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Drivetrain Privacy Notice
This privacy statement is intended to transparently document the practices of Drivetrain AI, Inc. and its subsidiaries (collectively “Company”, “we”, “our”, “us”) regarding information that we collect, use, share and secure from:

(i) visitors to https://www.drivetrain.ai (the “Site”);
(ii) users who register to use our online, web-based platform for analytics services (the “Services” and such users, the “Customers”).

If you are a Customer, this statement also describes your choices regarding the use, access, and correction of your information.
The use of information collected through our analytics platform is governed by our Terms of Use and shall be limited to the purpose of providing the service for which the Customer has engaged the Company. This privacy statement is not intended to discuss the collection or use of personal information by a Customer’s use of the Services since a Customer’s collection or use of personal information is specific to their use and implementation of the Services - therefore we urge you to read and go through the Customer’s privacy statement or the written contract between a Customer and Company for the Services for more information. For additional detail, please see the Analytics Product section below. If you have questions or complaints regarding this privacy statement or our privacy practices, please contact us at compliance@drivetrain.ai
Effective Date: April 1, 2023
Last Updated on: February 8, 2023

This privacy notice (“Notice”) explains how Drivetrain AI, Inc. or any of its affiliates or subsidiaries.
(“We”, “Us”, “Our”, “Drivetrain”) processes Personal Data collected from natural persons as
specified in the section “How We Collect, Use and Share Your Personal Data” below, as a Controller
(“You”).

1. DEFINITIONS

Terms not specifically defined herein shall have the meaning ascribed thereto in the Terms.

1.1. “Controller” means the natural or legal person, public authority, agency, or other body
which alone or jointly with others, determines the purposes and means of the processing of Personal
Data.

1.2. “End-User” means any person or entity with whom the User interacts using the Service(s).

1.3. “Personal Data” means any information relating to an identified or identifiable natural
person; an identifiable natural person is one who can be identified, directly or indirectly, in particular
by reference to an identifier such as a name, an identification number, location data, an online
identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person.

1.4. “Processor” means a natural or legal person, public authority, agency, or other body which
processes Personal Data on behalf of the Controller.

1.5. “Service(s)” shall have the meaning ascribed to it in the Terms.

1.6. “Subscriber” means the natural or legal person that has subscribed to the Service(s) by
agreeing to the Terms or signing any other agreement for the subscription and use of the Service(s).

1.7. “Terms” means the Terms of Service at https://www.drivetrain.ai/terms.

1.8. “Website(s)” means the websites owned and operated by Us including https://www.drivetrain.ai/

2. HOW WE COLLECT, USE AND SHARE YOUR PERSONAL DATA

2.1. PERSONAL DATA THAT YOU PROVIDE US
When You are a(n)
What Personal Data We Collect
How We use Your Personal Data
Whom We share Your Personal Data with
Individual who is a Subscriber
Billing information, Name, Address, e-mail id
To enable Your subscription and collect the fees.
Third party payment processors who process payment information for Us but who are otherwise not permitted to store, retain or use such information;
User who is onboarded to use the Services on behalf of the Subscriber
Your contact information, such as Your full name, email address, unique identifiers such as username, account number or password.
● Creation of a User account, verification of a User’s identity and help a User log into Our Services.
● To communicate with a User regarding existing products and Services availed by Subscriber including notifications of any alerts or updates.
● To send the User information about Our other products or services, events, webinars or programs which may be of
interest to such User.
Third party partners who
assist Us in onboarding
You and providing Our
Services to You.
User who requests
customer support
Your name, usage
information or any other
Personal Data You may provide Us in the course
of such interaction.
To provide support in relation to Your use of Our Services
Third parties who assist Us in providing these support services.
User who submits certain information to Our Services, such as filling out a survey about their user experience or feedback.
Information You have provided as part of it.
To improve Our Services
Third parties who assist Us in providing these services.
Website users who enter
information in the landing pages used by marketing teams
Your contact information, such as Your full name, email, phone, location, country, business name and shipping address.
To inform, promote and sell Our Services to You.
Third parties who assist Us in providing these services.
Individual who registers for an event, webinar or contest;
Your contact information, such as Your full name, email, phone, location, and business name.

When You register through a registration form on Our Website, We may collect information such as company Website URL, IP address and location.
● To ensure that the event is conducted in a secure and effective manner.
● To inform, promote and sell Our Services to You.
● Sponsors of such
contests
● Third party organisers that assist Us with the
organisation of such
events, webinars,
contests.
Any individual who communicates with Us
● Your name or any other Personal Data You may provide Us in the course of such interaction.
● Unless prohibited by
law, We may record any
telephonic conversation
We have with You.
● To respond to Your queries or requests.
● To inform, promote and market Our Services to You.
Third parties who assist Us in providing these services.
Individual who requests a demo
Your contact information, such as Your full name, email, phone, business
name and shipping address.
● To give You the demo and
● To inform, promote and market Our Services to You.
Third parties who assist Us in providing these services.
Individual who applies for an employment opportunity with Us through Our online recruitment systems.
Your contact information, such as name, email address, mailing address, phone number; any other information You volunteer, including during any interview or Your interactions with Us and contained in the resume that You submit to Us.
To evaluate You for any
position that You have applied for or that We may consider You at the time that You submitted Your resume or on a later date.
● With external recruiters and organizations like those that do employee background checks on Our behalf and on behalf of Our group entities.
● Third parties whose products We use in maintaining a record of and evaluating You for the position applied
2.2. PERSONAL DATA THAT WE COLLECT NOT PROVIDED DIRECTLY BY YOU
When You are a(n)
What Personal Data We Collect
How We use Your Personal Data
Whom We share Your Personal Data with
Website visitor
● Your device and Your usage of Our Websites or emails (such as Internet Protocol (IP) addresses or other identifiers
● As described in the section “Cookie Policy”
● For market analysis, and market research
● To protect Our data from threats, violations, and breaches if any.
● To inform, promote and sell Our Services to You.
Third party partners who provide Us with services in connection with such processing
User who uses and interacts with Our Services
Your device type, and the operating system version and Your usage of Our services through log files and other technologies, some of which may qualify as Personal Data.
● To evaluate, develop and improve Our
products and Services.
● For market analysis, product analysis and
market research.
● To provide support in
connection with Your queries
Third party partners who assist Us in such processing.
Individual whose information (a) third party sources share with Us without breach of any
confidentiality clause;
or (b) is available on
public platforms.
Your contact information, such as Your full name, email address, phone number, designation and business name. We may combine this information with any Personal Data provided by You.
● To update, expand, and analyze our records and create more tailored
advertising to provide services that may be of
interest to You
Third party partners who assist Us in such processing.
2.3. If You provide Us with any Personal Data relating to other individuals, You represent that You
have the authority to do so, and where required, have obtained the necessary consent, and
acknowledge that it may be used in accordance with this Privacy Notice.

2.4. In addition to the details provided in the table above, We may also share Your Personal Data with

  a. Our group entities and the companies that We will acquire in the future when they are
made a part of Our group entities to provide and improve Our Services

  b. Third Parties involved in a Corporate Transaction: If We become involved in a merger,
acquisition, or any form of sale of some or all its assets, then, in accordance with
applicable laws, We will use reasonable efforts to notify You of any transfer of Personal
Data to an unaffiliated third party.

  c. Law enforcement authorities, government authorities, courts, dispute resolution bodies,
regulators, auditors, and any party appointed or requested by applicable regulators to
carry out investigations or audits of Our activities.

  d. Professional advisors who advise and assist Us in enforcing Our contracts and policies,
handling Our claims, effective management of Our company and in relation to any
disputes We may become involved in.

3. LEGAL BASIS FOR PROCESSING

3.1. If You are a data subject from the European Economic Area, Our legal basis for collecting and
using the Personal Data described above will depend on the Personal Data concerned and the
specific context in which We collect it. We will normally collect Personal Data from You only
where it needs it to perform a contract with You, where the processing is in Our legitimate
interests and not overridden by Your data protection interests or fundamental rights and freedoms,
or where We have Your consent. In some cases, We may also have a legal obligation to collect
Personal Data from You. If We process Personal Data with reliance on Your consent, You may
withdraw Your consent at any time.

3.2. If You have questions or need further information concerning the legal basis on which We collect
and use Your Personal Data, please contact Us using the contact details provided under clause 11.

4. INTERNATIONAL TRANSFER

4.1. We mainly process Personal Data in the United States. However, We may transfer Personal
Data outside the United States for the purposes referred to in Section 4. We will ensure that the
recipient of Your Personal Data offers an adequate level of protection that is at least comparable to
that which is provided under applicable data protection laws.

4.2. If You are a resident of the European Economic Area and when Your Personal Data is
processed outside EEA, We will ensure that the recipient of Your Personal Data offers an adequate
level of protection, for instance by entering into standard contractual clauses for the transfer of
Personal Data as approved by the European Commission (Article 46 General Data Privacy
Regulation, 2016), or We will ask You for Your prior consent to such international data transfers.

5. RETENTION OF PERSONAL DATA

5.1. We retain the Personal Data collected where an ongoing legitimate business requires retention
of such Personal Data.

5.2. In the absence of a need to retain Personal Data under Section 5.1. above, We will either
delete it or aggregate it, or, if this is not possible then We will securely store Your Personal Data and
isolate it from any further processing until deletion is possible.

6. SECURITY OF PERSONAL DATA

We use appropriate technical and organizational measures to protect the Personal Data that We collect
and process. The measures We use are designed to provide a level of security appropriate to the risk
of processing Your Personal Data. If You have questions about the security of Your Personal Data,
please contact Us immediately as described in this Notice.

7. YOUR RIGHTS

You are entitled to the following rights:

  7.1. You can request Us for access and correction of Your Personal Data.

  7.2. If We have collected and processed Your Personal Data with Your consent, then You can
withdraw your consent at any time. Withdrawing Your consent will not affect the lawfulness of
any processing We have conducted prior to Your withdrawal, nor will it affect processing of Your
Personal Data conducted in reliance on lawful processing grounds other than consent.

  7.3. You have the right to complain to a data protection authority about Our collection and use of
Your Personal Data. For more information, please contact Your local data protection authority.

   7.4. You have the right to opt-out of marketing communications We send You at any time. You can
exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails We
send You. To opt-out of other forms of marketing (such as postal marketing or telemarketing),
please Contact Us.

  7.5. If You are a resident of the EEA, UK, or Switzerland, You are also entitled to the following
rights:
    a. You can request Us for deletion and erasure of Your Personal Data.

    b. You can object to the processing of Your Personal Data, ask Us to restrict processing of
Your Personal Data or request portability of Your Personal Data.

  7.6. If You seek to exercise Your rights under this clause, please contact Us at the details provided in
clause 11. We will verify any requests before acting on the request and respond to all requests We
receive from individuals wishing to exercise their data protection rights within a reasonable
timeframe in accordance with applicable data protection laws

8. COOKIE POLICY

  8.1. Cookies are text files that are placed on Your computer to collect standard internet log
information and visitor behaviour information by Us. When You visit the Website(s), We may collect
Personal Data automatically from You through cookies or similar technology. We also set cookies to
collect information that is used either in aggregate form to help Us understand how Our Website(s) is
being used or how effective Our marketing campaigns are, to help customise the Website(s) for You
or to make advertising messages more relevant to You.

  8.2. Essential Cookies: We set essential cookies that enable core functionality such as security,
network management, and accessibility. You may not opt-out of these cookies. However, You may
disable these by changing Your browser settings, but this may affect how the Website(s) functions.

  8.3. Analytics, Customisation and Advertising Cookies: We set these cookies to help Us improve
Our Website(s) by collecting and reporting information on how You use it. The cookies collect
information in a way that does not directly identify anyone.

  8.4. When You visit the Website(s), a cookie banner will be displayed providing additional
information about cookies and options to opt out of non-essential cookies as required by applicable
laws.

9. PRIVACY OF CHILDREN

  9.1. We recognize the importance of children's safety and privacy. We do not request, or
knowingly collect, any Personal Data from children under the age of 18. If a parent or guardian
becomes aware that his or her child has provided Us with Personal Data, they should write to us at the
email address provided in clause 11.

10. NOTICE TO CUSTOMER AND OTHER EXCLUSIONS

 10.1. Other than the Personal Data collected for the purposes set forth in clause 2 for which We
shall act as the Controller, for any other processing of Personal Data collected from or transmitted by
a Subscriber, We will only act as a Processor of Personal Data and such processing will be governed
by the terms and conditions of the agreement with the Subscriber. Where the Services are made
available to an End-User through a Subscriber, that enterprise is the Controller of the End-User’s
Personal Data. In such a case, the End-User’s data privacy questions and requests should be submitted
to the Subscriber in its capacity as the End-User’s Controller. If the End-User is an individual who
interacts with a Subscriber using Our Services, the End-User will be directed to contact Our
Subscriber for assistance with any requests or questions relating to their Personal Data. We are not
responsible for Subscribers’ privacy or security practices which may be different from this notice.
Subscribers to Our Services are solely responsible for establishing policies for and ensuring
compliance with all applicable laws and regulations, as well as any and all privacy policies,
agreements, or other obligations, relating to the collection of Personal Data in connection with the use
of Our Services by End-Users.

  10.2. Our Website(s) contain links to other websites. Our Notice applies only to our Website(s), so
if You click on a link to another website, You should read their privacy notice. We encourage You to
review the privacy statements of any such other websites to understand their Personal Data practices.

11. CONTACT INFORMATION

You may contact Our privacy officer if You have any enquiries or feedback on Our personal data
protection policies and procedures, or if You wish to make any request, in the following manner:

Kind Attention: Chief Information Security Officer

Email Address: privacy@drivetrain.ai

Address: 919 North Market Street, Suite 950, City of Wilmington, County of New Castle, Delaware
19801, United States

12. CHANGES TO THE NOTICE

We keep this Notice under regular review and may update this webpage at any time. This Notice may
be amended at any time and You shall be notified only if there are material changes to this Notice.
Information we collect
We collect information, including personal information, in various ways when you use our Site, Applications, and Services. As used in this statement, “personal information” means any information which, either alone or in combination with other information, identifies you as an individual, such as your name, mailing address, and email address.

Information you provide us: We collect information, including personal information, you provide us voluntarily. For example:
  • Information you enter to create an account to access the Services (“Account”) such as your first and last name, email address, and password or otherwise similar information which you may enter into forms or surveys on our Site.
  • Information you enter while using your Account, including postal address, phone number, fax number, company name and credit card payment information.
Information collected: We may collect the following information (but not limited to)
  • Site behavioural Information
  • Operating system (“OS”) running on your device
  • Internet protocol address (“IP Address”) (we may use this to obtain your geolocation, domain name or carrier network)
  • Access times
  • Browser type
  • Website you visited before our site and page load times
  • We also collect information about how you use our Site,Applications and Services, including the elements you have interacted with, meta data and other details about these elements, clicks, change states and other user actions.
  • Browser Local Storage: We also store data locally on your device to enhance the user experience on our Site. The Company uses cookies and similar technologies for several purposes, including Sign-In and Authentication. At the time of sign in to the Site using your username and password, we store an encrypted cookie on your device. This cookie allows you to move from page to page within the Site without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the site.
Access and control of the information we collect: We use the information we collect primarily to provide, maintain, protect, and improve our current products and to develop new ones.
• Facilitate the creation of and securing of your Account on our network
• Improve our Services, Applications, Site and how we operate our business
• Understand and enhance your experience using our Site, products and Services
• Provide and deliver products and services you request
• Respond to your comments or questions
• Send you related information, including timely notifications and alerts such as invoices and support related messages
• Protect, investigate and deter against fraudulent, unauthorised or illegal activity
• Link or combine it with other information we get from third parties, to help understand your needs and provide you with better service, as described under Profiling below
De-identified data: We may create de-identified data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We use this de-identified data for analytical purposes and to improve our Services. We may use de-identified data for any purpose and disclose de-identified data to third parties for analytical and business purposes.
Profiling: When you interact with our Site by completing a form (such as a request for us to contact you, request for information on pricing, or downloading content) we will collect your personal information and analyse your information to build individual profiles. We use third-party tools to help us build the profile by providing firmographics: company size and industry for example. These profiles will be used to help us predict future interest in our Services.
Sharing of information: We do not share your personal information with third parties without your consent other than
  • To provide products or services you've requested, with your permission. List of third-party services we use include,
    Google Cloud Platform - Cloud Services Provider
    Amazon Web Services - Cloud Services Provider
    GSuite - Productivity and Collaboration
  • To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law.
  • If Company is acquired. Analytics Product With respect to our Services, Company collects information under the direction of its Customers (the data controller) and has no direct relationship with the individuals whose personal information it processes. The processing of data sent from our Customers is governed by our Terms of Use, Data Processing Addendum, or any other agreement agreed to and signed by the Company with our Customers. If you are an end-user or customer to one of our Customers, we urge you to contact the Customer that you interact with directly for any information that you seek about your data or usage of your information by the Customer. Company acknowledges that you have the right to access your personal information. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to our Customer who will then provide instructions to the Company, if necessary. If requested to remove data, we will honour the request accordingly within a reasonable timeframe. We will retain personal information of any user, if any, pursuant to our retention policy and will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our Privacy Policy agreements.
Personal Information Security: Company maintains commercially reasonable administrative, technical, and physical safeguards to help protect your personal information in an effort to prevent loss, misuse, and unauthorised access, disclosure, alteration and destruction. We encourage you to protect your usernames and passwords to help prevent anyone from accessing or abusing your accounts and services, including not using the same passwords for the Services that you use with other accounts. If you have any questions about the security of your personal information, you can contact us at security@drivetrain.ai
Children: We do not intentionally gather personal information from visitors who are under the age of 16 in the US. If we learn that a child under 16 in the US submits personal information to the Company, we will delete the information as soon as possible. If you believe that we might have any personal information from a child under 16, please contact us at: compliance@drivetrain.ai
Your Rights with Respect to Your Information: You may have heard about the General Data Protection Regulation (“GDPR”) in Europe. GDPR gives people under its protection certain rights with respect to their personal information collected by us on the Site. Accordingly, Company recognises and will comply with GDPR and those rights, except as limited by applicable law. The rights under GDPR include:
  • Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
  • Right to Correction. This is your right to request correction of your personal information.
  • Right to Erasure. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession (also known as the “Right to be forgotten”). However, if applicable law requires us to comply with your request to delete your information, fulfilment of your request may prevent you from using Company services and may result in closing your account.
  • Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
  • Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed
  • Right to Object. This is your right, in certain situations, to object to how or why your personal information is processed.
  • Right to Portability. This is your right to receive the personal information we have about you and the right to transmit it to another party.
  • Right to not be subject to Automated Decision-Making. This is your right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for the performance of any contract between you and us, is allowed by applicable European law, or is based on your explicit consent. Many of these rights can be exercised by signing in and directly updating your account information. If you have questions about exercising these rights or need assistance, please contact us at privacy@drivetrain.ai
Deleted Data when you cancel your account: We'll attempt to delete all data and that nothing is stored on our servers past 30 days. Anything you delete on your account while it's active will also be purged within 30 days.
Location of Site and Data: This Site is currently operated in the United States. If you are located in the European Union or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using our Site, participating in any of our services and/or providing us with your information, you consent to this transfer.
Changes & Questions
Company may update this policy periodically and we’ll undertake reasonable efforts to notify you about significant changes by emailing the account owner or by placing a prominent notice on our site. Please get in touch at privacy@drivetrain.ai for any further information