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Thinkware Privacy Policy

Thank you for using our services. When you use our services, you trust us with your information. This Privacy Policy helps you understand what information we collect, why and what we do with it. Please take time to read through it carefully. Here, you will find information on how to manage your information and protect your privacy.

We work hard to protect your private information and improve such protection. Therefore, this Privacy Policy is updated from time to time. Our Apps downloaded from the AppStore usually contain the most recent version of this Privacy Policy. You may read the most recent version of this Privacy Policy at our website: http://member.thinkware.co.kr/Info/AgreementResult?terms_ idx=35. This Privacy Policy is last updated as of November 2, 2017.

1 Privacy Policy

When you choose to use Thinkware Cloud Service, you can easily store your location-related information and share with people you care where you are, and if anything happened to you or your car. In this Privacy Policy, we want to explain clearly how we use the data and how you can protect your privacy. This Privacy Policy explains:

- What information we collect and why, - How we use that information, and - The choices you can make on the provision and retention of that information.

We want to make this Privacy Policy as simple and clear as possible. Your privacy matters to us. Please take time to understand our practices.

2 Information we collect

We collect information to provide people you care about with information on your location, particularly if you have entered a zone you defined and if anything happened to you or your car.

We collect information in the following manner:

2.1 Information you provide: You may need to sign up for a Thinkware Cloud Account. When you do, you’ll provide personal information like your name, email address and/or telephone number.

2.2 Information we get from your device: We collect device-specific information from Thinkware devices (such as the unique device identifiers of the dashcam/blackbox hardware) and from the mobile phone (such as the MAC address, UUID (in case of iOS) or Android Id (in case of Android OS) and/or the telephone number). We may associate such device identifiers, MAC address, UUID or Android Id and/or telephone number with your Thinkware Cloud Account.

We also may collect and process information about your actual location. We may use various technologies to determine the location of the device such as GPS, IP address, W-Fi access points and cell towers.

We may collect the hardware sensor values such as the battery voltage value and the shock value (G-fence shock value) from your dashcam/blackbox device to determine if anything unusual happened to you.

Out of box, our dashcam/blackbox device gathers the location information and hardware sensor values every 2 seconds. The device stores these data for 1 day. If you use Thinkware Cloud Service and enable uploading through your cell phone, those data will be uploaded to our Thinkware Cloud Server. The Cloud Server will preserve the data for 30 days.

You may elect to delete those information we collect. For more information, see Section, Transparency and choice, below.

3 How we use information we collect

We use the information we collect to store them for giving notices, to give notice of what is happening to you or your car to the people you care about (only after such person makes a registration), and to improve our services. We do not use them for any other purpose (such as advertisements) or provide to any other person unless you specifically designate them as recipient of the events or required by law.

The choice of who receives an event notification is completely up to you. Unless required by law or a government agency, we will respect the choices you make on how the information is given to persons other than you.

We will keep a record of your choices and consents, as well as your communication with us to help solve any issues you may have. We may use your email address and/or telephone number to inform you about our services, such as changes or improvements to the services. We may store some additional information such as language preferences and the country in which you drive your car to improve our services.

We will not collect, use or associate an identifier with sensitive information such as information on your race, religion, sexual orientation or health. We will collect only the minimum personal identifier information for our service.

We will ask for your consent before using information for a purpose other than those that are set out in this Privacy Policy.

We may process information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live. Currently, all login-related information is stored and processed in Korea, and all other information (such as location information) is stored and processed in the United States of America.

4 Transparency and choice

Thinkware wishes to be clear about what information we collect and store so that you can make meaningful choices about how such data is used. You can:

- Review and update to who an event notification is sent when an event occurs such as when your car enters a predefined zone, violently stops or accelerates or voltage value of the device fluctuates abruptly, suggesting an important event occurred with your car. - Review and update the device information, email address and/or telephone number linked to your account. - Delete the data stored in our Thinkware Cloud Server.

5 Information you share

We will gather minimum personal identifier information to enable our services, and to prevent divulging your sensitive personal identifier information to an unauthorized person.

6 Accessing and updating your personal information

When you use our services, we will provide you with access to your personal information. If the information is wrong, we will give you ways to update it quickly or delete it, unless we have to keep that information for legitimate business or legal reasons. When you are updating your personal information, we may ask you to verify your identity and the ownership of the product before we can act on your request.

We may reject requests that are unreasonably repetitive, require disproportionate technical effort (such as fundamentally changing an existing practice or developing a new system), risk the privacy of others, or are extremely impractical (such as requesting information on a backup system).

Unless providing information access and control require a disproportionate effort, we will do it for free. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. For this reason, if you delete information from our services, we may not immediately delete copies from our servers and may not remove information from our backup systems.

7 Information we share

We do not share your personal and/or location information with companies, organizations and individuals outside of Thinkware unless:

7.1 According to your request and/or consent: We will share personal information with companies, organizations or individuals outside of Thinkware when you request, or consent to such sharing. We require opt-in consent for the sharing of sensitive personal and location information.

7.2 For external processing: We may provide personal and location information to our affiliates or other trusted businesses or persons to process it for us according to our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. When practical, we may remove from, or unlink the location information from, the sensitive personal information.

7.3 For legal reasons: We will share personal information with companies, organizations and individuals outside of Thinkware if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

- meet any applicable law, regulation, legal process or enforceable governmental request, - enforce applicable terms of service, including investigation of potential violations, - detect, prevent or otherwise address fraud, security or technical issues, or - protect against harm the rights, property or safety of Thinkware, our users or the public as required or permitted by law.

We may share non-personally identifiable information (or after unlinking other data from the personally identifiable information) publicly and with our affiliates, partners or connected sites. For example, we may share information publicly to show trends about the general use of our services.

If Thinkware is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

8 Information security

We promise to work hard to protect Thinkware and our users from unauthorized access to or alternation, disclosure or destruction of information we hold. For that purpose, we may use the following methods:

- Encryption of personally identifiable information using SSL, - Field encryption for transmission of personally identifiable information using AES128 algorithm, - Separation of security server/firewall for access to servers storing personally identifiable information, - Storage of personally identifiable information in a physically separate server, - Additional approval procedure for acess to servers storing personally identifiable information for administrative purposes, - Review of our information collection, storage and processing practices including physical security measures to guard against unauthorized access to systems, and/or - Restriction of access to personal information to Thinkware employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict professional or contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

9 When this Privacy Policy applies

Thinkware Privacy Policy applies when you elect to use our services such as Thinkware Cloud Service, but does not apply when using a service that has separate privacy policies that do not incorporate this Privacy Policy.

Thinkware Privacy Policy does not apply to services offered by other companies or individuals that may include Thinkware services, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who may use our services or incorporate our services in their own services.

10 Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy. When we receive formal complaints, we will contact the person who made the complaint to follow up. We will work with the appropriate regulatory authorities when necessary, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

11 Changes

This Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on our website mentioned above and, if the changes are significant, we will provide a more prominent notice (including email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.