LOAD&ROAD Privacy Policy
Overview
Your privacy and trust are important to us. This Privacy Policy explains the types of personal
information and data (hereinafter “personal data”) that we may collect and hold, how that
personal data is used and with whom the personal data is shared. You will find contact
information at the end of this Privacy Policy if you have any queries or concerns.
LOAD&ROAD INC. (hereinafter “LOAD&ROAD”, “we”, “us” or “our”) is the company
responsible for any personal data collected or received by LOAD&ROAD arising from youruse of any LOAD&ROAD products, services, applications and websites made available toyou. LOAD&ROAD is also responsible for ensuring that the handling of personal data
complies with this Privacy Policy.
Our products and services evolve constantly, and we will adjust this Privacy Policy toaccurately describe what personal data we collect, how we use it and with whom we aresharing the personal data, as well as if required to comply with changes in applicable laws. If
we make changes to this policy, we will change the last-updated date (see top) and update
this page. If we make material changes, we will notify you as required by law. Please checkfrom time to time what changes we have made.

1. Personal data that we collect
LOAD&ROAD may collect personal data about you in several different ways. We may collectinformation directly from you, automatically from your device, or from third parties. The
ways in which we collect information are further explained below. Please take care whensubmitting personal data to us.

A. Personal data that you provide us
Whenever you interact with products from us, you may be asked to provide us withpersonal data relating to you. For example:•••

Some of our applications or services may require you to create an account. Whencreating your account(s), we may ask you to provide a range of personal data, suchas your name, date of birth, location, contact details, applicable device ID(s) relating
to the devices you are using to access and receive particular applications andservices, interests and account and your current mobile network operator
When you use our applications and services or other platforms, we may receive
content that you choose to upload, such as product reviews, comments, photos andforum posts, or details of your interests and preferences that you choose to tell us
about when, for example, selecting the services that you wish to receive. Further,use of applications with voice recognition may require us to access certain personal
data on your device and also record your voice
When you specify interests and preferences during setup of products or service fromus

B. Personal data we collect when you use our websites, products, services andapplications
In order to improve and provide a better user experience, some of our websites, internetenabled products and applications and services provide us with personal data about youruse of them, including:
•

•

•

•
•
•
•

•

•

Details of your usage patterns, content that you view and interact with including
personal data on the services and applications you are using on-device topersonalise services to your specific needs
Device information and service, product or server logs which hold technical personal
data about your use of our service, product or websites, such as your IP address,
device ID(s), domain, device and application settings, errors and hardware activity.
We may use your IP address to determine your location/country of origin. Yourdevice ID is also collected when you download a software update
Location information including personal data about where your device is physicallylocated. For example, when you are using a geo-location service or application andyou have given consent to your location being shared
With your explicit consent, personal data related to your physical behavior or health
Voice recognition and utterance data when using a voice command application. Suchdata may be sent to our technology partners
C. Personal data we collect in relation to social networks
If you use any of our social network features, pages or plug-ins, or you use our
products or services that allow interaction with social networks, we may receive
personal data relating to such use. For instance:
If you log in to one of our websites, applications or services using your social
network account, we may receive basic details from your social network profile. The
basic details we receive may depend on your social network account privacy
settings. Typically; however, they might include your social network ID, name, profile
picture, gender and locale. We may also receive additional personal data from yourprofile if you give us permission to access it
If you ‘like’ or similar one of our pages on a social network site, we may receive
personal data about your social network profile, depending on your social network
account privacy settings

For more information and for details about how you can control access to your social
network profile, you should view the privacy policy and other guidance available on yoursocial network’s website.

2. How LOAD&ROAD uses your personal data
LOAD&ROAD uses the personal data you provide or which we collect mainly for these
purposes:

A. Service provisionWe may use data we have collected, including personal data, to:• provide you with a product or service you have requested, including any back-up andrestore service• process your registration with us or create an account• provide you with required notices and software updates which may contain criticalsecurity and functionality patches that make your device more secure and protect
the personal data on the device• send important information (including via text message, push notifications, email)regarding essential software updates, changes to applicable terms and conditions
and/or other communications or notifications as may be required to fulfil our legal
and contractual obligations to provide warranty

B. Product and service development
We work constantly to develop and improve our products and services to better meetcustomer requirements, to ensure quality, and to strengthen network and information
security. We may use personal data to:
•

•
•
•
•

•

create and manage customer database(s) of our users, including basic accountinformation (such as your name, date of birth, address, contact details), applicabledevice ID(s) (relating to the devices you are using to access and receive particularapplications and services), related product or service usage information andcustomer preference information as provided by you from time to time. As part ofour on-going customer relationship management activities, we may consolidate
several databases into one or otherwise link separate databases to more effectively
manage your accounts
improve and enhance existing LOAD&ROAD products, services and applications anddevelop new offerings in general
C. Personalization
We may use personal data to personalize your customer experience. In particular,
we may:show you personalized content, recommendations and advertisements. You may
notice this personalization when you use LOAD&ROAD products and services andwhen you visit our own and third-party websites that show advertisements from us
or our advertising partners. For example, you might see an advertisement for a
product that you have recently viewed on one of our websites. Some of thepersonalization that you see on our websites or in our online advertisements makes
use of cookies set by us or our third-party advertising partners. In other cases, ourapplications and services may have specific settings to control personalized content;
you should consult the applicable terms and conditions of the relevant application orservice for more information
use product reviews, comments or content you have uploaded and made publicly
visible in our websites or services to link to, publish or publicise elsewhere. Eachtime you create or reply to a post or thread on a website forum from us, in addition
to providing this forum service, we may also record the forum name and the timeand date of your post or thread with your account details. We do this to better
understand the ‘typical users’ of our forums.

•

If you want to know more about tracking and cookies and how to opt-out, seesection 7 below for more details.

D. Fraud prevention and investigation
LOAD&ROAD may use personal data to prevent fraud and to investigate violations or ourpolicies. We may use personal data to comply with applicable laws, regulations and court
orders and to comply with valid legal information requests from such bodies. We may use
your personal data to enforce or defend the legal rights of LOAD&ROAD or the terms andconditions of any LAOD&ROAD product or service.

E. Other purposes
We may use your personal data for other purposes:• to link or combine the personal data that we collect from the different sources
outlined above. Personal data may be linked via a unique identifier, such as a cookie
or account number.
• alternatively, we may decide to combine two or more databases into a single
database of customer information. We may link or combine personal data for your
and/or our convenience (for example, to allow you to more easily register for a newservice) and to provide you with better, personalised services and content

3. Sharing your personal data
A. Sharing of personal data by LOAD&ROAD
In general, LOAD&ROAD does not disclose personal data about you to third parties without
your explicit consent. However, there are exceptions:•

Other LOAD&ROAD group companies - We may disclose personal data about you
including basic account information (such as your name, email address, address,
contact details), applicable device ID(s) (relating to the devices you are using toaccess and receive particular applications and services), related product or service
usage information and any customer preference information as provided by you
from time to time) to other LOAD&ROAD group companies where:• you have linked your accounts, as further described in Section 4• we have engaged such other LOAD&ROAD group companies to provide dataprocessing services to us (and these other LOAD&ROAD group companies will
only process your personal data in accordance with our instructions and shallbe subject to appropriate confidentiality and security obligations)• you use your LOAD&ROAD devices and/or applications or services to access,purchase or download content, services, applications or products that are
published, developed, supported or offered by other LOAD&ROAD groupcompanies. They may combine this personal data with other details they holdabout you. Unless they provide you with their own privacy policy, they may
use your personal details for the purposes explained in this Privacy Policy.

•

•

•

Where you have multiple accounts with different LOAD&ROAD groupcompanies, these LOAD&ROAD group companies may also share personal
data with us in accordance with their own privacy policies• LOAD&ROAD transfers a portion or any part of our business to another
LOAD&ROAD group company
Our service providers - We may use other LOAD&ROAD group companies and/or
third-party service providers to provide certain data processing services for us.
Examples of authorized data processors could include data analytics providers who
process personal data on our behalf for the purposes outlined above. For example,
we may use the services of third parties to send update or other important productmessages (by SMS or email) or provide back-up services.
Legal and business purposes - We may use and/or disclose personal data to third
parties:• when we have a good faith belief that sharing the personal data withgovernment bodies and law enforcement agencies is necessary to prevent
fraud, to comply with applicable laws, regulations and court orders and tocomply with valid legal information requests from such bodies• when we are defending or enforcing the legal rights of any LOAD&ROAD
group company or the terms and conditions of any LOAD&ROAD product orservice and sharing the personal data with third parties, including
professional advisors, will be beneficial for our legal position• in connection with a corporate event such as a merger, business acquisition
or insolvency situation, when sharing the personal data with a prospective
third-party purchaser or seller, and its and our professional advisors, isnecessary
Anonymous statistics - We prepare anonymous, aggregate or generic data (including“generic” statistics) for a number of purposes as outlined above. As we consider thatyou cannot reasonably be identified from this information, we may share it with any
third party, such as our business partners or industry bodies.

B. Sharing of personal data provided by you
Some of our applications and services may allow you to upload and share messages, photos,
video and other content and links with others and/or create a publicly accessible profile foryour account. For example:• The communities and forums area (where applicable) of our websites allows you topost comments (with your account name), which are visible to other users of that
service
Other services may allow you to share a link which if clicked on may allow the recipient toaccess your uploaded content.

4. International transfers of your personal data
For the purposes explained in this Privacy Policy, your personal data (including your linked
account details) may be transferred to LOAD&ROAD group companies (including service
providers operating on their behalf) and other third parties in countries which do not havethe same level of data protection laws as those in the country, state or territory where youare located. LOAD&ROAD uses a variety of legal mechanisms to help ensure that your rights
and protections will travel with your data. This is why each of those LOAD&ROAD groupcompanies (and their authorised data processors) will comply with LOAD&ROAD’s internal
policy relating to processing of personal data ensuring adequate level of protection of
personal data.

5. Security of your personal data
While LOAD&ROAD can’t guarantee that unauthorized access will never occur, rest assured
that we take great care in maintaining the security of your personal data to prevent
unauthorized access to it, through the use of appropriate technology and internal
procedures. We take a number of steps to protect your personal data from unauthorizedaccess, use or alteration and unlawful destruction and disclosure.
Does this Privacy Policy extend to third party websites visited when following links on our
website(s)?
Some of our websites may contain links to other third-party websites that are not operated
by LOAD&ROAD, including websites operated by other LOAD&ROAD group companies.
While LOAD&ROAD tries to link only to sites that share LOAD&ROAD’s high standards andrespect for privacy, we are not responsible for the content, security or privacy practices of
those third-party websites. We strongly encourage you to view the privacy and cookie
policies displayed on those third-party websites to find out how your personal data may be
used.

6. Cookies & Tracking
What are cookies and how are they used?
Our websites use industry-wide technologies, such as “cookies”, to collect information
about the use of our websites and email communications. For instance, these technologies
may tell us which visitors clicked on key elements (such as links or graphics) on a website oremail and recognise your browser the next time you visit our websites. Cookies allow us tocustomise your experience to better match your interests and preferences, or to simply
facilitate your signing in to use the services. Most browsers will allow you to erase cookies
from your computer hard drive, block acceptance of cookies or receive a warning before acookie is stored. However, if you block or erase cookies, we may not be able to restore any
preferences or customization settings you have previously specified, and our ability topersonalize your online experience would be limited. Please refer to your browser
instructions to learn more about these functions. Your browser settings may allow you to
automatically transmit a “Do Not Track” signal to websites and online services you visit.
However, how browsers communicate “Do Not Track” signals is not uniform, and there is no
standard application.
Also note that third parties may collect personal data about your online activities over timeand across different websites when you visit our websites or other online websites andservices.

7. Retention of your personal data
We will only retain your personal data for as long as is reasonably necessary for the various
purposes set out in section 2 above or to otherwise comply with any applicable laws andregulations concerning the mandatory retention of certain types of personal data relating toour customers and/or any commercial transactions with them. Should any personal data
held by us no longer be required by us for any of the purposes set out in section 2 above, we
undertake to take reasonable steps to destroy or de-identify any personal data after areasonable period of time has elapsed. If you are concerned that we have not complied withyour legal rights or applicable privacy laws, you may contact your local data protection
authority.

8. CALIFORNIA PRIVACY NOTICEOur Practices Regarding Collection and Use of your CA Personal Information
If you reside in California, we are required to provide additional information to you about
how we collect, use and disclose your information, and you may have additional rights withregard to how we use your information. We have included this California-specificinformation below.

A. CA Personal Information
Consistent with the “Personal data that we collect” section, we may collect the following
categories of information about California residents (“CA Personal Information”) for the
purposes described in the “How LOAD&ROAD uses your personal data” section of thisPrivacy Policy, specifically:• Personal Identifiers: such as name, mailing address, telephone number, email
address and similar identifiers• Other Identifiers: such as Device IDs, IP address, or other unique identifiers;• Commercial Information: such as product or service types or applications purchased
or obtained, or transaction information;• Internet or Other Electronic Network Activity: such as device data and connected
device information, operating system, screen views, traffic to and from applications,other standard connectivity information;• Geolocation Data: such as data about your location, if you use location-based
services;• Other Consumer Characteristics: such as demographics (e.g., gender, age, profession
or job title, etc.), and inferences drawn from collected information

B. Sources of CA Personal Information
Consistent with the “Personal data that we collect” section above, we may collect CA
Personal Information from the following sources:

•

•
•

Directly from you: such as when you voluntarily provide CA Personal Information tous when activating a product or registering an account, or when it is collected
automatically from your LOAD&ROAD product;
Third-Party Business Partners: such as retail stores or mobile network operators;
Third-Party Applications: such as social networks or other blogs or chatrooms.

C. CA Personal Information Sold or Disclosed For Business Purposes••

Sharing your CA Personal Information for Business Purposes: In the preceding twelve
months, we may have shared the following categories of CA Personal Information forbusiness purposes: Personal Identifiers, Other Identifiers, Commercial Information,
Internet or Other Electronic Activity, Geolocation Data and Other Consumer
Characteristics. This information may be shared with LOAD&ROAD group companies,
third party business partners or legal authorities for the purpose of providing
services to you, for product development, monitoring and quality assurance,
managing and delivering communications, for legal compliance or to protect
legitimate interests, in compliance with law.
Sale of CA Personal Information: We do not “sell” (as defined under the California
Consumer Privacy Act) any categories of CA Personal Information.

D. California Consumer Rights
Subject to certain exceptions, as a California resident, you may have the following rights
with respect to your CA Personal Information:•••

Access: Request access to your CA Personal Information that we have collected, usedor disclosed within the preceding 12 months;
Deletion: Request deletion of your CA Personal Information; andCA Personal Information Disclosed for Business Purposes: Request information about
the CA Personal Information we have disclosed for business purposes within thepreceding 12 months.

Please note, if you request deletion of your CA Personal Information, to the extent
permitted by applicable law, we may be required to retain some of your CA Personal
Information, and certain CA Personal Information is strictly necessary in order for us to fulfill
the purposes described in this Privacy Policy. If you wish to exercise a right listed in thissection, you may submit a request here: Data Requests.

E. Exercising Your Rights
If you are a California resident and wish to exercise any of these rights, please: (a) access the
webform applicable to your request as described above, (b) contact us by sending an email
to info@load-raod.com. When submitting your request, you must include your first and last
name, email address, and zip code or mailing address. You may be asked to provide
additional proof of identification so that we can verify your identity and validate therequest. Please note that you are limited by law in the number of requests you may submit
per year.
We will not discriminate against you by offering you different pricing or products, or byproviding you with a different level or quality of products, or in connection with any
promotion or other offering, based solely upon you exercising your rights with respect toyour CA Personal Information.
Authorized Agents: To the extent that you elect to designate an authorized agent to make arequest on your behalf, they must provide appropriate documentation including written
signed permission from you, proof of your identity, and verification of their identity; or avalid, designated power of attorney as required under the California Probate Code. We may
require additional proof of authority or may need to contact you directly to validate therequest.
Additional Notice to California Residents:
If you are a California resident, under the California “Shine the Light” law, you have the rightto receive: a) information identifying any third party company(ies) to which we may havedisclosed, within the past year, personal information pertaining to you and your family forthat company’s direct marketing purposes; and b) a description of the categories of
personal information disclosed. To obtain such information, please email your request to
info@load-road.com, and include your name, email address, and a reference to “Your
California Privacy Rights.” We are not responsible for requests that are not labeled or sent
properly, or do not have complete information.

9. Specific Notices
Other State Rights / Notice to Nevada Residents
If you are a Nevada resident, you have the right to opt-out of the sale of certain personallyidentifiable information we have collected about you to third parties. We do not currently
sell your personally identifiable information as those terms are defined under Nevada law.
However, if you wish to submit a request to opt-out of the sale of such information if wewere to engage in such a sale in the future, you may submit your request in writing to:
info@load-road.com. Your request must reference your Nevada rights and include yourname, mailing address, zip code, and email address. We are not responsible for requests
that do not come through the designated request mechanism or do not contain sufficient
information to allow us to process your request. We will respond to valid requests within 60
days.

10. Contact us
If you have any concerns about our practices regarding your data, please contact us:
Email info@load-road.com