Consumer Safety Technology Privacy Notice

Effective November 2022

ATTENTION: PLEASE READ THIS PRIVACY NOTICE CAREFULLY BEFORE YOU ACCESS, DOWNLOAD, OR OTHERWISE USE OUR SERVICES. THIS PRIVACY NOTICE IS INCORPORATED BY REFERENCE INTO THE CONSUMER SAFETY TECHNOLOGY, LLC TERMS OF USE FOUND HERE.

Consumer Safety Technology, LLC is committed to safeguarding the privacy of its visitors to its website, including but not limited to its following brands: Intoxalock, Restorify, DUI.org, DUIcare, US Court Assessments, New Directions, (collectively “We” or “CST”). CST offers products and services to consumers through our websites, as well as any interactions with our live agents, websites, mobile applications, contests, sweepstakes, promotions, surveys, and forums (collectively, “Services”). This Privacy Notice describes the information We collect through your use of our Services, how We use it, how We share it, how We protect it, and the choices you can make about your information.

NOTICE. By continuing to use our Services, you acknowledge (a) that you have read and understood this Privacy Notice; and (b) this Privacy Notice shall have the same force and effect as a signed agreement.

Unless explicitly stated otherwise, any new products, services or features that enhance the current Services shall be subject to this Privacy Notice.

This Privacy Notice is part of the CST Terms of Service, which can be found here Terms of Use. Any terms defined in the Terms of Service that are not defined in this Privacy Notice shall have the same meaning in this Privacy Notice.

CST reserves the right to modify this Privacy Notice at any time in its sole discretion, in accordance with applicable law. You acknowledge that it is your responsibility to check this Privacy Notice periodically for any changes. Your continued use of the Services following the posting of changes will mean that you accept and agree to any changes to the Privacy Notice.

We collect information from you when you submit a request or inquire about our products or services, when you use our Services, or otherwise contact or interact with us. The information we collect may come from the following sources:

• Information you provide to us directly;
• Information you voluntarily share with our affiliated entities;
• Information you voluntarily share with third-party partners that we work with;
• Information that is publicly available (this does not constitute personal information);
• Information you provide to us when you register to receive communications from us (such as an email address or other contact information);
• Information you provide us when you enter promotions or sweepstakes offered by CST;
• Information you provide us through telephone or web-based surveys, customer service correspondence and general feedback; and,
• Information you provide us when you apply for a job with CST.

Types of information that We may collect from you, our affiliated entities and external third-party sources include:

• Your name;
• Contact information including email address, telephone number, and address;
• Citation information including city, county, state, blood alcohol content, DUI history, incident data, and court date information;
• Criminal history;
• Vehicle information;
• Date of birth;
• Drivers’ license information;
• Alcohol monitoring requirements including device requirements, monitoring authority, and install by date;
• Information collected by our products including user device data, photographs, and global positioning system (GPS) data;
• Payment information;
• Personal information provided by Facebook, Instagram, Linkedin, Twitter, Google, and Microsoft if you connect with these websites or applications through our Services;
• Information collected from your interactions with our digital properties;
• Your device information including your device’s Internet Protocol address, Device ID, Mobile Device Advertising ID (MAID), other PPI (Persistent Personal Identifiers), your page visits, and other general online analytics information. Additional information collected is described in the Analytics and Cookies sections below;
• Information you provide us in connection with a job application;
• Information you provide us in connection with a request to become an affiliated partner; and,
• Any other information that you voluntarily provide to us.

We also collect demographic information. Demographic information is all other information such as gender, zip code, or any information that is not tied to your personal information. In addition, we may receive information about you from third parties who provide appended information to create demographic profiles. This helps us to update, expand and analyze our existing information to tailor products and services that may be of interest to you.

We may also receive information from certain government agencies such as the DMV, in order to comply with legal obligations and to validate the information we have about you in connection with providing you the Services.

We may record conversations you have with a live agent, either via chat or on the phone. These recordings are collected and stored by us in order to perform quality assessments in connection with providing you the Services. We do not share these recordings with any third parties, except to the extent necessary to comply with a legal obligation. Our chat or phone providers may have access to the recordings solely to provide their services to us (please see Section III(A) below for more information).

We may combine all of the information we collect from or about you and use it in the manner described in this Privacy Notice.

We use the information that We collect for several purposes, including:

• The purposes for which you provided the information;
• To provide you with the products or services you reasonably expect from us;
• To provide information about our products and services or other information that we think may be of interest to you;
• To process and respond to your inquiries and requests;
• To connect you with third-party providers or our affiliated entities to provide you with your requested products and services;
• To promote and advertise our and our affiliated entities’ products and services to you;
• To contact you for market research purposes and to use this information to customize our Services according to your interests;
• To administer, operate, and improve our Services or to further the mission of CST;
• To personalize and enhance your experience using our Services;
• To provide you with occasional news, updates, or related product or service information;
• To engage with you on social media platforms;
• To allow you to use our mobile application;
• To contact you about potential vendor opportunities if you visit one of our vendor pages;
• To generate and review reports and data about our user base and Services usage patterns;
• To analyze the accuracy, effectiveness, usability or popularity of our Services;
• To compile aggregate data for internal and external business purposes;
• To prevent fraud and abuse of our Services and to otherwise protect users and visitors and our business;
• To comply with the law;
• To assist law enforcement and respond to subpoenas or other regulatory or legal proceedings; and
• To perform other business activities as needed, or as described elsewhere in this Privacy Notice.

CST does not sell its customer data or customer personal information to third parties. We will only share your information as outlined in this Privacy Notice, and as otherwise permitted by law.

Information may be disclosed to third parties in accordance with our Privacy Notice. Please note that a user may choose not to share certain information as described in Your Choices Regarding Your Information below.

A. Third Party Service Providers and Business Partners. We may use third party service providers and business partners to perform functions in connection with our Services, such as administration services; marketing or advertising services ; technical services relating to the maintenance, servicing, and upgrading of our products; hosting services; customer service; data migration services; payment processing services; debt collection services; and analytical services, among others (collectively, “Business Functions”). We may disclose your information in connection with these Business Functions for a business purpose as defined in the California Consumer Privacy Act, amended by the California Privacy Rights Act. For more information, please find our Supplemental California Privacy Notice here .

We may also use the following third-party service providers and business partners to perform functions in connection with our online Services, such as email marketing and other marketing services, site analytics, social sharing, relationship management, functions related to analyzing and improving our Services usefulness, reliability, user experience, and operation, storing data, and as otherwise described in this Privacy Notice. Some of these third-party service providers and business partners include the following, which may change from time to time:

• Adobe Typekit. We use Adobe Typekit to serve fonts on our website and to enhance the performance of our website. Adobe Typekit may collect information relating to your JavaScript version, the amount of time it takes for You to download and apply fonts, and whether you are using an ad blocker and the effects of Your ad blocker on website rendering. For more information on Adobe Typekit, please visit Adobe Typekit's privacy policy: https://www.adobe.com/privacy/policies/typekit.html.
• Advertising Platforms. We use third-party advertising platforms to serve ads to you about our and our affiliated entities’ products and services across multiple platforms. These third-party platforms may collect information such as your browser information, Internet Protocol address, name, email address, cookie data, and other general analytics information to allow us to provide customized ads to you.
• DoubleClick/Google Ad Manager. We use DoubleClick/Google Ads to improve advertising. DoubleClick/Google Ads is a Google/Alphabet service used for advertising. For more information on the information DoubleClick/Google Ads will collect, please visit https://support.google.com/admanager/answer/2839090?hl=en&ref_topic=7395141 . If You wish to opt-out of DoubleClick/Google Ads’ use of cookies, please visit: https://support.google.com/ads/answer/2662922?hl=en&ref_topic=7048998 or https://optout.networkadvertising.org/?c=1#!%2F.
• Facebook/Meta. By clicking on the Facebook button on our Services, you will be automatically transported to the official Facebook Page for Intoxalock®. CST allows users to comment on blog posts using the Facebook Comments Plugin and in doing so, CST may have access to personal information about you. For more information on the Facebook Comments Plugin, please visit, https://developers.facebook.com/docs/plugins/comments.
• Instagram. By clicking on the Instagram button on our Services, you will automatically be transported to the official Instagram page of Intoxalock®.
• LinkedIn By clicking on the LinkedIn button on our Services, you will be automatically transported to the official LinkedIn profile for Intoxalock®.
• Live Chat Functionality. We use third-party service providers to provide live chat functionality on our Services. When you connect with us via the live chat function, we may share your name, email address, and any other information that you provide to the live chat service.
• Trustpilot. We use TrustPilot to facilitate reviews of our Services. TrustPilot may display your profile name, profile photo, and actions you take on TrustPilot's site or on other third-party applications connected to your TrustPilot account, including displaying ads and other commercial content. For more information, please visit the TrustPilot privacy policy here: https://legal.trustpilot.com/end-user-privacy-terms.
• Twitter. By clicking on the Twitter button on our Services, you will automatically be transported to the official Twitter feed of Intoxalock®.
• VWO. We use VWO to evaluate our visitors’ behavior on our Services and to gather feedback related to user experience on our Services. VWO may collect heatmap analytics information, browser information, other hardware information, Your IP address, and other behavioral indicators on our Services. For more information, please visit VWO’s privacy policy at: https://vwo.com/privacy-policy/.
• YouTube. We host videos on YouTube that are embedded on the Website. These are hosted on CST’s accounts. By viewing the videos on the Services, YouTube may collect your information, including your Google username and other account information. For more information, please visit the YouTube privacy policy at: https://policies.google.com/privacy?hl=en
• Other Website Trackers. We use third-party service providers to provide marketing services for us, or to create demographic profiles to understand our customer’s needs better. These service providers may match users who visit our websites with other identifying information they may already have. In the course of providing their services to us, these third-party service providers may collect your device’s Internet Protocol address and other PPI (Persistent Personal Identifiers) to allow us or them to contact you about our and our affiliated entities’ products and services.

We also may share your personal information with these providers and partners to market and promote our Services to you online, or through offline advertising methods such as direct mail. If you opt-in to a short code or SMS campaign with us, we may share your personal information with service providers, however, they will not use your information for their own text message marketing purposes.

B. Business Changes. If We become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, We may transfer Your information to a third-party or parties in connection therewith.

C. Affiliated Entities We may share your information with our affiliated entities for purposes consistent with this Privacy Notice. We also may share your personal information with our affiliated entities for their direct marketing and promotional purposes and so they can provide services to you. Our affiliated entities will be required to maintain that information in accordance with this Privacy Notice.

D. Providers. We may share your information with third-party providers for purposes consistent with this Privacy Notice. In addition, as part of Our Services, you may voluntarily elect to be connected with relevant third-party providers of services related to managing issues related to DUIs. For some Providers, We may provide them with your telephone number or other contact information for them to contact you.

E. Investigations and Law. We may disclose information about you to third parties if We believe that such disclosure is necessary to:

• Comply with the law or guidance and cooperate with government or law enforcement officials or private parties;
• Investigate, prevent or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety, and property of us, users or others, or violations of our policies or other agreements with us;
• Comply with legal and contractual requirements in connection with the Services, such as providing information about you pursuant to a court order, or to parole officers and other authorized monitoring entities;
• Respond to claims and legal process (for example, subpoenas); and/or,
• Protect against legal liability.

F. Aggregated Information. We may share aggregated information relating to users of our Services with affiliated entities or third parties. This aggregated information does not contain personal information about a particular user or information that may be reasonably linked to a unique user.

G. Analytics. We use third-party analytics tools to better understand who is using our Services and how people are using them. These tools may use cookies and other technologies to collect information about your use of our Services and your preferences and activities. These tools collect information sent by your device about your use of our Services and other information that assists us in improving our Services. This information may be used to analyze and track data, determine the popularity of certain content, and better understand your online activity, among other things.

We use Google Analytics to better understand who is using our Services and how people are using them. Google Analytics uses cookies to collect and store information such as Service pages visited, places where users click, time spent on each Service page, Internet Protocol address, type of operating system used, location-based data, device ID, search history, gender, age, and phone number. We use this information to improve our Services and as otherwise described in this Privacy Notice. Please see http://www.google.com/policies/privacy/partners/ for information about how Google Analytics uses this information, and visit https://tools.google.com/dlpage/gaoptout for information about the Google Analytics Opt-out Browser Add-on. Google may track your activity over time and across websites.

H. Cookies and Other Tracking Technologies. We, along with third parties, use cookies, local storage objects, web beacons and other similar technologies. These technologies are used for tracking, analytics and personalization and optimization of the Services.

Cookies are small files that are transferred to and stored on your computer through your Web browser (if you allow it) that enable the website’s or service provider’s system to recognize your browser and capture and remember certain related information. You can instruct your browser to either stop accepting cookies, clear your browser cookies or adjust browser settings yourself. But if you do not accept certain cookies, you may not be able to use all portions of the Services due to functionality limitations. Here are the types of cookies that may be deployed by your browser:

• Persistent cookies remain on the visitor’s computer after the browser has been closed.
• Session cookies exist only during a visitor’s online session and disappear from the visitor’s computer when they close the browser software.
• Flash cookies (also known as local shared objects) are data files that can be created on your computer by the websites you visit and are a way for websites to store information for later use. Flash cookies are stored in different parts of your computer from ordinary browser cookies. You can disable the storage of flash cookies. For additional information about managing and disabling flash cookies, please visit http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Web beacons are small strings of code that provide a method for delivering a graphic image on a Web page or in an email message for the purpose of transferring data. You can disable the ability of web beacons to capture information by blocking cookies.

We use cookies and other tracking technologies on our Services to help us understand and save your preferences and interests so We can personalize your future visits. We also use cookies and tracking technologies to compile aggregate data about website traffic and website interactions so that We can offer better website experiences and tools in the future.

Some of our business partners, such as our analytics providers, advertising networks, social sharing provider, and social media connections, also use cookies and other tracking technologies on our website, which may track users across websites and over time.

We implement a variety of security measures to protect the safety of your personal information when you enter, submit, or access your personal information.

While We take reasonable measures to protect the information you submit via our Services against loss, theft and unauthorized use, disclosure, or modification, We cannot guarantee its absolute security. No Internet, email, or mobile application transmission is ever fully secure or error free. Email or other messages sent through our Services may not be secure. You should use caution whenever submitting information through our Services and take special care in deciding which information You provide us.

We cannot guarantee that transmissions of your personal information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR THE DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD-PARTY ACCESS, OR CAUSES BEYOND OUR CONTROL.

Any information collected through our Services is stored and processed in the United States. If you use our Services outside of the United States, you consent to having your data transferred to the United States.

Unless otherwise required by law, We will retain your personal information to the extent necessary to fulfill the purpose for which that personal information was collected. Please note that We may be required to retain your personal information for a reasonably longer period of time to the extent necessary to comply with regulatory or legal obligations, resolve disputes, enforce our agreements or for any other business purpose in accordance with applicable laws.

We may maintain anonymized or aggregated data, including usage data, for analytics purposes. Please note that some or all of the information We have collected may be required for our Services to function properly.

This Privacy Notice applies only to our Services. Our Services may contain links to other websites or apps or may forward users to other websites or apps that We may not own or operate and to which this Privacy Notice does not apply. The links from our Services do not imply that We endorse or have reviewed these websites or apps. The policies and procedures We describe here do not apply to these websites or apps. We neither can control nor are responsible for the privacy practices or content of these websites or apps. We suggest contacting these websites or app providers directly for information on their privacy policies. Nonetheless, we seek to protect the integrity of our Services, and welcome any feedback about these linked websites and mobile applications.

You have choices regarding the use of Your information.

• Changing Your Information – To change or update your information, please contact us by calling 1-844-535-0260. You can also make changes to your information through your account portal, if you have created a user account.
• Marketing Opt-Out – To opt-out of receiving promotional or marketing communications that We provide to you or that you consent to receive, as applicable, by mail, email, phone, or text message, contact us by writing to Consumer Safety Technology, LLC, Attn: Marketing Opt Out, 11035 Aurora Avenue, Des Moines, IA 50322, with your request and include (i) your name and account number (if applicable), (ii) if you are requesting communications to cease via mail, email, phone, or text message, (iii) the specific mailing address(es), phone number(s) or email address(es) to which the opt-out applies, and (iv) the specific business to which your opt-out request applies (Intoxalock, Restorify, US Court Assessments formerly New Directions, DUICare, or DUI.org). Alternatively, please use the following form to submit your opt-out request.
• California Consumers – Please see Section XII below on how to exercise your rights.

Your browser or device may offer you a “Do Not Track” option, which allows you to signal to operators of websites, web applications, mobile applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites or applications. Generally, our Services do not support national Do Not Track requests at this time, which means that in certain circumstances, We or our analytics providers or other third parties with which We are working may collect information about your online activity both during and after your use of our Services. However if you are a California Consumer, you may have specific rights with respect to certain privacy opt-out signals, which we honor provided that they are in accordance with applicable laws – please see the California Privacy Notice for more information.

Our Services are not intended for children under 16 years of age. We do not knowingly collect personal information from an individual under age 16. If You are under the age of 16, please do not submit any personal information through our Services. If You have reason to believe that We may have accidentally received personal information from an individual under age 16, please contact us immediately as provided in Section XI, below.

We reserve the right to update or modify this Privacy Notice at any time without prior notice, however you will be notified if We make any material changes that affect the use of your personal information before it takes effect. If you do not agree with the changes to how your personal information will be used, please do not continue to use this website. Your continued use of the website or Services after you have been notified of changes to the Privacy Notice will mean that you accept and agree to the changes to this Privacy Notice. Please review this Privacy Notice periodically, and especially before you provide any information. This Privacy Notice was made effective on the date indicated above.

Please feel free to contact us by calling 1-844-535-0260, by writing to Consumer Safety Technology, LLC, Privacy Notice, 11035 Aurora Avenue, Des Moines, IA 50322, or by visiting the ‘Contact Us’ page at www.intoxalock.com if you have any questions about this Privacy Notice.

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by contacting us as provided in Section XI, above.

If you are a resident of the state of California, USA, please see our supplemental California Privacy Notice California Privacy Notice which discusses additional privacy rights you may have under applicable law regarding the processing of your personal data.