Effective date: 5/5/2025

1. Introduction

Welcome to Stealth Smart Technologies.

When you are using Stealth Smart Technologies’ Stealth Tracer, we want you to understand what personal data we collect from you and how we are using it. This policy explains how we collect, safeguard and disclose information that results from your use of our Service.

We use your  asset location data to provide and improve our Service. By using our Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).

2. Definitions

PERSONAL DATA means data about a living individual who can be identified from that data (or from those and other information either in our possession or likely to come into our possession).

ASSET DATA means the is data collected from the telematic device that provides us the location data of the asset that will allows us to perform our Service.

USAGE DATA is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we, Trak Global Stealth Tracer Limited, are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you (“Contract”): Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

4. Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

1.        Name

2.        Address

3.        Telephone Number

4.        Email address

5.        Vehicle Licence Number

We use this data to provide features of our Service, to improve and customize our Service.

 

 

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through any device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data. . We use this data to provide features of our Service, to improve and customize our Service.

Images & Files

We may use the user's camera / gallery to access images / files / documents if you give us permission to do so . We use this data to provide features of our Service, to improve and customize our Service.

Location Data

We may use and store information about the location  of your asset ( “Asset Data’). We use this data to provide features of our Service, to improve and customize our Service.

We do not collect, track or use any indivudal location data that from the mobile device used to access the Service.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

0.1. Session Cookies: We use Session Cookies to operate our Service.

0.2. Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

0.3. Security Cookies: We use Security Cookies for security purposes.

0.4. Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

5. Use of Data

We use the collected data for various purposes, the legal basis for each activity is stated in brackets:

0.1. to provide and maintain our Service (Contract/Legitimate Interests);

0.2. identify you as a user in our system (Contract/Legitimate Interests);

0.3. to notify you about changes to our Service (Contract/Legitimate Interests);

0.4. to allow you to participate in interactive features of our Service when you choose to do so (Contract/Legitimate Interests);

0.5. to provide customer support (Contract/Legitimate Interests);

0.6. to gather analysis or valuable information so that we can improve our Service (Legitimate Interests);

0.7. to monitor the usage of our Service (Legitimate Interests);

0.8. to detect, prevent and address technical issues (Contract/Legitimate Interests);

0.9. to fulfil any other purpose for which you provide it (Contract/Legitimate Interests);

0.10. to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection (Contract/Legitimate Interests);

0.11. to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc. (Contract/Legitimate Interests);

0.12. to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information (Contract/Legitimate Interests/Consent);

0.13. in any other way we may describe when you provide the information (Contract/Legitimate Interests/Consent);

0.14 to carry out vehicle identification checks (Contract/Legitimate Interests/Consent/ Legal Obligation);

0.15. for any other purpose with your consent (Consent).

6. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

7. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Stealth Smart Technologies will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place. We will only transfer your personal data to:

·      countries that have been deemed by the UK to provide an adequate level of protection for personal data; or

·      third parties that agree to specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK.

8. Disclosure of Data

We may disclose personal information that we collect, or you provide as follows:

0.1. Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

0.2. Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

0.3. Other cases. We may disclose your information also:

0.3.1. to our subsidiaries and affiliates;

0.3.2. to contractors, service providers, and other third parties we use to support our business;

0.3.3. to fulfill the purpose for which you provide it;

0.3.4. for the purpose of including your company’s logo on our website;

0.3.5. for any other purpose disclosed by us when you provide the information;

0.3.6. with your consent in any other cases.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. Security of Data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Data security includes data encryption, hashing, tokenization, and key management practices that protect data across all applications and platforms.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the UK, the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at sam@stealthtracer.com.

In certain circumstances, you have the following data protection rights:

0.1. the right to access, update or to delete the information we have on you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

0.2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete though we may need to verify the accuracy of the new data you provide to us;

0.3. the right to object. You have the right to object to our processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object;

0.4. the right of restriction. You have the right to request that we restrict the processing of your personal information in one of the following scenarios:

• If you want us to establish the data's accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

0.5. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.;

0.6. the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent;

0.7 the absolute right to object any time to the processing of your personal data for direct marketing purposes.

0.8 the right to request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Service without some necessary data.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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. In the UK this is the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

11. Service Providers

We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

12. Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

13. CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

14. Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

15. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

16. Children’s Privacy

Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).

We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

17. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.