Smart Start^® Customer Privacy Policy

IMPORTANT NOTE: THIS POLICY APPLIES TO USERS OF OUR SERVICES IN THE UNITED STATES. PLEASE ALSO SEE OUR EU & UK PRIVACY POLICY. YOU MAY NOT USE THESE SERVICES IF YOU ARE YOUNGER THAN 14 YEARS OF AGE.

Last modified: August 18th, 2022

We respect your privacy and are committed to protecting it through our compliance with this privacy policy (the “Policy”).

1A Smart Start, LLC (“Smart Start” or “We” and corresponding pronouns) provide ignition interlock services, location-based monitoring services, and related services (the “Services”). The Services may include equipment we provide to you (the “Equipment”). The Services will require you to provide information to us at one of our local service centers (a “Service Center”), by calling us at our call center (the “Call Center”), or through the web site or mobile application described below. The information we collect from you (described more fully below) will be maintained by us pursuant to this Policy. We may be required by law, regulation, or under the terms of your agreement, to provide your information to a government authority, law enforcement agency, employer, school, or any other person you consent to receive your information (each a “State Authority”).

This Policy DOES NOT apply to information we receive through other referring web sites or sources or which is publicly available. This Policy does not apply to information provided to us by any State Authority. Other websites and apps may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use the App, the Site, or our Services. By using any of our Services or the Site/App, you agree to this Policy. This Policy may change from time to time. Your continued use of the Services or the Services, the Site or the App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information You Provide to Us

When you inquire about, apply for, or use the Services, we may obtain information about you, including:

• Information by which you may be personally identified, such as name, postal address, email address, telephone number, social security number, date of birth, sex, marital status, and other information required for the Services.
• Photographs that are taken as part of the Services.
• Geo-location data that will identify where you (or the Equipment you use as part of the Services) are located.
• Information relating to the State Authority, including criminal history, and the terms of the reporting required by a State Authority.
• User data collected by monitoring equipment (whether the equipment is provided by us or by you) when you use the Services, including alcohol content levels, attempts to disable or bypass the Equipment, reporting, notes and documents you add to the system, and similar data.
• Information about your property, such as the type and model of the device(s) used to access the Services, the make, model and registration of any vehicle monitored by the Services, and the identity of your State Authority.
• Credit card or other financial information required to place an order or pay for the Services.
• Any other information you provide to us in the course of our providing the Services.
  

How We Collect Information:

We may collect, or you may provide (or others may provide on your behalf, such as a parent or other relative), the information listed above when:

• you use Equipment we provide to you;
• you download, install, register with, access, or use any device application provided by us (the “App”);
• you interact with our web site at www.smartstartinc.com or any other web site that we own or partner with (the “Site”);
• you provide information to a Service Center;
• you provide information when interacting with our Call Center (including the recording of calls with you); or
• you email, text, or use other electronic communications to contact us.

Information of Those With You

Certain information collected through the processes listed above may include personal information of other people. For example, a photo taken as part of the monitoring services may include other people in the background, or your geo-location data that is gathered as part of the Services may disclose the location of those traveling with you. YOU AGREE TO NOTIFY THOSE PERSONS WHO ARE WITH YOU THAT SUCH INFORMATION ABOUT THEM MAY BE COLLECTED AND DISCLOSED THROUGH YOUR USE OF THE SERVICES. YOUR CONSENT TO THIS POLICY IS DEEMED TO BE NOTICE TO, AND THE CONSENT OF, SUCH PERSONS.

Automatic Information Collection

Our Equipment, at times, collects information automatically. This collection may include geo-location data.

In addition, when you download, access, or use the Services, the Site, or the App, we may use cookies (a small file placed on your device(s)) or similar technology to automatically collect:

• Usage Details. When you access and use the Site or App, we may automatically collect certain details of your access to and use of the Site/App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Site or App.
• Device Information. We may collect information about your mobile or computer device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Stored Information and Files. The Site or App also may access metadata and other information associated with other files stored on your device.

If you do not want us to collect this information, do not use the Services, and you may delete the App from your device(s) by the method used by your smart phone provider. Note, however, that opting out of the App’s collection of location information will cause its location-based features to be disabled.

You agree to the collection of the information described above.

We may use information that we collect about you or that you provide to us, including any personal information, to:

• Provide you with the Services, the Site, the App, and their contents.
• Fulfill any other purpose for which you provide it.
• Give you notices about your account, including expiration and renewal notices.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Carry out our obligations that are imposed on us by law or regulation.
• Notify you when updates to the Services, the Equipment, the Site, or the App are available, and of changes to any products or services we offer or provide though them.
• Contact others you have referred to us about our Services.
• Refer you to aligned services provided by others (such as auto insurance carriers).

You agree to our use of your Information as described above.

IF YOUR AGREEMENT WITH US INCLUDES MONITORING SERVICES, WE WILL SHARE INFORMATION WITH THE MONITORING AUTHORITY AS REQUIRED BY THE TERMS OF YOUR MONITORING OBLIGATIONS, OR AS REQUIRED BY APPLICABLE LAW, RULE OR REGULATION.

SMART START MAY DISCLOSE YOUR INFORMATION WHEN RESPONDING TO OR COOPERATING WITH REQUESTS FOR INFORMATION REGARDING YOUR USE OF THE SERVICES WHEN MADE BY ANY MONITORING AUTHORITY OR LAW ENFORCEMENT AGENCY, OR AS A RESULT OF A SUBPOENA, COURT ORDER, OR OTHER LEGAL PROCESS.

We may disclose aggregated information about our customers, and information that does not identify any individual, without restriction.

In addition, we may disclose information that we collect, or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Smart Start’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Smart Start is among the assets transferred.
• To fulfill the purpose for which you provide it, including any Services we provide to you.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To other parties with whom we partner that provide services related to our Services.
• To enforce our rights arising from any contracts entered into between you and us, including the Terms and Conditions for the Sale of Services and Use of Equipment as stated in the Terms and Conditions and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Smart Start, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

You agree to the disclosure of your information as described above.

We will use commercially reasonable efforts, consistent with industry standards, to protect your personal information from access by unauthorized persons while such information is in our control. However, no system of safeguarding personal data is perfect, and unauthorized access to personal data can occur. If such an event occurs, we will notify you if required by, and in the manner provided by, our policy and applicable law.

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We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring that you periodically visiting this privacy policy to check for any changes.

To ask questions or comment about this privacy policy and our privacy practices, contact us at Smart Start, Attn: Customer Service Center, 500 E. Dallas Road, Suite 100, Grapevine, Texas 76051, or by calling us at our call center at (800) 880-3394.