Effective date: January 1st, 2017

This Privacy Notice describes the practices of Innova Electronics Corporation (“Company”, “we”, “us”, or “our”) regarding the collection and use of information through diagnostic devices ("Device") marketed by the Company or from individuals who view the content available at www.innova.rtltelematics.com/account/login or within Company apps or through our Application Programming Interfaces (APIs) (collectively “Site”) or interact with us, through emails or otherwise (“Interactions” or “Interact”). “Service” means Device, Site, and/or Interactions.

1. Consent to Privacy Notice

In this Privacy Notice, we describe the information we collect when an individual (“user” or “you”) purchases our Service, accesses our Site or otherwise Interacts with us. By using or purchasing our Service, accessing or using our Site, or interacting with us, you consent to the information collection, disclosure and use practices described in this Privacy Notice.

By using or purchasing the Service, you allow Company-trained technicians and staff to collect information about you and about your vehicle as described in this Privacy Notice.

If you do not agree with the terms of this Privacy Notice, please refrain from purchasing or using the Service or otherwise Interacting with Company.

2. Changes to our Privacy Notice

We may update this Privacy Notice from time to time. If we make any material changes to the Privacy Notice, we will prominently post the notice of the changes and the updated Privacy Notice on the Site, along with its effective date, and will provide other notifications as required by law.

If you do not agree with the proposed changes to the Privacy Notice, you should discontinue your use of the Service and the Site before the new Privacy Notice takes effect, and contact us as provided in the “Contact Us” section. Your continued use of the Service after we have posted changes to the Privacy Notice will indicate that you agree that your information can be collected and processed in accordance with the updated Privacy Notice.

3. Company Service

The Service is intended to provide consumers with a basic overview of the status of electronic-and emissions-related systems in their vehicle. The Service allows the identification and reporting of certain diagnostic trouble codes (DTCs), and the identification of the probable causes and probable fixes associated with the diagnostics. The identification of “probable cause(s)” and “probable fix(es)” is made through data compiled by ASE Certified Master Technicians and others.

To perform the Service, a technician, store staff member or other individual must first plug a small device into a vehicle's OBD port, typically located beneath the steering column in order to retrieve certain information from the vehicle as described below.

4. Information We Collect

We collect information about any user of the Service, and information from the vehicle that is being serviced. Information collected about the vehicle user is obtained directly from the user.

(i) Information about your Vehicle

We automatically collect information about your vehicle when the Company Device is connected to your vehicle. This includes: vehicle identification number (VIN), current mileage; diagnostic trouble codes (DTCS), freeze frame diagnostic data, and inspection maintenance readiness data.

(ii) Information you provide to us directly

We automatically collect information about the owner or user of the vehicle receiving the Service:

1. Contact Information: Vehicle users who want to have access to a copy via text or email of the report concerning their vehicle must provide their phone number or email address. Otherwise no contact information about the owner or user of a Vehicle will be required or collected.
2. Registration Information: If you select to register with our Service, as part of the registration, we will collect your name, password, zip code) and email address.
3. Electronic Communications: When you interact with us electronically, through the Site or otherwise, for example for support requests, we will collect this information, for example, in order to respond to you.
4. Online Purchases: If you make purchases through the Site, we will collect the information necessary to complete the purchase and ensure the delivery of the items ordered. Please note that we do not have access to, and do not retain any payment card information. Even though the collection form may have a look and feel of the Site pages, this information is directly transmitted to, and processed by, our payment processing service provider. We accept no liability for any error, omission, or negligence of our payment processing service.

(iii) Information automatically collected through your use of the Site:

We automatically collect information from anyone who uses our Site (“Visitor”). This may include:

1. Device Information: We record the visitor’s Ip address, customer ID at the time of the visit to the Site, and information regarding the browser and operating system that is used.
2. Log File Information: We collect information about how the visitor uses the Site, including information on when and how the visitor interacts with the Site, the actions that the visitor takes on the Site, the pages visited, and the links on which the visitor clicks, how long the visitor remains on the Site, which sites were visited before and after the visit to our Site.

5. Methods Used to Collect Information

We use different methods to collect information.

(i) Information Collected Directly:

Some information is collected directly from the vehicle itself by connecting a Company Device to a vehicle.

Some information is collected directly from the owner or user of the vehicle; for example, name and email address.

(ii) Information Collected through Cookies and Similar Technologies

When an individual visits our Site, we collect some information automatically through different technologies:

1. Cookies: We use cookies to identify a returning visitor, identify the pages visited by that visitor, facilitate log-in, as navigation aids, and as session timers. We also use the information collected through cookies in the aggregate, to understand how many users are using our Service and to determine for what purposes they are using the Service.
   It is possible to block certain categories of cookies. Most browsers contain information on how to control or delete cookies. These settings will typically be found in the "options" or "preferences" menu of your browser. Please note that blocking or disabling certain cookies may interfere with certain functionalities of our Site. Further, while disabling a cookie may prevent the future collection of information, it does not prevent the use of the information collected before disabling the cookie. For general information about cookies you can visit http://www.allaboutcookies.org.
2. Web Beacons: Web beacons are small graphics with a unique identifier that are embedded in the webpages that a visitor accesses. They are used to track the visitor’s online activity. We use web beacons to understand visitors’ interest in our Service and to serve advertising based on our perception of the visitor’s interests.
3. Embedded Scripts: We use embedded scripts to collect information about a visitor’s interaction with the Site, such as on which links the visitor clicks. An embedded script is a code that is temporarily downloaded onto a device and is deactivated or deleted when the visitor disconnects from the Site.
4. Third Parties' Use of Cookies and Web Beacon: Our Site includes third party content. These third parties may use their own cookies and other technologies to track the actions of users online over time and across different websites or platforms to deliver targeted electronic advertisements to a user. We do not have access to or control over the privacy practices of these third parties, or the technologies that these third parties may use. We are not responsible for the privacy practices of these third parties.
5. We use Google Analytics. You can prevent the collection and use of data such as cookies and Ip addresses by Google by installing the browser pug in available from https://tools.google/dlpage/gaoptout?hl=en.

6. How We Use Collected Information

In addition to some of the specific uses that we describe in this Privacy Notice, we may use the information that we have collect to:

1. Process the data collected from the vehicle in order to identify the related trouble codes, and identify the probable causes and probable fixes associated with the diagnostic;
2. Derive statistical information used in the Service and other products and services;
3. Facilitate the use of the Service or the Site by an individual;
4. Maintain a record of the Service provided;
5. Send electronic communications about the Service, or respond to inquiries or requests for information;
6. Alert you of new products, services, special offers, and other information related to vehicle repair and maintenance services;
7. Improve, test, and monitor the effectiveness of the Service;
8. Develop Site features that may be of interest to you;
9. Perform data analysis, audit, fraud monitoring and prevention;
10. Conduct other functions as otherwise described at the time when the information is collected;
11. Optimize our marketing and communications efforts, for example to compile statistics regarding the users of the Site, to identify usage trends, and to determine the effectiveness of our promotional campaigns; or
12. Perform any other function that we believe in good faith is necessary to protect the security or proper functioning of the Site.

7. How we Share and Disclose Information

In addition to our use of the information collected for our internal purposes, we share information about users with third parties in the following circumstances:

1. Employees, Third-Party Processors and Third-Party Service Providers: We will share the collected information with our employees, contractors, affiliates, distributors, dealers, vendors, and suppliers ("Service Providers") who provide certain services to us or on our behalf, such as operating and supporting the Service, conducting data analytics, or performing marketing or consulting services. These Service Providers will only have access to the information needed to perform the functions that we have requested them to carry out on our behalf.
2. Business Partners: We may share information with business partners, such as in connection with a joint marketing project. The business partner may use the information in accordance with its own privacy policies over which we have no control.
3. In Connection with Business Transfers or Bankruptcy: We may transfer users' information to a third party in case of the sale, merger, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stocks, corporate restructuring or bankruptcy, and as part of the due diligence process with any potential acquiring entity.
4. Responding to Legal Requests and Preventing Harm: There may be times when we use, share, or disclose information about a user (an) if required to do so by law, or in response to a facially valid search warrant, subpoena, or a court order and we believe that such request complies with applicable law; (b) if we believe that disclosure is reasonably necessary to protect against suspected illegal or fraudulent activity, to protect the safety, property and other rights of our company, our service providers, other users or the public; and/or (c) to enforce our Terms and Conditions, to enforce our End User License Agreement or to defend against legal claims, or to allow us to pursue available remedies or limit the damages that we may sustain.
5. Aggregate and Anonymized Information: We may share information relating to vehicles or the Service with affiliated or unaffiliated third parties on an anonymous, aggregate basis for research, analytical or strategic purpose. This information is not intended to allow the identification of any specific user of the Service.

Except as indicated above, we do not share, disclose, lease or sell any information pertaining to an identifiable individual to any third party.

8. Information Storage and Retention

We will retain information about our users as needed to provide the Service, or as necessary to comply with our legal obligations, resolve disputes and enforce our rights or agreements unless a longer retention period is required or permitted under applicable law.

9. Information Security

We use reasonable technical, organizational and administrative measures to protect the information that we collect and store against unauthorized or unlawful processing and against accidental loss, destruction and/or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody. However, as no method of transmission over the Internet, or method of electronic storage is 100% effective, we cannot guarantee and do no warrant the security of any information we may have collected.

10. Users Located Outside the United States - Consent to Transfer

If you are located outside the United States, please be aware that information that we collect about you will be transferred to the United States or other countries or jurisdictions that do not have the same data protection laws as your jurisdiction. By using our Site or Service you content to the transfer and storage of our personal information to the US or to any other country in which we or our service providers maintain facilities.

11. Links to Other Sites

This Site may contain links to third party websites that we do not own or control. These links are provided for your convenience only and should be used at your discretion. These links do not constitute sponsorship, endorsement, or approval of the content, policies or practices of such third party websites. We are not responsible for the data collection or the privacy practices of these third parties’ websites and our Privacy Notice does not apply to information provided to, or gathered by, the third parties that operate them.

12. California Residents – Your California Privacy Rights

We do not share any personal information about you with outside third-parties for their direct marketing purposes to the extent prohibited by California law, unless you agree otherwise as authorized by your prior written consent. If our practices change, we will implement new procedures as required by applicable law.

13. Minors, Children's Privacy

Our Device, content and Service are not directed towards minors. We do not knowingly collect personal information from children under the age of 13.

If you are a California Resident under the age of 18, and you are a registered user of the Site, you have the right to request that we remove content or information that you posted on the Site or stored on our Service by submitting a request in writing according to Section “How to Contact Us” below clearly identifying the content or information that you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. Please note that there are some exceptions.

14. How to Contact Us

If you have any questions about this Privacy Notice, please contact us at support@innova.com or by mail addressed to Innova Electronics Corporation 17352 Von Karman Ave., Irvine, California 92614, Attention: Legal Department