PRIVACY POLICY

This Privacy Policy governs the treatment by SmartDrive, Inc. d/b/a Surete (“Surete”, “we”, “our”, or “us”) of both anonymous and personally identifiable information that Surete collects when you use the Surete website (www.surete.co), application and associated features (collectively, the “Site”) and when you provide information to us in any medium for our Surete Service (the “Service”). Current subscribers to the Service and other users of our Site are or may be subject to our Terms & Conditions (“Terms and Conditions”), which can be viewed at http://surete.co/terms-of-use/.

We value your privacy and are dedicated to protecting your information and providing you with NOTICE about our information collection and use practices and how you have a choice about all of it.

USERS/SUBSCRIBERS

Surete collects information you provide to us when you purchase products from us and when you subscribe to and/or use the Service. For example, you may provide us (or third party payment process performing this service for us) a billing address and credit card information, including your name, address, email address and telephone number, when you become a user of the Service or perhaps purchase a product, device or service through our online store on our Site. When you register online to subscribe, purchase, activate and/or use the Service, you must complete a registration form that may require you to provide personally identifiable information, including your name, company name (if applicable), address, email address, phone numbers.

The Administrator (“Admin”) is granted the ability to rules and policy for each phone registered to an activated Surete device. Once policy is applied by the Admin, the Service can block certain voice, data or email communications as dictated by the policy, as well as other functionality not enabled through the Surete application.

SURETE DOES NOT COLLECT OR STORE BLOCKED VOICE, DATA OR EMAIL COMMUNICATIONS.

Our Site may also offer interactive services, such as form submissions, chat rooms, forums and message boards. Please remember that any information that you disclose in these areas becomes public information, and you should exercise caution when deciding to disclose personally identifiable information in these areas.

You must be at least eighteen (18) years old to register online for the Service or purchase any of our products. If you are a minor (under the age of eighteen), please do not submit any personally identifiable information to us. We do not knowingly collect, maintain, or sell products or services to people under 18.

DATA COLLECTION

Surete automatically receive certain types of anonymous information which do not identify you personally, whenever you interact with us. The anonymous information includes the pages you view on the Site, the search terms you enter into the search utility, your IP address and the operating system, browser software and Internet service provider you use.

We may track your movement within the Site, the third-party website pages from which you were referred, your use of the Account Management features, access times and browser types. We use this information to gauge the effectiveness of our Site, track information for statistical purposes and to improve the products and Services we provide.

COOKIES

Surete uses the standard “cookie” feature of major browser applications and other data capture mechanisms that allow us to store data about your visit to our website. We store information that we collect through cookies, log files and other tracking technology such as clear gifs. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use session ID cookies and persistent cookies. We use session cookies to make it easier for you to navigate our Site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Persistent cookies are used to differentiate users of the Site from subscribers, to customize the content of certain sections of the Site and to enable us to track and cater to the interests of users, in order to enhance their experience on the Site. Cookies help us learn which areas of our site are useful and which areas need improvement. We will not use cookies or other data capture mechanisms to collect any personally identifiable information about you. We may also use cookies in connection with Google analytics.

You may configure your browser to prevent cookies from being set on your computer. If you reject cookies, you may still use the Site, but your ability to use some areas of the Site may be limited and you may not be able to use certain features of the Site.

SUPPLIMENTAL INFORMATION

Surete may supplement the information you provide us by acquiring commercially available demographic and marketing information from third parties to help us better serve you, for instance, to verify your address or to update your information and to create a profile of your preferences. We tie your personally identifiable information to information in the profile, and use it to improve the content of the Site for you or to inform you about products or services that we think will be of interest to you. Some demographic information, which you are not required to provide, include: your age, gender; the number of drivers in your household; the make, model and age of your car; information about your commute and the amount of time you spend driving.

THIRD PARTY LINKS

Our Site may contain links to other websites. We are not responsible for the content or privacy practices of those websites, including the use of personally identifiable information about you collected by those websites. We encourage you to be aware when you leave our Site and to read the privacy statements of websites you visit that collect personally identifiable information. This privacy statement applies only to information collected by us on the Site and collected when you subscribe to, activate or use the Service or purchase products or services from us.

ADVERTISEMENTS

We may from time to time use various outside ad-serving companies and affiliates to serve advertisements on the Site. In the process of serving advertisements, the ad serving companies may place a cookie in your browser’s cookie file and may use information about your visits to the Site and other websites in order to provide advertisements on the Site about products and services that may be of interest to you.

USE OF ANONYMOUS INFORMATION

We use the anonymous information we collect from our Site and your IP address to administer our site, improve our goods and the Service, determine how our Site is being used, identify popular areas of our Site and analyze trends and usage patterns. We may use your IP address to help diagnose problems with our server.

PERSONAL INFORMATION

We receive and store any personal information you enter on the Site or give to us voluntarily in any other way and may use it to contact you from time to time. We will use your information to (i) provide and improve the Service, (ii) enforce the Terms & Conditions, as applicable, (iii) offer you extensions or renewals of Service, or new products and services, (iv) send you information on products, services, special deals, promotions, or information which we think may interest our users and subscribers, and (v) perform market research. We do not knowingly market or sell the Service to, or knowingly solicit information from, anyone who is under 18.

By registering on the Site, or by subscribing to the Service and providing your telephone number, you agree that this action constitutes a purchase, inquiry and/or application for purposes of telemarketing laws. Regardless of the fact that your telephone and/or cell number may be listed with the Federal Do-Not-Call Registry, or your local State Do-Not-Call list, you expressly consent to receive future information about products and services from us, and in, that regard, you hereby consent to our contacting you pursuant to the business relationship established using the information you provided to us. This means we may contact you, in person or by recorded message, by e-mail, phone and/or cell number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving, except as may be prohibited by law.

We may employ other companies and individuals to perform functions on our behalf. Examples might include, but are not limited to, fulfilling orders, payment processing, sending e-mail, analyzing data or trends collected from your use of the Site, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links and providing customer service. These companies or individuals may be granted temporary access to your personal information as needed to perform the task at hand. We (or our third-party vendors) will use your credit card information only to charge you for any paid products and services you have authorized. We will not supply your credit card information to any third party except the credit card company or associated billing company.

We (or our affiliates) may share personally identifiable information and demographic information with third parties in order to have them send you special offers and promotions or other information we think you might find of interest. They may use your email address, postal address, or telephone number, to provide you with information about their products or services. You acknowledge and agree that we have this right to make our customer list, and portions thereof, and your information available to these select third parties. If you do not want us to provide your information to third party companies, it is your obligation to please let us know, by contacting us at support@surete.co.

SECURITY

Please note that we use a third-party payment processor to handle processing of payment for all orders originated at surete.co. Accordingly, you recognize that you will leave our Site and provide financial information to the third-party payment processor in order to complete your order. We are not responsible for the security or safety of any financial information provided to these providers in order to complete your Surete purchase online. You agree to hold Surete harmless from any loss that you may incur as a result of submitting your financial information to the payment processor in order to complete your order.

It is important for you to protect against unauthorized access to your password, your phone and to your computer. Be sure to sign off when finished using a shared computer. The Site may also contain links to other Web Sites. Keep in mind that we do not control, and are not responsible for, the privacy or security practices or the content of these other web sites.

KEEP IN MIND, THAT NO METHOD OF TRANSMISSION OVER THE INTERNET, OR METHOD OF ELECTRONIC STORAGE, IS 100% SECURE. THEREFORE, WHILE WE STRIVE TO USE COMMERCIALLY ACCEPTABLE MEANS TO PROTECT YOUR PERSONAL INFORMATION, WE CANNOT GUARANTEE ITS ABSOLUTE SECURITY.

SURETE ASSUMES NO RESPONSIBILITY OR LIABILITY WITH REGARD TO ANY THEFT, LOSS, ALTERATION OR MISUSE OF PERSONAL OR OTHER INFORMATION WHICH WE LAWFULLY PROVIDE TO THIRD PARTIES, OR WITH REGARD TO THE FAILURE OF ANY THIRD PARTY TO ABIDE BY THIS PRIVACY POLICY OR AGREEMENT BETWEEN THAT THIRD PARTY AND SURETE.

NOTIFICATION OF CHANGES

We may revise and update this Privacy Policy at any time without notice if our practices change, as technology changes, or as we add new services or change existing ones. These privacy practices apply to past, current and potential future subscribers who purchase and use our products and services.