PRIVACY POLICY

OCTO TELEMATICS NORTH AMERICA, LLC PRIVACY POLICY STATEMENT

Octo Telematics North America, LLC its subsidiaries and affiliate companies (collectively “Octo North America”) understand that the protection and use of information provided by you to Octo North America is important to you. Octo North America is committed to maintaining your privacy. This Privacy Policy Statement sets out our information collection, use and dissemination practices for our websites (the “Website”). By visiting any of the Octo North America Websites you are accepting the practices described in this Privacy Statement and hereby grant your consent to collect this information. Please read this Privacy Policy Statement to understand how Octo North America collects, uses and disseminates information through our Website.

What Personal Information About You Does Octo North America Collect?

The information we learn from customers helps us personalize and continually improve your experience with Octo North America. Here are the types of information we gather.

Information You Give Us: We receive and store any information you enter on this Website or give us in any other way. This information includes demographic information and contact information such as names, addresses, phone numbers, fax numbers, vehicle information and email addresses. Additionally, we collect information through our Telematics services regarding general driving habits, global positions and locations.  You can choose not to provide certain information, but then you might not be able to take advantage of many of our features, programs or conduct transactions.

Information Automatically Collected: Octo North America may also automatically collect non-personal information and data through the use of Cookies. Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser to enable our systems to recognize your browser and to enhance your experience using our Website. Through cookies, a website can recognize repeat users, facilitate the user’s access to and use of the Website, and allow a site to track usage behavior. Octo North America does not use cookies to gather personal information about you. Examples of the information we may collect and analyze include the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information such as browser type and version, operating system, and platform; purchase history, which we sometimes aggregate with similar information from other customers.

The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, cookies allow you to take full advantage of some of our Website’s features, and we recommend that you leave them turned on.

How is Collected Information Used?

We use the information collected  to communicate with you, share with your auto insurance company (if applicable), determine driving patterns and risks, determine traffic information and to provide the services described in our various customer programs.

Does Octo North America Share Information?

Yes.    Octo North America shares information collected with your automobile insurance company.  Additionally, Octo North America may share your information with third parties on an anonymous basis.

Affiliated Businesses We Do Not Control: For certain transactions we work closely with our affiliated businesses to package, ship and fulfill your order. We may share customer information related to those transactions with third parties.

Agents:We employ other companies and individuals to perform functions on our behalf. Examples include fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service and support. They have access to personal information needed to perform their functions, but may not use it for other purposes.

Promotional Offers:Sometimes we send offers to selected groups of customers on behalf of other businesses. When we do this, we do not give that business your name and address. If you do not want to receive such offers you can let us know by sending an email to support@octousa.com.

Business Transfers:As we continue to develop our business, we might sell or buy subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy Statement (unless, of course, the customer consents otherwise). Also, in the unlikely event that Octo North America, or substantially all of its assets are acquired, customer information will of course be one of the transferred assets.

Protection of Octo North America and Others:We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Terms of Use and other agreements; or protect the rights, property, or safety of Octo North America, our shareholders, users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. Obviously, however, this does not include selling, renting, sharing, or otherwise disclosing personally identifiable information from customers for commercial purposes in violation of the commitments set forth in this Privacy Notice.

How Do I Grant Consent?

You hereby grant consent for Octo North America to collect the information as set out in this Privacy Policy Statement. Other than as set out above, you will not receive notice when information about you might go to third parties, and you will not have an opportunity to choose not to share the information. You may withdraw or limit you consent by contacting Octo North America at support@octousa.com.

What About Children?

It is Octo North America’s intention that our Website be use only by adults. Octo North America does not sell products or services for purchase by children. If you are under 18, you may use the Website only with the involvement of a parent or guardian. Octo North America does not knowingly send direct mailings to anyone under the age of 16.

What About Other Policies and Revisions?

If you choose to visit our Website, your visit and any dispute over privacy is subject to this Notice and our Terms of Use (located at www.octousa.com) which are incorporated herein by reference, including limitations on damages, arbitration of disputes, and application of the law of the state of California. We encourage you to familiarize yourself with this policy.

Consent and Revisions:

Subject to the above provisions, by using our Website, you consent to the collection and use of information by us. If we decide to change our Website Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we may disclose it.

© 2011 Octo Telematics North America, LLC.  All Rights Reserved.

Last revised Aug 16, 2011