Data Privacy Notice

Last updated August 4, 2025 

Introduction 

LifeSafer (“LifeSafer”, “we”, “our” is a public safety provider company specializing in alcohol monitoring and ignition interlock devices. We are committed to protecting and respecting your privacy.   

This Privacy Notice describes LifeSafer’s policies and practices regarding its collection and use of ”Personal Data” or “Personal Information” as defined by applicable laws, and sets forth privacy rights and obligations on the websites (the “Sites”).  

Data Protection Officer 

LifeSafer is headquartered in Cincinnati, Ohio, in the United States, with offices in various locations around the US and internationally. LifeSafer has appointed an internal data protection officer for you to contact if you have any questions, concerns, or complaints about LifeSafer’ Personal Data policies or practices. If you would like to exercise your privacy rights, please direct your query to LifeSafer’ data protection officer. Please note the different DPO contacts for USA and EU respectively. Contact information is as follows: 

Definitions 

When appearing in this Privacy Notice, the following terms shall have the meanings ascribed to them: 

Administering Authority: The appropriate state authorities responsible for administration of the Program including state courts, divisions of motor vehicles and probation offices, as applicable in the Client’s state. California residents are hereby notified that in California “Administering Authorities” include, but are not limited to: 

• The Department of Motor Vehicles of the State of California and its third-party service providers 

• The Courts of the State of California and their third-party service providers 

• The county probation offices located in the State of California and their third-party service providers. 

Personal Data, also known as Personal Information Personal Identifiable Information; also known as Personal Data; any information relating to an identified or identifiable natural person or as otherwise defined by law. We may collect and process Personal Data about you in the ways outlined below. Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so.  

Data Subject: A natural person who is the subject of Personal Data collection. Also known as a Personal Data principal. Also known as a Client.  

Processing: Any operation or set of operations performed on Personal Data, including collection, recording, organization, storage, alteration, retrieval, consultation, use, disclosure, transmission, dissemination, or destruction. 

Controller: A natural or legal person, public authority, agency, or another body that determines the purposes and means of Personal Data processing. 

Processor: A natural or legal person, public authority, agency, or another body that processes Personal Data on behalf of the controller. 

Consent: Freely given, specific, informed, and unambiguous indication of the data subject’s wishes, either by a statement or by a clear affirmative action. 

Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. 

Devices: Includes Ignition interlock devices, portable alcohol devices, and any other devices offered by LifeSafer  

LMG Holdings, Inc.: This entity is a wholly owned subsidiary of LMG Holdings, Inc., and specializes in devices and services for alcohol monitoring and ignition interlock devices, and their associated applications. 

LifeSafer: LifeSafer is a federally registered trademark of #1A LifeSafer, Inc.  

Data Security and Privacy Safeguards 

LifeSafer endeavors to apply suitable safeguards to protect the privacy and security of your Personal Data and to use it only consistent with your relationship with LifeSafer, Administering Authorities, and the practices described in this Privacy Statement. LifeSafer’ security and privacy practices are governed by adherence to a Privacy Information Management System (PIMS) in accordance with ISO 27001 and ISO 27701. Among the safeguards used is encryption of your Personal Data in transit, at rest, and in process. However, because no electronic transmission or storage of information can be entirely secure, LifeSafer cannot guarantee the security or privacy of your information, to the extent permitted by applicable law. 

LifeSafer’s Role as a Data Controller 

For marketing to visitors to our Sites, LifeSafer is a data controller and determines the purpose and means of Personal Data processing. 

Personal Data 

The Data we collect about You 

When you access our Sites, we may collect, or you may provide us with Personal Data. We may collect, use, store, and transfer different types of Personal Data about you, which we have grouped together as follows: 

• Identity data and identifiers, including categories of Personal Information in Cal. Civ. Code Section 1798.80(e) such as your first name, last name, title, your organization and job role, or other identifiers such as a consumer’s social security, driver’s license, state identification card, or passport number; 

• Commercial Information such as Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 

• Internet or Other Electronic Network Activity Information such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement. 

• Precise Geolocation, including precise physical location  

• Professional or Employment-related information, such as job application or resume information, past and current job history, and job performance information. 

• Inferences drawn from Personal Data, including consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

• Marketing and communications data including your preferences in receiving marketing materials and updates from us and third parties and your communication preferences. 

We also collect, use, and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your Personal Data but is not considered to be Personal Data in law as it does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing specific features. However, if we combine or connect aggregated data with your Personal Data so that it can directly or indirectly identify you, the combined data is Personal Data, and we deal with it in accordance with this privacy notice. 

We do not knowingly collect details about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, sexual orientation, or genetic or biometric data (known as “special categories of data”) through our Sites. If we find we have collected this information inadvertently, we will promptly delete it.  

How Your Personal Data is Collected 

• Direct interaction with you. You may give us identity and contact data by filling in forms on our Sites or by communicating with us by mail, telephone, email or otherwise. This includes data you provide when you request information about our products and services, contact us in relation to our blog, refer a client, download resources, or use interactive features on our site or social media applications. 

• Third parties and publicly available sources. We may receive Personal Data about you from other parties and/or from public sources, as set out below: 

• technical data from analytics providers such as Google Analytics and Pardot and advertising networks such as Google Ads and Remarketing, Facebook Pixel, the X (Twitter) Conversion Tracker, and the LinkedIn Insight Tag; 

• contact information about you from business partners, events, conferences, or industry tradeshows;  

• other individuals under our “refer a client” form. 

• Personal Data collected via automated means. 

• Cookies and similar technologies. We use cookies and similar technologies (collectively “cookies”) to ensure that our Sites function properly, to improve our products and services and to assist with marketing campaigns. Cookies are small text files containing a string of alphanumeric characters. We and third-party partners collect information using cookies, pixel tags, or similar technologies. We and third-party service providers may use the following cookies: 

• Functional cookies. Some cookies are strictly necessary to make our Sites available to you. For example, to provide login functionality or to allow you to fill out forms. We cannot provide you with the Sites without this type of cookie.  

• Analytics cookies. We use cookies for website analytics purposes to operate, maintain and improve our Sites, and to track whether you open emails that we send to you. We work with third parties such as HubSpot, Google Analytics and Microsoft Clarity for these purposes.  

• Advertising cookies. We work with third party advertising partners such as Google Ads and Bing Ads to show you ads that we think may interest you. These advertising partners may set up and access their own cookies on our Sites and they may otherwise collect or have access to information about you which they may collect over time and across different online services. 

Cookie Notice  

We may use first party and third-party cookies on our Sites. “First party cookies” are deployed by us, and “third party cookies” are deployed by our third-party partners.  Use of our Site could generate the following types of cookies: 

• “Necessary” cookies, which are cookies that are necessary for the Sites to function properly. Some of the following actions can be performed by using these cookies: 

• Storing articles in a shopping cart for online purchases 

• Saving your cookie preferences for the Site 

• Saving language preferences 

• Logging in to our portal. We need to check whether you are logged in.  

• “Performance” cookies, which are cookies that are used to gather statistical information about the use of the Site, also called analytics cookies. We use this data for performance and Site optimization.  

• “Functional” cookies, which enable more functionality for our Site visitors. These cookies can be set by us or our external service providers. The following functionalities may or may not be activated when you accept this category: 

• Live chat services 

• Online videos 

• Social media sharing buttons 

• Logins to the Sites with social media 

• “Advertising” or “Tracking” cookies, which are cookies are set by external advertising partners and are used for profiling and tracking data across multiple websites. If you accept these cookies, we may show our advertisements on other websites based on your user profile and preferences. These cookies also save data about how many visitors have seen or clicked on our advertisements in order to optimize advertising campaigns. 

• “Unclassified” cookies, which are cookies that are still in the classification process. They will show up in one of the following categories: Necessary, Performance, Functional, or Advertising. 

Cookies stay on your device for different periods of time depending on the type of cookie that is placed. These include: 

• Session cookies. We use session cookies, which are temporary cookies that remain on your device until you leave our Sites. 

• Persistent cookies. We also use persistent cookies, which remain on your device for a longer period of time to remember your preferences.  

Pixel Tracking. In addition to using cookies, the Sites may employ “pixel tracking,” a common process which may be used in connection with advertisements on other websites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of the Site that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our Sites with your interests and needs. For example, if you visit our Site from an advertisement on a third-party site or service, the pixel tag will allow the advertiser to track that its advertisement brought you to the Site. If you use our Site, and we link you to a third party’s site or services, we also may be able to determine that you were sent to and/or transacted with the third-party’s site or services. This data is collected for use in our marketing, research, and other activities. 

Meta Pixel. We incorporate “pixels” provided by Meta Platforms, Inc. in our Sites. This enables us to track user behavior after a user clicks on a Facebook ad and is redirected to our Site. By doing so, we can assess the effectiveness of Facebook ads for statistical and market research purposes and sometimes re-target (a type of online advertising that targets users that have previously visited our Site) users. Please note that the data collected through this process remains anonymous to us, meaning we do not have access to Personal Data of individual users. However, Facebook stores and processes this Personal Data. Therefore, we are providing you with this information based on our current understanding. It is important to be aware that Facebook may associate this information with your Facebook account and utilize it for its own promotional activities, in accordance with Facebook’s Data Usage Policy available here. You have the option to authorize Facebook and its partners to display advertisements on and off Facebook (see here). Additionally, a cookie may be stored on your computer for these purposes. 

Google Analytics. We use, and/or some of our third-party service providers may use, Google Analytics or other analytics services to help us understand the use of our Sites. Google Analytics is a web analysis service provided by Google. Google utilizes data it collects to track and examine the use of our Site and to prepare reports on the activities occurring on the Sites, and share them with other Google services. Google may use the Personal Data collected to contextualize and personalize the ads of its own advertising network.  

Do Not Track (DNT) Signals. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with the service on the page. Because there is currently no industry or legal standard recognizing or honoring DNT signals, we do not recognize them.  

If you are a visitor from the European Union or the United Kingdom, you will have the option to set your browser to refuse marketing or analytical cookies. If you disable or refuse cookies, some parts of our site may become inaccessible or may not function properly.  

How We Use Your Personal Data 

We will only use your Personal Data when the law allows us to do so. Our most common uses of your Personal Data will be: 

• in order for us to perform a contract we are about to make or have made with you (or to take steps at your request before entering such a contract); 

• if it is necessary for our legitimate interests and your interests and rights do not override those interests; and/or 

• in order for us to comply with a legal or regulatory obligation. 

The table below sets out all the ways in which we plan to use your Personal Data, which of the legal bases we rely on to do so and, where relevant, what the legitimate business interests are. We may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Personal Data. 

Who Do We Share Your Personal Data With 

LifeSafer collects personal information about Data Subjects who use our products and services for ignition interlock services and alcohol monitoring.  

We may also share this information with the following entities: 

• Third parties including affiliates, entities within our group (whether acting as sub processors), who are based in the United States, and internationally, subcontractors, service providers, and entities that provide support, marketing, and administration services and reporting. These third parties may have access to or process your Personal Data as part of providing those services to us. 

• Legal. We may disclose your Personal Data to third parties if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose your Personal Data that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our Sites and any facilities or equipment used to make our Sites available, or (v) protect our property or other legal rights, including to enforce our agreements, or the rights, property, or safety of others. 

• Merger. We may disclose or otherwise transfer Personal Data to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. 

• Consent. We may also disclose your Personal Data with your permission. 

List of third parties and Subcontractors that may process PII  

Microsoft Azure, AWS, Mongo Cloud Database, Google (for GPS tracking data), SendGrid, Five9, Trust Pilot, HubSpot, Twilio  

This list of third-parties and subcontractors may change and shall be updated in this privacy notice from time to time.  Organizations who are the controllers of the data shall be informed prior to the change, through our respective customer service departments and in accordance with the contractual obligations. 

*To subscribe to notifications of changes or updates to this page, please enter your information here.

Processing Personal Data within the U.S. and International Data Transfers 

LifeSafer has offices and data processing facilities in the United States. Information we collect about you will be processed in the United States for all products and services sold in the jurisdiction of the U.S. By using the LifeSafer’ services, you acknowledge that your personal information will be processed in the United States and shall not be transferred to any jurisdiction outside the United States. 

Processing Personal Data Within Canada and International Data Transfers 

LifeSafer has data processing facilities in Canada. Information we collect about you will be processed in Canada for all products and services sold in the jurisdiction of Canada. By using the LifeSafer’ services, you acknowledge that your personal information will be processed in Canada and shall not be transferred to any jurisdiction outside Canada. 

Data subject rights in the U.K. and European Union 

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects. A good explanation of them (in English) is available on the website of the United Kingdom’s Information Commissioner’s Office. https://ico.org.uk/  See also the website for the European Data Protection Board (EDPB) https://edpb.europa.eu/edpb_en  

Residents of the EU and UK have the following rights: 

1. Access and Portability. You may ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have provided to us, and request information about its processing. 

2. Rectification and Deletion. You may ask us to update and correct inaccuracies in your Personal Data, or to have the information anonymized or deleted, as appropriate. 

3. Restriction and Objection. You may ask us to restrict the processing of your Personal Data, or object to such processing. 

4. Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdraw your consent. 

5. Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance. 

Data Subject Rights in the United States 

Certain states in the U.S., including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (or will in the future provide) their state residents with rights related to their Personal Data.  Some such rights apply generally, but certain of such rights will only apply to a limited set of individuals or in limited circumstances, depending on a person’s jurisdiction of residence. To the extent that these laws apply, you may exercise the following rights:  

• Right to Know and Access Information. Note that much of the information you are entitled to know or access is disclosed in this Privacy Notice. With that said, you have the right to know about our Personal Data processing practices. You also have the right to know and access the categories of Personal Data we collect, with whom we share or sell that Personal Data, and, in some cases, what specific Personal Data we associate with you or your account.  

• Right to Data Portability. If you request a copy of your specific Personal Data, then we will provide it in an easily accessible format. 

• Right to Deletion or Erasure. You may request that we delete the Personal Data we have collected about you. Depending on the applicable law, in some cases we are required or permitted to retain your Personal Data, even if you validly request that we delete or erase it.  

• Right to Correct Information. You may request that we correct or rectify any inaccuracy in the Personal Data that we have collected about you. 

• Right to Opt-out of Targeting Advertising, Sales, or Profiling. You may opt-out of our use of your Personal Data for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects.  

To exercise any privacy rights to which you are entitled under applicable law, contact us using the contact information provided within this Privacy Notice.  

Appeal. If we deny your request relating to your Personal Data, you may have the right to request an appeal of our decision, depending on your state of residence. To initiate an appeal, follow the instructions provided in the communication denying your request, or contact us using the contact information provided in this Privacy Notice.  

Non-Discrimination. You may have the right not to experience discrimination by us for exercising the rights listed in this section, depending on your state of residence. What we mean by discrimination is denying you access to our Sites or limiting the quality of our Sites.  

To exercise your rights, please make a request by email to dpo@scramsystems.com.    

Data Storage and Retention 

Retention of data that is owned by an Administering Authority (Controller) is managed by that Administering Authority. We will retain Personal Data we process on behalf of our customers for as long as needed to provide services to our customers. We will also retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Retention of data laws and regulations vary from jurisdiction to jurisdiction, and it is incumbent upon the controller to ensure that its contracted or approved processors such as LifeSafer delete personal information according to contract or explicit request.  Any request from a data subject to delete personal information owned by the respective controller shall be redirected to the Controller.  LifeSafer shall delete personal information solely collected and used for marketing purposes upon the data subject’s request and in accordance with local data privacy laws. To make this request, contact the Data Protection Officer at dpo@scramsystems.com. 

SMS Text Opt In/Out Service Information 

Monitoring clients have the option to sign up for automated SMS Text reminders as part of their monitoring service. When an individual opts into the service, we will send an SMS message to confirm registration. 

Monitoring clients can cancel the SMS Text service at any time. Text “STOP”. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time, and we will start sending SMS messages to you again. 

If at any time you forget what keywords are supported, just text “HELP”. After you send the SMS message “HELP” to us, we will respond with instructions on how to use our service as well as how to unsubscribe. 

Please note: Carriers are not liable for delayed or undelivered messages. 

As always, message and data rates may apply for any messages sent to you from us and to us from you. You will receive messages as agreed to in the Program Sites Agreement. If you have any questions about your text plan or data plan, it is best to contact your wireless provider. For all questions about the services provided by this short code, you can send an email to info@scramsystems.com. 

Marketing 

You may receive marketing communications from us if you have requested such information from us. You may also receive marketing communications from us if you have purchased similar products or services from us or if you provided us with your details. 

You can ask us, and/or any third party, to stop sending you marketing messages at any time by following the opt-out links in any marketing message sent to you. 

If you opt out of receiving any marketing messages, this will not apply to Personal Data provided to us for other purposes, for example, as a result of your purchase of a product or service, warranty registration or other transactions. 

Third Party Websites 

Our Sites may include links to third-party web, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third parties and are not responsible for their privacy policies. When you leave our Sites, we recommend that you read the privacy policy of every website you visit and every plug-in or application you use. 

Changes to this Policy 

We may update or change this Privacy Notice from time to time. We will post the changes on our Sites and will indicate the effective date. Your continued use of Sites after the changes are effective constitutes your acceptance of the Privacy Notice as so updated.