreements with Google. You are solely responsible for the use of the Letstrack Action to access information about your Circle members on your Assistant-enabled devices, including in the case of any unauthorized access to your device by a third party, and for the consequences of enabling the Action on any of your devices.
• Other users may share your personal information in certain circumstances. For example, if a member of your Circle enables the Letstrack Action on a Google Assistant-enabled device, your personal information (including name, current location and other data) may be displayed on screen or via audio response on any device with the Letstrack Action enabled. This means your information may be available to other individuals who have access to your Circle member’s Assistant-enabled device or who may overhear your Circle member interacting with the Action. To prohibit this data sharing, you must ask your Circle member to disconnect his or her account from the Letstrack Action or you can leave the Circle.
• We may use Captcha service providers to authenticate data entered on our website.  
• Any information or content that you voluntarily post to the website or to our Facebook page will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile app or link your reviews to third party websites.

Other instances in which we may share your information: We may also share your information for business purposes, as follows:

• We may share your personal information with our third-party business partners, vendors and consultants who perform services on our behalf or who help us provide our Services, such as accounting, managerial, technical, marketing or analytic services, and to other third-party partners or service providers who contractually agree to process personal information solely as necessary to provide services or features to our users.
• We may at any time buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personal information such as customer names and email addresses, and other user information related to the Service will likely be one of the items transferred in these types of transactions. We may also share, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.
• We may disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) when required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of Letstrack, our Users or others.

Letstrack Ltd and Letstrack UK Ltd are UK based organisations and we store your personal information in the UK, which may be outside your jurisdiction of residence. Our partners and service providers may also store your personal information outside your jurisdiction of residence. Accordingly, your personal information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such jurisdictions.

De-Identified Information:  We may also share your information with third parties in a form that does not reasonably identify you directly.  These third parties may use the de-identified information for any purpose.

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3.  HOW WE PROTECT YOUR INFORMATION

Letstrack cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

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4.  YOUR CHOICES ABOUT YOUR INFORMATION

You may, of course, decline to submit any personal information through the Service, in which case Letstrack may not be able to provide its Services to you.

Modifying Your Account Information and Settings: You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. If you have any questions about reviewing or modifying your account information, you can contact us directly at privacy@letstrack.co.uk

Close Your Account or Delete Personal Information: We retain your information for as long as your account is active or as reasonably necessary to maintain the Service, meet legal and accounting obligations, and for the other purposes described in this Privacy Policy. If you wish to close your account, and/or request to delete your personal information, please contact us at privacy@letsrack.co.uk. When account information is deleted or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing and tax purposes.

Emails and Notifications: You can control your receipt of email and text alerts by visiting “Settings” and “Notifications and Alerts” within the mobile app. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of Service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices).  We make every effort to promptly process all unsubscribe requests.

Location and Movement Data Collection and Sharing:  As described in Section 2, we collect precise location data and driving event and movement data (such as accelerometer data, magnetometer data, gyro data, etc.) from your device to provide the Letstrack Services, and may share your personal information, including location and movement data, with other Letstrack users in your Family Circle or other Circle you belong to, and with third parties for crash detection, research, analytics, attribution and tailored advertising purposes. You have many options to control this data collection and sharing activity through the App Settings:

• Limit location sharing with your Circle. You may turn location sharing “OFF” for one or more of your Circles through your App settings.  If you turn off location sharing in one or more of your circles, we will not share your location with such Circles; however, we will continue to collect your location information in order to provide the Service (for example, to provide our emergency services, to share your location with the other Circles, or to provide location-based advertising).
• Limit Drive Detection. You can limit the collection and display of location and movement data through the Drive Detection feature in the in-App Privacy settings. When you turn Drive Detection “off,” your Driver Reports will no longer be visible in your Circles. Please note that your Letstrack app may not be able to provide all of our Services to you turn off Drive Detection. When Drive Detection is turned “off,” Crash Detection services will be disabled and safety services like SOS Help Alerts and 24/7 Dispatchers will not be available.  
• Limit data sharing with third party data partners through in-App Privacy Settings. To opt-out of Letstrack sharing personal information (including location and movement data) with data partners for targeted advertising, research, attribution and similar purposes, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security settings. If you opt-out, Letstrack will continue to collect your device location and movement data and to share such data with your Circles and with third parties as needed to support and provide the Letstrack services or other services you engage, but we will no longer share data about you with our third-party data partners for their own advertising and other commercial purposes. Please note, some third-party data partners may continue to send you location-based ads based on your previous location or may approximate your location based on other data.
• Limit driving event sharing. We may share data with our partners to support important App features like driving behaviour and Crash Detection. This data may be used for research, to improve its analytics and predictive driving behaviour models and improve its performance generally. To opt-out of permitting our Partners to use and learn from your data for its own research and to develop and improve its predictive behaviour models and products and services generally, you can opt-out through the in-App Privacy Settings. To opt-out of permitting our Partners to use data for its own commercial purposes, including marketing, advertising, and to provide and service insurance company products and ads, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security Settings.
• Disconnect Location Data and Movement Data in Device Settings. You may also be able to turn off device location data collection through your mobile device settings.  For example, depending on your mobile device, you may be able to “Turn location services ‘off,’ which restricts access to your device location data. You can also adjust your device settings to withdraw permission for the Letstrack app to access device location data and/or motion data (depending on the device type, this may be called “Fitness and Motion” data), and you can also adjust your device settings to limit the app’s access to WiFi and Bluetooth information. Please note that your Letstrack App may not be able to provide all of our Services to you if you disable access to location and movement data through your device settings.

Third Party Tracking and Online Advertising: We may share information about your use of our Services over time, including location information, with third party ad networks, social media companies and other third parties so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices or advertising channels. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third party ad partners collect and use information such as click stream information, timestamp, hashed email address, device ID or AdID, your use of third party applications and/or precise geolocation data and other information, and may combine this information with information they collect directly through tracking technologies or that they receive other partners, both online and offline, so that they may recognize you across other browsers or devices you use, including computers, mobile devices and Smart TVs. These third parties use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

• To opt-out or control third-party tracking and advertising: Interest-based advertising.To learn about interest-based advertising and how you may be able to opt-out of the use of your personal information to inform and display targeted advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at aboutads.info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu.
• Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).  You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoicesand downloading the mobile AppChoices app.    
• Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
• Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
• Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

• To opt-out of Letstrack sharing data with third parties for advertising purposes. To opt-out of Letstrack sharing personal information (including location and movement data) with data partners for their own targeted advertising, research, attribution and similar purposes, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security settings. Please note, some third-party data partners may continue to send you personalized or location-based ads based on your previous location or data they have collected from other websites and mobile apps.

You may request access to, or correction of, your personal information by contacting us at privacy@letstrack.co.uk

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5.  CHILDREN'S PRIVACY POLICY

Letstrack takes special precaution to protect the privacy of our younger users.  Letstrack does not knowingly collect personal information from children under the age of 13 (a “child”) without verifiable consent of a parent or guardian and the Service is intended to be used by children under 13 only with significant parental involvement and approval.

If Letstrack learns that we have inadvertently collected personal information of a child without parental consent, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with our Service without your consent, please alert us immediately by emailing privacy@Letstrack.com so that we may delete that child’s personal information from our systems.

By enabling your child to create a user account and permitting your child to use the Service, you expressly agree to the practices described in this Children's Privacy Policy and you consent to the collection, use, and disclosure of your child's personal information as described herein.

Setting up a child account.  If a parent wishes to add a user who is under 13 to the Service, we request parental. The child will then be able to participate in most aspects of the Letstrack Service.

Personal information we collect.  We take special precautions to collect only as much information as is reasonably necessary for the child to use the Service. As further described in our Privacy Policy above, we collect various types of personal information from all users of the Service. For example, we collect profile information (username, email address and mobile phone number) when a user creates an account and other types of personal information the user may provide during the course of using the Service, such as a nickname, favourite location, and emergency contact information.  We collect information about a user’s device (e.g., IP address, device type/model/manufacture / operating system, and a unique ID that allows us to identify the browser, mobile device or account, such as a UDID, IDFA, Google AdID or similar)  as well as certain usage information about the use of the Service (for example, whether the user opens emails) and we collect analytics data. We collect geolocation data through the device IP address, WiFi, Bluetooth and GPS coordinates available through the user’s mobile device and through technologies and sensors that may be nearby. We also collect driving event data through sensory and motion data sensors in the user’s mobile device (e.g., data from a smartphone’s gyroscope, accelerometer, compass and Bluetooth) in order to calculate and detect driving events such as hard braking, speeding and crash detection. Please review the section of our Privacy Policy called “How We Collect and Use Information” to learn more.

Information sharing.  Letstrack may share or disclose a child’s personal information our third party vendors, service providers and business partners as described in our full privacy policy, including, for example, with third parties as needed to analyze and detect driving behaviour data, perform analytics or otherwise , support the features and functionality of our Service such as crash detection. However, we do not share or sell personal information collected from the accounts of children under 13 for marketing or advertising purposes, nor permit our third-party partners to collect and use such information for advertising purposes. Please review the section of our Privacy Policy called “Sharing of Your Information” to learn more about how we share information with our vendors, service providers and others.

Sharing information with other Letstrack users.  The child’s profile information and location will be shared with other members of the Family Circle and any other Circle the child joins. Please note that if your child joins any other Circles, the child will be able to share his or her location with other members of that Circle and may exchange messages with those Circle members. You are responsible for monitoring your child’s account and location-sharing activity through the Service and for blocking or permitting location sharing features.  

Your Choices.

Contact Us.  The Parent has a right to request to review or have deleted the child’s personal information and may withdraw consent for the Service to collect any further personal information from the child. Please contact us at privacy@Letstrack.com to request to review and/or delete any personal information we have collected from the child, or to withdraw permission for Letstrack to collect any additional information from the child. Please also review the section of the Privacy Policy called “Your Choices About Your Information” to learn more about how you may control or turn off certain data collection and sharing features of the Service.

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6.  LINKS TO OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.

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7.  CHANGES TO OUR PRIVACY POLICY

Letstrack may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the top of this page. If there are material changes to this Privacy Policy or in how Letstrack will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.

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8.  YOUR CALIFORNIA PRIVACY RIGHTS

This section applies to you if you are a resident of the state of California (a “consumer”). California law requires us to disclose certain information regarding the categories of personal information we collect. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with an identifiable consumer or device.

Collection and use of personal information. We collect personal information from and about you for a variety of purposes explained in this Privacy Policy.

In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your name, address, phone number, email address, unique device identifiers or other similar identifiers;
• California customer records, such as birth date and payment information;
• Commercial information, such as records of services purchased, obtained or considered;
• Internet/Network information, such as device information, logs and analytics data;
• Geolocation data, such as precise location data from your mobile device (e.g., GPS coordinates) or generated based on your IP address;
• Inferences about your interests and preferences, generated from your use of our services; and
• Other personal information, such as driving event and movement data collected from your mobile device, or content or messages you send through the Service.

We collect this information directly from you, from our business partners, from your browser or device when you visit our websites, download or use our mobile app, and from third parties that you permit to share information with us.

Disclosure of Personal Information. We share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see Your Rights and Choices below). The categories of third parties to whom we disclose your personal information may include: (i) other users with whom you elect to share such information; (ii) our service providers and advisors, (iii) third party businesses that provide features or services you may use in connection with our Service; (iv) marketing and strategic partners; (iv) ad networks and advertising partners; (v) analytics providers; and (vi) social networks. To learn more about how we disclose personal information to third parties, please refer to Section 2 of this Privacy Policy.

Your Rights and Choices.  As a California resident, you may be able to exercise the following rights (subject to certain limitations under law):

• The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: (i) the specific pieces of personal information we have collected about you; (ii) the categories of personal information we have collected about you; (iii) the categories of sources of the personal information; (iv) the categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; (v) the categories of personal information we have sold and the categories of third parties to whom the information was sold; and (vi) the business or commercial purposes for collecting or selling the personal information.
• The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
• The Right to Opt Out of Personal Information Sales to third parties now or in the future.

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

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10.  HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at privacy@Letstrack.com

Letstrack UK Ltd

Palatine House

Sigford Road

Exeter

EX2 8NL

Part 2 – Privacy Policy for EEA, Swiss and UK users

This Part 2 of our Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access our Service from the European Economic Area, Switzerland or the UK.

Letstrack is the data controller of the personal information we hold about you.

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1.  PERSONAL INFORMATION WE COLLECT ABOUT YOU

1.1  We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, create or edit your user profile on the Service, update your preferences, check-in at a particular location, correspond with us by phone, SMS, e-mail or otherwise, or use some other feature of our Service.

1.2  We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.

1.3  The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.

1.4  We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.

1.5  The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

1.6  We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

1.7  We may de-identify any of the personal information we collect (so that it does not directly identify you) and use it for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features.

1.8  We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.

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2.  RECIPIENTS OF PERSONAL INFORMATION

2.1  We may share your personal information with the following:

(a) Others in your Letstrack Circle: we may share your personal information, including your name, location and driving event data, with other users of our Service at your request and in accordance with your settings and preferences.

(b) Third parties for their marketing and related purposes with your consent. Where you have provided consent for us to do so, we may sell your personal information (specifically, your location data, driving sensor data, information about your device, and unique identifiers or AdIDs) to third parties for their marketing and business purposes, including without limitation, to inform and improved tailored advertising, attribution, analytics or market research purposes.

(c) Service providers, business partners and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, bot detection, web hosting, or providing analytic services.

(d) Third parties that provide features you use in connection with the Services: With your consent or on your instruction, we share personal information, including contact information and location data, with third-party partners that provide certain features and services you elect to use through or in connection with our Service. For example, we may provide your personal information and location data to emergency responders in the event we detect a crash. We also share personal information with third party partners that provide services and features available through our Premium subscriptions, such as Emergency Dispatch services. Similarly, we may share personal information with third parties that you have connected to your Letstrack account to facilitate the features or services, such as Siri voice assistant. Any information provided to these third parties will be governed by that third party’s own privacy policy.

(e) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

(f) Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of Letstrack, its users or others.

2.2 Annex 1 and Annex 2 contain further information about some of the parties with which we may share your personal information.

2.3 We may also share your geolocation and movement data, mobile device information (such as information generated by the gyroscope and accelerometer in your device) and application analytics, including IP address and device identifiers, driving event data and information provided by you during your registration of a Letstrack account.

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3.  YOUR LOCATION

3.1 We collect information about your location in order to provide you certain functionalities of the Service.

3.2 We will collect your location where it is necessary for the purposes of providing you with the location-based services features of the app as well as for the legitimate interests of Letstrack or our business partners, such as for data analytics into safe driving modelling. Where you have given us your consent to do so, we may also sell your location data to third parties for marketing and research purposes.

3.3 You can turn off location sharing in one or more of your Circles – if you do so, we will continue to collect your location information in order to provide you the Service. You can withdraw your consent sharing your location with third parties for advertising purposes through the in-app Privacy & Security settings.

3.4 You can also stop sharing your location with us at any time by updating the settings on your mobile device to limit the app's access to your location information. Please note, however, that we may not be able to provide all of the functionalities of our Services to you if you disable access to location data.

3.5 If you no longer want to continue using the Service, uninstalling the Letstrack app or logging out from the Service will also stop us from collecting your location.

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4.  MARKETING MESSAGES AND NOTIFICATIONS

4.1 From time to time, we may contact you with information about our products and services. Most of the marketing messages we send will be by email or through push notifications on your device.

4.2 We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details.

4.3 You can change your preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing newsletters.

4.4 Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Service.

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5.  TARGETED ADVERTISING

5.1 We may share information about your use of our Services over time, including location information, with third party ad networks, social media companies and other third parties so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices you may use. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, Google+ and others. These third-party ad partners collect and use information such as click stream information, timestamp, hashed email address, device ID or AdID, and information about your use of third-party applications, and may combine this information with information they collect directly through tracking technologies or that they receive from other partners, both online and offline, so that they may recognise you across various devices you use, including computers, mobile devices and Smart TVs.

5.2 Where you have consented to us doing so, we may also share your precise geolocation data with advertising partners. We and our advertising partners use the information we collect about you to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

5.3 To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at aboutads.info/choices.

5.4 You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.    

5.5 Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out from receiving interest-based ads on that specific device, but you may still receive interest-based ads on your other devices. You must perform the opt-out on each device you use.

5.6 To opt-out of Letstrack sharing data with third parties for advertising purposes. To adjust your data sharing preferences and to opt-out of Letstrack sharing personal information (including location and movement data) with data partners for their own targeted advertising, research, attribution and similar purposes, you can opt-out or adjust your preferences through the Data Platform page in the in-App Privacy settings. Please note, some third-party data partners may continue to send you personalized or location-based ads based on your previous location or data they have collected from other websites and mobile apps.

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6.  STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

6.1  Security. We implement appropriate, commercially reasonable technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

6.2  International Transfers of your Personal Information. As we are located in the UK, any information we collect from you will initially be collected and stored in the UK. If you are in the EEA, Switzerland or the UK, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will implement appropriate safeguards to ensure that your personal information is treated securely and in accordance with applicable EEA and UK privacy law and this privacy policy, including: (i) ensuring that we use your personal information in accordance with standard data protection clauses adopted by the European Commission for transfers of personal data to recipients outside the EEA and UK; and (ii) ensuring that any recipients of your personal information commit to the same standards. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy notice.

By using and/or shopping on the Letstrack website you consent to the transfer of your personal data to our servers located in the UK.

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7.  USERS' RIGHTS IN RESPECT OF THEIR PERSONAL INFORMATION

7.1  In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

(a) Right of access. You have the right to obtain:

(i) confirmation of whether, and where, we are processing your personal information;

(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your personal information; and

(iv) a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f) Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

7.2 If you wish to exercise one of these rights, please submit your request by email to privacy@letstrack.co.uk  

The EU’s GENERAL DATA PROTECTION REGULATION (GDPR) requires us to be open about our holding and use of personal data.  It also entitles individuals to find out from us what personal data is held about them on a computer, to have that information corrected or erased if it is inaccurate, and to claim compensation if they can prove they have suffered damage from inaccuracy or breach of security

7.3 You may also review and edit your contact and profile information by logging into your account on the app, and opt out of certain processing activities, such as the collection and sharing of your driving event data and movement data, by updating your in-App Privacy Settings. Please note that we may not be able to provide some functionalities of our Services to you if you opt-out of the collection and/or sharing of motion data or driving event data.

7.4 You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

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8.  CONSENT

8.1 We are not required to obtain your consent for most of the processing activities that we undertake in respect of your personal information.

8.2 We may, however, need your consent for certain processing activities. If we need your consent, we will notify you of the personal information we intend to use and how we intend to use it.

8.3 If you have provided consent for certain processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our processing of your personal information before your withdrawal.

8.4 Where we share your personal information with your consent with third parties for marketing and related purposes, you may withdraw consent at any time via our in-app Privacy Centre.

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9.  COOKIES AND SIMILAR TECHNOLOGIES

9.1 Our websites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website or access any of our other websites and also allows us to improve our websites.

9.2 Please see our Cookie Policy for more information about the cookies we use on our website, and how to manage cookies.

9.3 Deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

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10.  JURISDICTION AND ENFORCEMENT

10.1 You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

11. CONTACT LETSTRACK AND RECOURSE

11.1 In the event that you are concerned about how personal information you have provided to Letstrack has been used, please address your inquiry or complaint first to us at the address listed above. Letstrack takes all concerns about privacy and use of personal information very seriously, and shall endeavour to reply to you within 45 days of receiving a complaint.

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12.  LINKS TO THIRD PARTY SITES

Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

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13.  OUR POLICY TOWARDS CHILDREN

13.1 The Service may only be used by children with the consent of a parent or person with parental responsibility over the child.

13.2 The age at which children need parental consent varies between EEA Countries. Please refer to Annex 3 to verify the minimum age at which children no longer need consent to use our Service (the "Minimum Age").

13.3 If you would like to grant your child access to the Service, you must provide consent through one of our available consent mechanisms, for example, by verifying your government-issued identity document (not available in all jurisdictions) or returning the consent form available at https://www.Letstrack.com/pdf/consent.pdf by mail or email using the contact details at the end of this policy.

13.4 We will use the personal information of users under the relevant Minimum Age as set out in this privacy policy. We do not, however, use or share personal information collected from accounts of children under the Minimum Age for marketing or advertising purposes, nor permit our third-party partners to collect and use such information for advertising purposes. We also do not contact, or permit third parties to contact any children under the Minimum Age who access or use our Service. However, other users with whom the child has added to his or her Circles will be able to contact the child.

13.5 If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@Letstrack.com, so that we can take steps to remove such information and terminate any account your child has created with us.

13.6 If you would like to review or delete any personal information we have collected from the child, or to withdraw permission for us to collect any information from the child, please contact us at privacy@Letstrack.com.

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14.  CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

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15.  NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

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16.  CONTACTING US

16.1 Please contact privacy@Letstrack.com if you have any questions, comments and requests regarding this Privacy Policy.

ANNEX 1 – PERSONAL INFORMATION WE COLLECT

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

ANNEX 3 – MINIMUM AGES