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LEGAL INFORMATION

Biometric Information Privacy Policy

Privacy Policy

Last Updated: February 25, 2025

This Lytx Biometric Information Privacy Policy (“Policy”) supplements our Lytx Privacy Policy and does not supersede the Lytx Distracted Driving In-Vehicle Alert Data Policy.  This Policy explains our collection or capture, use, generation, retention, and storage of Biometric Information (defined below) related to our clients’ employees, contractors, workers, drivers, and passengers (collectively, “Fleet Personnel”). This Policy applies to Lytx, Inc., together with our controlled affiliates and subsidiaries (collectively, “Lytx”, “we”, “us” and/or “our”).

This Policy is designed to comply with applicable U.S. federal, state, and local Biometric Information laws and regulations (“Biometric Laws”). This Policy is not intended to create any rights beyond those that exist by virtue of these Biometric Laws. For purposes of this Policy, “Biometric Information” shall have the meaning as defined under such applicable Biometric Laws (and is inclusive of such similar terms such as “Biometric Identifier” or “Biometric Data”). This Policy shall only apply where the information collected or captured, used, retained, and stored by a Lytx service meets such definition.

Lytx services are intended for and provided to businesses and other organizations and not individual consumers. Certain Lytx services provide our clients with the ability to collect or capture, use, generate, retain, or store Biometric Information. Where our client elects to use such services, Lytx processes Biometric Information as a service provider or a data processor to our client, so we do not control and are not responsible for the privacy practices of our client. When we collect or capture, use, retain and store Biometric Information on behalf of our clients, our processing is subject to the control and instructions of such client as permitted by our agreements and applicable law.  

Biometric Information Our Services Collect or Capture

When enabled by our client, Lytx services collect, capture, use, generate, retain, and store Biometric Information relating to Fleet Personnel to perform the client-requested services in accordance with our agreements. Additionally, our client may enable a subscribed Lytx service to collect or capture a facial scan or facial geometry from which Biometric Information and related metadata is generated or derived.

Purposes of Use

Lytx does not control how our clients use Biometric Information relating to Fleet Personnel and does not access such information except where necessary to provide the services. Where our client enables the collection or capture of Biometric Information, the client shall determine the purpose and use of the Biometric Information in accordance with Biometric Laws.  With our services, our clients may have the ability to use Biometric Information for the following purposes:

  • Identity verification for associating Fleet Personnel with a particular vehicle for a segment of time, and improving client systems, assets and resources; 
  • Manage, monitor, and detect unauthorized access and use of client vehicles;
  • Legal and policy compliance administration and enforcement, including monitoring access and use of client vehicles;
  • As otherwise described to Fleet Personnel in a client notice.

Retention and Deletion 

Biometric Information will be deleted within one year from the client’s last use of such Biometric Information unless Lytx receives an instruction from our client to retain such Biometric Information for a longer timeframe, so long as such instruction complies with applicable Biometric Laws.  In the case of such instruction, Biometric Information will be retained in accordance with such client’s retention and deletion policies. Biometric Information will be deleted from Lytx systems in accordance with our internal deletion policies and processes. 

Your Privacy Rights

As Lytx is a service provider or processor with respect to the Biometric Information it processes on behalf of its clients, Fleet Personnel must contact the business with whom they are engaged for employment or contract with any inquiries, questions, or complaints regarding their individual rights or the business’ privacy practices.  

Changes to This Policy

Lytx may occasionally update this Policy to reflect changes in the law or our practices or procedures. If we make material changes to this Policy, or in how our services collect, capture, use, or retain Biometric Information we will provide notice or obtain consent regarding changes as required by law.