Last Updated: January 1, 2019
II. PERSONAL INFORMATION WE COLLECT
A. Information You Give Us LifeSafer is committed to adhering to the Digital Advertising Alliance self-regulatory principles (“DAA Principles”) that govern best practices for Interest-based and Internet-based advertising (“IBA”). Our use of IBA is described in more detail below. Consistent with DAA Principles, if you would like to opt-out from such third party data collection for use in IBA, please visit the Digital Advertising Alliance Consumer Choice Page at www.aboutads.info/choices. Except for physical location information and tracking technologies (as described below), you do not have to give us any personal information to browse this Site. However, you may be asked to provide personal information to submit or request information from us, or to use the services offered through this Site. Once you provide us with your personal information, you are no longer anonymous to us. This information may include:
TYPE OF PERSONALLY IDENTIFIABLE INFORMATION (PII) WHAT IT INCLUDES WHERE WE GET IT HOW WE USE IT TO WHOM WE DISCLOSE IT
Contact information Full name Birthdate Home address Home and business telephone numbers (which may be cellular numbers) Email address Client Authorities administering ignition interlock program in which client participates (“Program”) (“Administering Authorities”) Client’s closest relative, if necessary to locate client To provide Services To obtain payment for the System or Services (“Payment”) To locate client To send client marketing information To report to or communicate with Administering Authorities To report to or communicate with other governmental, law enforcement, and judicial authorities, and other persons or entities, as we reasonably believe is necessary to provide Services or carry out Program obligations (“Other Authorities”) Administering Authorities, to provide Services and fulfill contractual obligations (such as inspection and audit) Other Authorities, to provide Services Client’s financial institution, to obtain Payment Third parties (including our vendors), as needed to provide Services, service or maintain the System, locate client, and/or obtain Payment Full Social Security number (where permitted by law) *Under most State laws, a truncated SSN (for example, the last four digits) is not considered PII, and we will not treat it as PII Social Security number If we are permitted by law to collect client’s SSN, we will directly seek it only from client. However, SSN may be incidentally included in information from Administering Authorities As permitted by law: To locate client To obtain Payment As permitted by law: Administering Authorities, to provide Services and fulfill contractual obligations (such as inspection and audit) Other Authorities, to provide Services Client’s financial institution, to obtain Payment Third parties, as needed to locate client and/or obtain Payment License/vehicle information Driver’s license number, vehicle identification number (“VIN”); vehicle plate number Client Administering Authorities To provide Services To report to or communicate with Administering Authorities To report to or communicate with Other Authorities Third parties (including our vendors), as needed to provide Services, or service or maintain the System Administering Authorities, to provide Services and fulfill contractual obligations (such as inspection and audit) Other Authorities, to provide Services Payment information Credit or debit card number Client To obtain Payment Client’s financial institution, to obtain Payment Third-party service providers, to process Payment Driving information Information regarding the client’s vehicular accidents, driving violations, and driver’s status Administering Authorities To provide Services To report to or communicate with Administering Authorities To report to or communicate with Other Authorities Administering Authorities, to provide Services and fulfill contractual obligations (such as inspection and audit) Other Authorities, to provide Services Information generated by the ignition interlock System Information collected, monitored, stored, downloaded, and reported by the System installed in the client’s vehicle, including the client’s breath alcohol concentration, photographs (if the System is camera-enabled), GPS data (if the System is camera-enabled), information related to inspection of the System System To provide Services To report to or communicate with Administering Authorities To report to or communicate with Other Authorities Administering Authorities, to provide Services and fulfill contractual obligations (such as inspection and audit) Other Authorities, to provide Services
B. Location Information. In order to access and use certain areas or features of the Site, you consent to our collection and use of your physical location information if you use the Site on a location-enabled device (including GPS, cellular, and Wi-Fi networks) or from your browser.
III. HOW WE USE PERSONAL INFORMATION
LifeSafer complies with its obligations under applicable privacy laws by: keeping personal data up to date where needed based on the purposes for which the personal data is being processed; by not collecting or retaining excessive amounts of data; by ensuring that appropriate technical measures are in place that are designed to protect personal data from loss, alteration, misuse, unauthorized access and disclosure as it is transmitted, stored, or otherwise processed, and by using appropriate measures to securely destroy personal data when it is no longer needed by LifeSafer. Personal information collected through the Site may be used by us and our affiliates for purposes of: Responding to your questions and feedback; Providing the services you select through this Site; Contacting you, whether by email, postal mail, or telephone with information about this Site, our products, or our services; For such purposes as you may authorize at the time you submit the information; Auditing, research, and analysis to maintain, protect, and improve this Site and our services; Ensuring the technical functions of our network; Improving and customizing the content and layout of the Site; Developing new products and services; or Compiling personal information and other information collected through the Site on an aggregate basis.
IV. PERSONAL INFORMATION WE SHARE
V. AGGREGATE INFORMATION
VI. YOUR CHOICES
A. Information You Provide You can always choose whether or not to provide information on the Site. However, if you choose not to disclose certain information, you may not be able to register as a user of the Site, which may limit your access to certain portions of the Site.
B. Communications From Us If at any time you decide that you no longer wish to receive notices from us regarding the Site, you may indicate this preference by contacting us at firstname.lastname@example.org.
D. Your Rights and Your Personal Data Unless subject to an exemption under the GDPR, if your personal data is subject to the GDPR, you have the following rights with respect to your personal data: The right to request a copy of your personal data which the LifeSafer holds about you; The right to request that the LifeSafer correct any personal data if it is found to be inaccurate or out of date; The right to request your personal data be erased where it is no longer necessary for LifeSafer to retain such data; The right to withdraw your consent to the processing at any time of personal data to which you provided consent for processing; The right to request that LifeSafer provide you with a copy of your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability); The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction be placed on further processing; The right to object to the processing of personal data (where applicable); and The right to lodge a complaint with a data supervisory authority.
E. Transfer of Data Abroad If your personal data is subject to the GDPR, LifeSafer will transfer personal data from the European Economic Area (EEA) to a location outside the EEA only when there has been a documented adequacy determination, or where LifeSafer has confirmed adequate privacy protections. If LifeSafer transfers personal data to a third party acting as an agent of LifeSafer, we will also obligate the third party to have adequate privacy protections in place. LifeSafer may transfer personal data to and on behalf of clients and third party’s with whom LifeSafer has an existing service agreement or as part of our legal obligations, each of which shall be subject to LifeSafer policies, and only to the extent necessary for purposes of legitimate interests pursued by the data controller (or by a third party).
F. Automated Decision Making Under the GDPR, data subjects have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent. We do not engage in automated decision making.
VII. INFORMATION STORAGE AND SECURITY
We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Site. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.
VIII. A SPECIAL NOTE ABOUT CHILDREN AND CALIFORNIA RESIDENTS
IX. EXTERNAL LINKS
X. SPECIAL ADMONITIONS FOR INTERNATIONAL USE
The Site is hosted in the United States. All matters relating to the Site are governed exclusively by the laws of the State of Ohio in the United States of America and not the jurisdiction in which you are located. If you are located outside of the United States of America and you contact us, please be advised that any information you provide to us will be transferred to the United States of America and that by submitting information, you explicitly authorize such transfer.
LifeSafer Legal Department
Attn: Copyright Agent
4290 Glendale Milford Road
Blue Ash, Ohio 45242
Any data subject may, at any time, contact us directly with any questions and suggestions concerning data protection. We encourage interested persons to raise any concerns about the collection, use, or processing of personal data using the contact information provided above. In the event of a privacy related issue or complaint, we will investigate and attempt to promptly resolve any complaints and disputes regarding use and disclosure of personal data. For complaints that cannot be resolved, if your personal data is subject to the GDPR, we commit to cooperating with the panel established by the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC), as applicable, and comply with the advice given by the DPAs or FDPIC about personal data transferred from the EU or Switzerland. In order to facilitate the handling of complaints, individuals in the EU can choose to contact their national DPA or use the form located at this link: http://ec.europa.eu/newsroom/document.cfm?doc_id=42962 Individuals in Switzerland can contact the Swiss FDPIC by visiting: https://www.edoeb.admin.ch/edoeb/de/home.html This independent dispute resolution process is provided at no cost to the individual.