EZ Lynk, SEZC (“EZ Lynk”, “we”, “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide when you visit the website www.ezlynk.com (the “Website”) or use the AutoAgentTM Application (the “App”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Policy also describes our practices with respect to the cloud-based document management and storage service we provide (the “Cloud Services”) as well as the Electronic Logging Device services we offer (the “ELD Services”). The Website, App, Cloud Services and ELD Services are sometimes referred to in this Policy as the “Services”. This Policy also applies to information we collect from you in email, text or other electronic messages between you and EZ Lynk.

Please read this Policy carefully to understand our policies and practices regarding your Personal Information (as defined below) and how we will treat it. If you do not agree with this Policy, your choice is not to use our Services. By continued use of our services, you consent to the collection and processing of your Personal Information as defined by this policy.

We collect the following “Information” from users of our Website, App and Cloud Services: name, phone number, email address, physical address, driver’s license, IP address, location data, and purchase history (“Personal Information”). In addition, we also collect information that some jurisdictions consider sensitive. Those categories include driver's licenses and precise geolocation. Please note that we do not collect credit card information.

We collect Personal Information directly from you when you provide it to us by registering an account on our Website, App or Cloud Services. We also collect information automatically when you visit or use the Website, App, or Cloud Services, including information about your IP address and information collected from cookies. This information collected automatically may include Personal Information.

All documents, including documents and files containing Personal Information and other personally identifiable information, such as photographs and videos, which you upload to the Cloud Service remain your property. EZ Lynk is only a processor, or custodian for the documents or files you store in the Cloud Services. All documents or files are encrypted in transit and at rest and are safely stored in secure data centers. You control all access to, and use of, such documents or files. EZ Lynk personnel have no access to your documents or files, except when explicitly granted by you. EZ Lynk has no knowledge regarding the content of your documents or files. You are responsible for meeting your obligations with respect to all Personal Information or other personally identifiable information you upload to the Cloud Services. EZ Lynk is responsible for providing you a robust, secure document management and storage service.

When registering as a driver to use the ELD Services, we may collect Personal Information listed above as well as your driver’s license number and license state. We also collect information about the Cycle Rules you use, cargo type, and Cycle Restart type.

When registering as a fleet manager to use the ELD Services, we may collect the Personal Information listed above as well as your carrier’s name, phone number, US Department of Transportation number, company Cycle Rules, company address and contact information, cargo type and Cycle Restart type. Fleet managers may also voluntarily provide a photograph while using the ELD Services.

When registering as a technician to use the ELD Services, we collect the Personal Information listed above as well as the name of your company, company address and company contact information. Technicians may also voluntarily provide a photograph while using the ELD Services.

If you or your employer has installed one of our Electronic Logging Devices (“ELD”) in your vehicle, or you are using the App, the ELD or App will collect various types of information concerning your vehicle and your operations either for you or on behalf of your employer (typically, a fleet manager). For example, information is collected by sensors built into the ELD installed in your vehicle. The following information may be collected when using the ELD or App: vehicle information including VIN number, make, model, location, speed, engine faults, fuel level, and driver information, such as driver location, routes taken, or hours of service, and images and video of drivers, passengers, and persons immediately surrounding your vehicle. Such information may include Personal Information. Only those who use the ELDs (you, your employer or fleet manager) may access information collected by ELDs.

When you use our Website, App or Cloud Services, we use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to, or use of, the Website, App or Cloud Services, including traffic data, and other communication data that can not be reidentified to you and the resources that you access and use on the Website, App or Cloud Services.
• Information about your computer or mobile device and internet connection that cannot be identified to you, including operating system and browser type.

We collect and use your Personal Information for the purpose of conducting our business, performing a contract with you (delivering our Services to you) and pursuing our legitimate interests, including for the following purposes:

• To present our Website and App and their contents to you.
• To provide you with information, products, or services that you request from us.
• To provide the Cloud Services to you.
• To provide you with notices about your account or subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to the Services.
• To allow you to participate in interactive features provided by products or services we offer.
• To improve the functionality of the Website and App.
• To improve security and combat fraud.

We may share your Personal Information with others, such as our subsidiaries or affiliates, contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information secure and to use it only for the purposes for which we disclose it to them, or a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EZ Lynk's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by EZ Lynk about our Website, App or Cloud Services users is among the assets transferred. If you are using one of our ELDs in connection with professional services you perform as a driver, we may disclose your Personal Information and non-personal information with your fleet manager or employer, to the extent you are part of, or employed by, such fleet manager or employer. We may also disclose your Personal Information to comply with a court order, law, or legal process, including to respond to any government or regulatory request, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of EZ Lynk, our customers, or others. We may disclose aggregated information about our users, and non-personal information without restriction. We do not sell, trade, or lease your Personal Information to third parties, except as described in the “Your Rights” section of this Policy.

A cookie is a small file placed on your computer by a website that uses the cookie to store information about your use of the website to help users navigate websites efficiently, as well as to provide information to the owner of the website. There are two general types of cookies: session cookies and persistent cookies. Session cookies are only used during a single session online and will be deleted once you leave a website. Persistent cookies have a longer life and will be retained by the website and used each time you visit a website. Both session and persistent cookies can be deleted by you at any time through your browser settings.

When you visit the Website, we may place session and/or persistent cookies in order to improve your experience by recognizing you when you return to the Website, such as by assigning a session ID, and to deliver content specific to your interests. We may also allow our affiliates and third-party vendors to use cookies on our Website. Some of these parties may use cookies in ways that we do not.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you visit the Website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.

Certain web browsers may allow you to enable a “do not track” option that sends signals to the websites you visit indicating that you do not want your online activities tracked. This is different than blocking cookies as browsers with the “do not track” option selected may still accept cookies. We currently do not honor “do not track” signals. If we do so in the future, we will update this Policy accordingly.

EZ Lynk is located in the Cayman Islands. If you are using the Services from outside the Cayman Islands, please be aware that any Personal Information you share with us will be stored and/or processed in the Cayman Islands where we locate and operate our servers and databases. We may also use cloud-based service providers located in other countries to store information we collect from you, including Personal Information. By voluntarily sharing your Personal Information with us, you understand that your Personal Information will be stored and/or processed in the Cayman Islands and other jurisdictions.

Individuals in the European Economic Area (“EEA”) and Switzerland have certain data subject rights that may be subject to limitations and restrictions. These rights include the right to: (i) request access to and rectification or erasure of their Personal Information; (ii) obtain restriction of processing or object to processing of their Personal Information; and (iii) ask for a copy of their Personal Information to be provided to them or a third party in a machine readable format. If you wish to exercise one of the above-mentioned rights, please send us your request to the contact details set out below. Individuals in the EEA and Switzerland also have the right to lodge a complaint about the processing of their Personal Information with their local data protection authority.

State consumer privacy laws may provide their residents with additional rights regarding using their personal information. To learn more about California residents’ privacy rights, visit https://oag.ca.gov/privacy/ccpa or see the section below related to California. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email or write us.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise these rights, please email us at legal@ezlynk.com

California

The California Consumer Privacy Act 2018 (the “CCPA”) and its recent addition of the California Privacy Rights Act of 2023 (“CPRA”) grants specific rights to California residents and requires that we make certain disclosures. If you are a California resident, you have the right to: (i) request that we delete Personal Information that we have collected about you; (ii) request that we disclose the Personal Information we have collected about you; (iii) request that we disclose whether we sell (or sold) your Personal Information; (iv) opt-out of the sale of your Personal Information (to extent we sell your Personal Information); (v) not face discrimination for exercising your rights under the CCPA; (vi) request that we correct your data; and (vii) request that we limit the processing of sensitive data if possible. With respect to the sale of Personal Information, the CCPA defines “sale” or “sell” broadly to cover scenarios that are traditionally not considered a sale of Personal Information. Accordingly, there may be instances where we sell (as that term is defined under the CCPA) Personal Information. To exercise your right to opt-out of such sale, you (or your authorized agent) may submit a request to us by visiting the following link: https://cloud.ezlynk.com/ccpa/donotsellmypersonalinformation. To exercise other rights under the CCPA, you (or your authorized agent) may contact us by submitting a verifiable consumer request as described below. Your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We collect the following categories of Personal Information directly from you and indirectly from you: (i) Identifiers, which includes the following specific pieces of Personal Information: name, telephone number, email address, street address, and IP address; (ii) Commercial Information, which includes the following specific pieces of Personal Information: products or services purchased or considered, or other purchasing or consuming history or tendency; and (iii) Internet or other electronic network activity information, which includes the following specific pieces of Personal Information: browsing history, search history, and information regarding your interaction with the Services.

The purposes for collecting and selling (as that term is defined by the CCPA) Personal Information, and how we use and share Personal Information, are those outlined in the “How We Use Your Personal Information” and “Disclosure of Information” sections of this Policy. In the preceding twelve months, we have:

• collected the following categories of Personal Information: Identifiers, Commercial Information, and Internet or other electronic network activity information.
• “sold” (as defined by the CCPA) the following categories of Personal Information: Identifiers.
• disclosed for a business purpose the following categories of Personal Information: Identifiers, Commercial Information, and Internet or other electronic network activity information.
• collected Personal Information from the following categories of sources: directly from you and indirectly from you.
• shared Personal Information with the following categories of third parties: service providers that help facilitate our business.

California Civil Code Section § 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below.

We implement appropriate security measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any of our Services’ privacy settings or security measures.

Ads appearing on our Website or App may be delivered to you by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile non-personal information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Policy does not cover the use of cookies by any advertisers.

If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information, etc. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us using the contact information below.

You may find advertising or other content on our Website that link to the websites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. Such external links and websites are operated by third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Website. In addition, these websites or services, including their content and links, may be constantly changing. These websites and services may have their own privacy policies and customer service policies. Once you have left our Website, we cannot be responsible for the protection and privacy of Personal Information you provide on other websites. Browsing and interaction on any other website, including websites which have a link to our Website, is subject to that website’s own terms and privacy policy. You should exercise caution and review the privacy policy of any website you visit.

Our Website is not intended for children under 13 years of age. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on this Website, App or Cloud Services on or through any of their features or register on the Website, App or Cloud Services, make any purchases through the Website or App or Cloud Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us using the contact information provided below.

We retain your Personal Information for as long as you store documents in the Cloud Services or remain a customer of the Services provided by the Website or App, and thereafter only for the period necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is required or allowed by law, including to fulfil a legal obligation. We do not retain any Personal Information collected by ELDs installed on your vehicle. Retention of such information is subject to your employer’s data retention policy.

We may update this Policy from time to time. When we do, we will post a notification on the main page of our Website and App and revise the “last modified” date at the top of this Policy. We encourage you to frequently review this Policy for any changes to stay informed about how we are helping to protect the Personal Information we collect.

If you have questions or concerns about this Policy, please contact us at:

legal@ezlynk.com

or by mail at:

EZ Lynk
P.O. Box 10315
125 Owen Roberts Drive
KY1-1003, Cayman Islands