Effective Date May 30, 2025

Last updated May 30, 2025

At SpeedGauge, Inc. (“Company,” “we,” “us,” or “our”), your privacy is important to us. This Privacy
Policy explains how we collect, use, store, share, and protect your personal data when you interact
with our websites, applications, and services (collectively, the “Services”). It also explains your rights
and how to exercise them.

If you do not agree with this policy, please discontinue use of our Services. Continued use of our
Services implies your acceptance.

1. Information We Collect

We collect personal information in the following ways:

a) Information You Provide Directly

  • Name, address, email, and phone number
  • Login credentials (username, password)
  • Company information (e.g., DOT number, VINs, tax ID)
  • Insurance policy and account setup data
  • Communication data (support tickets, emails, feedback)

b) Information from Third Parties

  • TSP (telematics service providers)
  • Business partners (resellers, distributors)
  • Public data sources or government registries (e.g., NAICS)

c) Automatically Collected Data

  • IP address, device ID, browser type
  • Operating system, screen resolution
  • Referring URLs, session duration, and actions taken
  • Cookies and similar tracking data

d) Location Data

  • GPS and network-based geolocation via connected devices
  • Wi-Fi, mobile, and Bluetooth signals
  • Used strictly for service performance (e.g., driver behavior analytics)

2. How We Use Personal Information

We process your information for the following legitimate purposes:

  • Service Delivery
  • Security
  • Communications
  • Marketing
  • Legal Obligations
  • Product Improvement
  • Consent-Based Actions

3. Legal Basis for Processing

Under the GDPR, our processing is based on:

  • Performance of a contract
  • Consent
  • Legal obligation
  • Legitimate interests

4. Sharing and Disclosure

We do not sell personal data. We may share it with:

  • Authorized vendors
  • Affiliates and partners
  • Legal authorities
  • Business transfers

5. Data Transfers

We use Standard Contractual Clauses (SCCs) and other lawful mechanisms to safeguard data
transfers where required under GDPR or other laws.

6. Data Retention

We retain personal data as long as it is necessary. Once retention is no longer necessary, we
securely delete or anonymize the data.

7. Data Security

We use industry-standard technical and organizational safeguards including:

  • Encryption in transit and at rest
  • Role-based access controls
  • Regular vulnerability testing
  • Continuous monitoring

8. Your Rights

Depending on your location, you may have rights to:

  • Access and obtain a copy of your data
  • Correct inaccuracies
  • Request deletion
  • Object to processing
  • Data portability
  • Withdraw consent
  • Lodge a complaint

To exercise these rights, contact us at privacy@speedgauge.net.

9. Children’s Privacy

We do not knowingly collect data from children under 18.

10. Cookies and Tracking

We use cookies and similar technologies for:

  • Authentication
  • Security
  • Analytics
  • Personalization

11. Do-Not-Track (DNT)

We do not currently respond to DNT signals.

12. Data Protection Officer (DPO)

Magaly Masís
Data Protection Officer
Email: magaly.masis@speedgauge.net

13. Subprocessors

A list of authorized subprocessors is maintained and updated at: www.speedgauge.net/subprocessors

14. Changes to This Policy

We may update this policy periodically. We will notify you of material changes and update the “Last
Updated” date.

15. Contact Information

SpeedGauge, Inc.
Attn: Magaly Masís – Data Protection Officer
DPO Email: magaly.masis@speedgauge.net

Mailing Address:

1390 Market Street
Suite 200
San Francisco, CA 94102
United States