Please read this statement with care prior to using this site. By using this site, you signify your assent to these terms of use. If you at all unhappy or disagree with any of the notices contained, please contact us prior to use for clarification.

GENERAL
This site is owned and operated by Interactive Driving Systems Inc., a New Jersey corporation and Interactive Driving Systems Limited, a United Kingdom limited liability entity and their affiliates (collectively, “IDS”). It is the policy of IDS and its global subsidiaries and affiliates to respect personal data, including sensitive personal data that is collected or maintained by or on behalf of IDS for the benefit of the IDS customers for whom IDS is an authorized service provider. Many IDS affiliates are themselves corporate entities within the EU and subject to the EU data protection directives. Other IDS affiliates are outside the EU but are either part of the US/EU Safe Harbor or enter into individual conformed data transfer agreements in accordance with the EU directives. The Safe Harbor certification assures EU companies and EU regulators that IDS has implemented the necessary measures to secure and protect data IDS receives from the EU or relating to EU residents.

EU DATA PROTECTECTION DIRECTIVE; UNITED STATES / EUROPEAN UNION SAFE HARBOR
In furtherance of its commitment to protect personal data, IDS has certified to the United States/European Union Safe Harbor Agreement (www.export.gov/safeharbor/) regarding personal data collected in the European Economic Area that may be transferred to the United States. IDS privacy policy complies with these privacy principles and where feasible, IDS enters into data transfer agreements and obtains individual consents as to the use of personal data in compliance with such privacy principles. The Safe Harbor certification assures EU companies and EU regulators that IDS has implemented the necessary measures to secure and protect data it received from the EU or relating to EU residents. IDS policies and procedures for handling customer information and personal data have been created with the understanding that Internet technologies are still evolving and that Internet business methods are continuing to evolve to meet the needs and opportunities of the changing technologies. As a result, IDS policies and procedures are subject to change.

NOTICE TO INDIVIDUALS
By means of delivery of a definitive consent and its acceptance by an individual, IDS or the IDS customers notifies the such individual as to the identity of the data controller, the purposes for which IDS collects, processes and maintains the data and any further information as may be required by the circumstances under which the data is being collected including the types of personal data IDS collects, the recipients or categories of recipients of the data, the proposed transfer of such data to third countries, the types of third parties to which IDS may disclose such data and the right of access to the data. Notice to such individual is provided in clear conspicuous language at the time of consenting to participation into the service programs or at the time of collection, or as soon as practicable thereafter and before IDS uses or discloses the information for a purpose other than that for which it was originally collected.

CHOICE OF INDIVIDUALS TO PROVIDE PERSONAL DATA
IDS only uses the personal data of individuals who have provided their consent to collect and use such data either directly to IDS or to their employer which in turn has authorized IDS to collect and use such data. Individuals can opt out of providing such data by not providing their consent. For sensitive information, affirmative or explicit (opt in) choice is given such individuals if the information is to be disclosed to a third party not contemplated in the consent or used for a purpose other than its original purpose that is not otherwise contemplated in the consent or has not been subsequently authorized.

PURPOSES FOR WHICH IDS COLLECTS AND USES PERSONAL DATA
In the course of servicing IDS customers directly and servicing the employees, consultants, agents and representatives, strategic partners and their representative affiliates of such IDS customers indirectly, IDS acquires, collects, maintains, utilizes, discloses and transfers customer and individual communications and information that individuals may regard as private or sensitive. Some of this information - such as the individual’s name and e-mail address - is provided to IDS by its customers in order to establish service. Other information - such as the aggregate results of a customer's 'Risk Assessment' and the “risk assessment” of an individual related to such IDS customer- is created and maintained by IDS in the normal course of providing services and is used for research, statistical archival and other analytical purposes. IDS also uses cookies, which are small pieces of information that a web site can store in a designated file on a user's computer for various reasons. For example, IDS uses cookies on the last page of the assessment to record the individual's assessment results. This information is then forwarded to an IDS database facility which currently is located in the EU but subject to a data transfer agreement may be stored outside of the EU. In addition, IDS may store an individuals' electronic mail and other communications as a necessary incident to the transmission and delivery of those communications.

HOW IS PERSONAL INFORMATION USED?
IDS will only acquire, collect, maintain, utilize, disclose or transfer individual sensitive personal information at the express instruction/permission of the IDS customer to provide fleet management services and driver assessments to such customer and to undertake research and dissemination of driver safety developments and trends. Under no circumstances will any personal information be used by IDS for promotion or marketing to individuals related to such IDS customers.

DATA SECURITY
The principle of security applies to how IDS stores, processes, maintains and protects customer information and information obtained from individuals. IDS will take reasonable and appropriate steps to protect the confidentiality of its customers' information, account information and personal communications to the fullest extent possible and consistent with the law and the legitimate interests of IDS, its partners and its employees. To protect from the loss, misuse, unauthorized access, disclosure, alteration or destruction of information and to seek to ensure the integrity of the data that is collected from customers or obtained from individuals, IDS and its suppliers seek to have in place, maintain and from time to time improve appropriate technological, physical, electronic, and managerial procedures and undertake reasonable precautions as IDS deems appropriate.

DISCLOSURE OF PERSONAL INFORMATION AND COMMUNICATIONS
To the extent IDS wishes to transfer information derived from the EU to a third party that is acting as an agent to IDS, it may do so if it first either ascertains that the third party subscribes to the EU privacy principles or is subject to EU directives or another adequacy finding or enters into a written agreement with such third party requiring that the third party provide at least the same level of privacy protection as is required by the relevant privacy principles. IDS will not otherwise disclose its customers' information and information obtained from individuals unless IDS has reason to believe that disclosing such information is necessary to identify, make contact with, or bring legal action against someone who may be causing harm or interfering with the rights or property of IDS, IDS customers, or others, or where IDS has a good faith belief that the law requires such disclosure.

If you have a user name and password for any of the features on the IDS Web sites, you have the responsibility of keeping your password secret. You should not reveal your password to anyone. IDS will not ask you in an unsolicited telephone call or e-mail for your password. In addition, you should take reasonable precautions when using a computer that is not your own or in a public setting.

Data collected online may also be combined or merged with information you provide to IDS by means other than through this site as part of IDS’s standard business operations.

IDS or its Affiliates may sell or buy other businesses or entities. In such transactions, personal information may be one of the transferred business assets. Also, in the event that IDS or substantially all of its assets are acquired, personal information may be one of the transferred assets. IDS may also transfer such information to its affiliates directly involved in the operation of the web site or any application.

IDS also will not, except for reasons stated below, otherwise disclose to third parties personal information or the contents of any electronic mail or other electronic communications that IDS stores or transmits for its customers. The other circumstances under which IDS will disclose such personal information or electronic customer communications are when:

• It is necessary in order to provide service to the customer;

• It is necessary to protect the legitimate interests of IDS and its customers;

• It is required to cooperate with interception orders, warrants, or other legal process that IDS determines in its sole discretion to be valid and enforceable;

• It is necessary to provide to a law enforcement agency when the contents are inadvertently obtained by IDS and appear to pertain to the commission of a crime;

• For certain research purposes to seek to improve driver safety; and

• When necessary to avert a serious threat to your health; or safety or to the health and safety of another individual or the public.

IDS will report to its direct customers any use or disclosure of the individual sensitive personal information (“ISPI”) not provided for under these policies of which it becomes aware in accordance with applicable national, federal, state and local law. IDS will destroy, or arrange for the destruction of records within its custody or control containing ISPI which is no longer to be retained by IDS or the IDS customer to make such ISPI unreadable, undecipherable or non-reconstructable through generally available means.

DATA INTEGRITY
Consistent with these privacy principles, personal information must be relevant for the purposes for which it is to be used. IDS seeks not to process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual. To the extent necessary for those purposes, IDS takes reasonable steps to ensure that data is reliable for its intended use, accurate, complete, and current and that that decisions will not be based upon erroneously or inappropriate information. The data integrity principle minimizes the risk that personal information would be misused or abused because as IDS is collecting only relevant information, there is less opportunity to misuse and abuse personal information.

ACCESS
IDS customers and their individual employees or drivers are not only concerned about what data is being collected by IDS, they are also concerned that this information is correct and timely. Providing access to the data that IDS has been provided or collected about an individual allows that person to check the stored information and ensure that it is up-to-date and correct, and that IDS and the IDS customer is doing what it says it is doing about collecting and retaining data. Accordingly, IDS seeks to require that the IDS customers provide to the individuals whose personal information has been provided to IDS with access to such personal information so as to be able to correct, amend, or delete that information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question, or where the rights of persons other than the individual would be violated or the integrity of IDS research efforts would be jeopardized. Expense and burden are important factors and shall be taken into account but they are not controlling in determining whether providing access is reasonable. The sensitivity of the data is also important in considering whether access should be provided.

ENFORCEMENT
Effective privacy protection must include verification mechanisms for assuring compliance with these privacy principles, recourse to dispute resolution procedures for individuals to whom the data relate when they are materially affected by non-compliance with these privacy principles, and consequences for IDS, the IDS customer and the individual when these privacy principles are not followed. IDS has implemented self assessment procedures for verifying that the attestations and assertions IDS has made about its privacy practices are true and that privacy practices have been implemented as presented with appropriate follow up procedures. IDS has put in place a readily available and affordable independent dispute resolution system that will investigate and resolve individual complaints and disputes and damages awarded where the applicable law or private sector initiatives so provide. This dispute resolution system is also designed to remedy problems arising out of a failure by IDS, the IDS customer or a disputing individual to comply with these privacy principles that is sufficiently rigorous to ensure compliance. IDS agree to cooperate with the EU data protection authorities regarding any dispute concerning human resources data.

VERIFICATION
Under the self-assessment approach to verification, IDS periodically assesses whether its published privacy policy is accurate, comprehensive, prominently displayed, completely implemented, accessible and conforms to the EU and other applicable privacy principles. IDS‘s self assessments also are designed to indicate that appropriate employee training is in place and that internal procedures for periodically conducting objective reviews of compliance are in place. A statement verifying the self- assessment prepared and executed by an IDS corporate officer or other authorized representative at least once a year. In addition, from time to time, IDS at its sole discretion permits a third party to conduct an independent audit of IDS’s privacy policies.

INDEPENDENT DISPUTE RESOLUTION SYSTEM; REMEDIES:
IDS customers and their related individuals are encouraged to raise any concerns they may have with IDS before proceeding to independent recourse mechanisms. IDS provides for any controversy or claim arising out of or relating to its privacy policy to be resolved by arbitration in the City of Newark, New Jersey before and in accordance with the Commercial Arbitration Rules of the American Arbitration Association. The procedures provide for standard complaint forms to facilitate the complaint resolution process and that the arbitrators are directed in the formulation of any remedy to recommend to IDS as to means and mechanisms by which the effects of noncompliance with its privacy policies are reversed or corrected, in so far as feasible, and that future processing by IDS will be in conformity with its privacy policies and the EU privacy principles and, where appropriate, that processing of the personal data of the individual who has brought the complaint will be in compliance with such policies and principles.

HOW DOES IDS PROTECT THE PRIVACY OF CHILDREN?
IDS does not knowingly collect or use any personal information from children (IDS defines “children” as minors younger than 13) on IDS web sites. IDS does not knowingly allow children to order our products, communicate with us, or use any of our online services. If you are a parent and become aware that your child has provided IDS with information, please contact IDS using any of the methods specified below, and IDS will work with you to address this issue.

YOUR STATE PRIVACY RIGHTS
Applicable state or local law may provide additional privacy rights.

CHANGES TO THIS PRIVACY STATEMENT
This privacy statement may be amended from time to time consistent with the requirements of the Safe Harbor and otherwise to reflect technological advancements, legal and regulatory changes and good business practices. When IDS does update the privacy statement, IDS will also revise the effective date paragraph to provide a “last updated” date.

COMMENTS
IDS welcomes your comments regarding this privacy statement. If you believe IDS has not adhered to this statement, please contact us at the addresses below. IDS will use commercially reasonable efforts to promptly determine and remedy the problem. You can find out more information about the U.S. Department of Commerce Safe Harbor Program at www.export.gov/safeharbor/.

UK, EUROPE, AFRICA AND THE MIDDLE EAST
Interactive Driving Systems Ltd.
Pennine Business Park, 9 Longbow Close, Huddersfield, HD2 1GQ

ASIA PACIFIC, NORTH & SOUTH AMERICA, CANADA AND THE CARIBBEAN
Interactive Driving Systems Inc.
PO Box 396, Cape May Court House, New Jersey, 08210, USA

EFFECTIVE DATE
This statement is effective as of March 31, 2008.