1    Soter Driving, Inc. PRIVACY POLICY

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Effective Date: February 13th, 2024
Last Updated: This Privacy Policy was last updated on February 3th, 2024

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1.1    Introduction
1.    Soter Driving, Inc. ( “Company”) is committed to maintaining robust privacy protections for its users.  Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Service.  
2.    For purposes of this Agreement, “App” refers to the Company’s mobile application, Soter Driving. “Service” refers to the Company’s services accessed via the App, in which users can receive audio cues while driving to try to redirect user attention if the app estimates that the user is distracted. Users can also receive comprehensive driving reports based on historical driving data. 
3.    The terms “We,” “Us,” and “Our” refer to the Company. “You” refers to you, as a user of our App or our Service. “Device” refers to the platform used to access and use the App. In most instances, “Device” will refer to Your phone.
4.    By accessing our App or our Service, You accept our Privacy Policy and Terms of Service (found here: [insert link to Terms of Service]), and You consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy.

1.2    Information We Collect
5.    We collect “Non-Personal Information” and “Personal Information.” Non-Personal Information includes information that cannot be used to personally identify You, which includes but is not limited to anonymous usage data and general demographic information We may collect. Personal Information includes but is not limited to email, phone number, first name, last name, which You submit to us through the registration process at the App.
1.2.1    Information collected while registering for an account
6.    To become a subscriber to the Service You will need to create a personal profile. You can create a profile by registering with the Service and entering a first name, last name, email address and phone number, as well as creating a password. By registering, You are authorizing us to collect, store and use the first name, last name, email address, phone number and usage data provided in the registration and in accordance with this Privacy Policy.
1.2.2    Information collected while using the App
7.    In order to provide some of the features contained in the Service, it is sometimes necessary to collect, with permission, Your speed, geographical location, and instances of distractions as determined by the App. To collect this information, it will sometimes be necessary to utilize the front-facing TrueDepth camera on your phone, Your geographical location, and the Device’s internal accelerometer. We use this information to provide features of Our Service. The information may be uploaded to the Company’s servers and/or Third-Party Partners, or it may simply be stored on Your device.
1.2.3    Children’s Privacy
8.    The Site and the Service are not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13, or allow anyone under the age of 13 to sign up for the Service. In the event that we learn that we have gathered personal information from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at info@soterdriving.com. 

1.3    How We Use and Share Information
1.3.1    Personal Information
9.    Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We do share Personal Information with vendors who are performing services for the Company, such as the servers for our email communications who are provided access to user’s email address for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy.
10.    In general, the Personal Information you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.
11.    We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law. 
1.3.2    Non-Personal Information
12.    In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the App. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion. Such third parties will provide the same or equal protection of user data as stated in the app’s privacy policy
13.    In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.
14.    Under certain circumstances, the Company may be required to disclose Your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). 
15.    The company may disclose Your Personal Information in the good faith belief that such action is necessary to:

15.1.    Comply with a legal obligation
15.2.    Protect and defend the rights or property of the Company
15.3.    Prevent or investigate possible wrongdoing in connection with the Service
15.4.    Protect the personal safety of Users of the Service or the public
15.5.    Protect against legal liability

16.    By using our Service, you acknowledge that you understand and agree to these conditions.

1.4    How We Protect Information
17.    We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed. By using our Service, you acknowledge that you understand and agree to assume these risks.

1.5    Your Rights Regarding The Use of Your Personal Information
18.    You have the right at any time to prevent us from contacting you for marketing purposes.  When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. Please note that notwithstanding the promotional preferences you indicate by unsubscribing, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.

1.6    Links to Other Website or Mobile Applications
19.    As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the App and the Service. Therefore, this Privacy Policy does not apply to your use of a third-party website or mobile application accessed by selecting a link on our App or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.

1.7    Changes to Our Privacy Policy
20.    The Company reserves the right to change this policy and our Terms of Service at any time.  We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the App and this privacy page for updates.

1.8    Contact Us
21.    If you have any questions or concerns regarding this Privacy Policy or the practices of this App, please contact us at:

Soter Driving, Inc.
info@soterdriving.com
www.soterdriving.com

By accessing and using the App, you acknowledge that you have read, understood, and agree to be bound by these Terms and any other policies or guidelines posted on the App.