Privacy Notice

Last updated: 12/2/24

Update 9/1/24: This update includes general maintenance, changes to the information we collect including demographic information, and additional information for your choices regarding your information.

Update 12/2/24: This update includes revisions to clarify how personal information is shared among Alcohol Detection Systems Technology, Breathe Easy, DUICare, DUI.org, Intoxalock, and Keeper, which make up the Mindr family of brands. This update also addresses new state privacy laws that are applicable to Mindr.

Who We Are

This is the Privacy Notice of Mindr and its family brands, which include Alcohol Detection Systems Technology, Breathe Easy, DUICare, DUI.org, Intoxalock, and Keeper (“We” or “Mindr”). We are committed to safeguarding the privacy of our users.

Scope

This Privacy Notice applies to Mindr products and services, including our websites, our mobile applications, our devices, and any related interactions with our live agents, mobile applications, contests, sweepstakes, promotions, surveys, and forums (collectively, “Services”). This Privacy Notice describes the information We collect through your use of our Services, how We use it, how We share it, how We protect it, and the choices you can make about your information. It does not apply to other Mindr products or services that link to a different privacy notice.

Unless explicitly stated otherwise, any new products, services or features that enhance the current Services shall be subject to this Privacy Notice unless they link to a different privacy notice.

NOTICE: Please read this privacy notice carefully before you access, download, or otherwise use our Services. By continuing to use our Services, you acknowledge (a) that you have read and understood this Privacy Notice; and (b) this Privacy Notice shall have the same force and effect as a signed agreement.

California consumers can find specific disclosures, including “Notice at Collection” details by clicking here. To see our Washington State Consumer Health Data Privacy Policy, click here.

I. Information We Collect

The personal information We collect depends on how you interact with us, the Services you use, and the choices you make.

We collect information from you when you submit a request or inquire about our products or services, when you use our Services, or otherwise contact or interact with us. The information We collect may come from the following sources:

• Information you provide to the Mindr brands directly;
• Information we collect automatically when you use our website or other Services;
• Information you voluntarily share with third-party partners that We work with;
• Information that is publicly available;
• Information provided by government agencies (e.g. we may receive information from the Department of Motor Vehicles in order to comply with legal obligations and to validate the information We have about you in connection with providing you the Services.).

Types of information that We may collect from you, our affiliated entities, and external third-party sources include:

• Identifiers and Contact information, such as your name, email address, mailing address, phone number, and driver’s license information.
• Account information, such as your username and password.
• Demographic information, such as your gender, birth date, age, familial status, income, racial or ethnic origin and/or profession;
• Payment information, such as your credit or debit card number and billing address.
• Commercial information, such as purchase history and information submitted with your contract or lease;
• Vehicle/Driver information, including vehicle identification number, make and model, and driving history;
• Information related to citations and/or use of our products, including the location of citation (i.e. city, county, and state), blood alcohol content, DUI history, incident data, and court date information. We may also collect information that relates to your criminal history and alcohol monitoring requirements (e.g. device requirements, monitoring authority, and install by date).
• Biometric information, such as facial geometric features obtained from a scanned photo. This category of personal information will only be collected in limited circumstances where we rely on trusted third-party identification providers to verify your identity in connection with your use of Intoxalock and Alcohol Detection Systems Technology Ignition Interlock Devices (IIDs). Biometric information will be deleted promptly after your identity has been verified. We do not use, disclose or retain biometric information for any other commercial purpose.
• Geolocation information, including your precise location may be collected when you use our IIDs and similar devices.
• Audio, visual, or similar information, including photographs and recordings of customer service interactions such as calls, chats, emails, text, or other correspondence with us. Our chat or phone providers may have access to the recordings solely to provide their services to us. Call recordings are collected and stored by us to perform quality assessments in connection with providing you the Services. We do not share these recordings with any third parties, except to the extent necessary to comply with a legal obligation or to insurance carriers in connection with an application for insurance or related claim.
• Information from cookies and other automated technologies, such as information about the devices you use to engage with our Services (e.g., your device and browser type; your device’s operating system, device ID, Mobile Device Advertising ID (MAID), or other persistent personal identifiers; and your geographic location based on IP address), and online activity data including information regarding your interaction with our Services and our advertisements (e.g., how long you use our Services, which pages or content you view, and on which dates and times, as well as other general analytics information). On certain Services, we use tools to look at mouse movements, clicks, keystrokes, data or text entered, and the pages you visit. For more information about the use of cookies and trackers, see the Cookies and Other Tracking Technologies section below.
• Personal information provided by social media platforms, such as Facebook, Instagram, Linkedin, Twitter, Google, and Microsoft, if you connect with these platforms through our Services
• Any other information that you voluntarily provide or submit to us, information you provide us in connection with a request to become an affiliated partner and feedback about our products and services (including reviews).

We may combine all the information We collect from and/or about you, including from third-party tools, and use it in the manner described in this Privacy Notice.

Some of the information described above may be considered “sensitive” under the laws of certain jurisdictions (including payment information, account login credentials, driver’s license number, race and ethnicity, biometric information, and precise geolocation information) (“Sensitive Information”). Whether information is Sensitive Information will depend on the laws of your jurisdiction.

II. How We Use Your Information

We use the information that We collect for several purposes, including:

• The purposes for which you provided the information;
• To provide you with the products or services you reasonably expect from us;
• To provide information about our products and services or other information that We think may be of interest to you;
• To process and respond to your inquiries and requests;
• To connect you with third-party providers or our affiliated entities to provide you with your requested products and services;
• To promote and advertise our and our affiliated entities’ products and services to you;
• To contact you for market research purposes and to use this information to customize our Services according to your interests;
• To administer, operate, and improve our Services or to further the mission of Mindr;
• To personalize and enhance your experience using our Services;
• To provide you with occasional news, updates, or related product or service information;
• To engage with you on social media platforms;
• To administer entries into sweepstakes, contests, promotions or surveys;
• To allow you to use our mobile application;
• To contact you about potential vendor opportunities if you visit one of our vendor pages;
• To generate and review reports and data about our user base and Services usage patterns;
• To analyze the accuracy, effectiveness, usability or popularity of our Services;
• To create and compile de-identified or aggregate data for internal and external business purposes. When we create de-identified data, we do not attempt to re-identify that data;
• To prevent fraud and abuse of our Services and to otherwise protect users and visitors and our business (including by using biometric information to verify your identity in limited circumstances);
• To comply with the law;
• To assist law enforcement and respond to subpoenas or other regulatory or legal proceedings;
• To perform other business activities as needed, or as described elsewhere in this Privacy Notice.

We use Sensitive Information for necessary or reasonably expected purposes – specifically, to fulfill purchases, allow account logins, comply with our legal obligations including state IID requirements, and as authorized by law. Additionally, we may use demographic information, including race/ethnicity, collected from third party sources to create demographic profiles which helps us to update, expand and analyze our existing information to tailor products and services that may be of interest to you ). Please see our U.S. State Privacy Notice for information about your choices for these practices.

III. How Your Information is Disclosed

Information may be disclosed to third parties in accordance with our Privacy Notice or as otherwise permitted by law. Please note that a user may choose not to share certain information as described in Your Choices Regarding Your Information below.

A. Government agencies, law enforcement, monitoring authorities, and similar parties.

We will share your information with the government, law enforcement, monitoring authorities (e.g., judges and probation officers) and/or other parties if needed to:

• Comply with the law or guidance and cooperate with government or law enforcement officials or private parties;
• Investigate, prevent or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety, and property of us, users or others, or violations of our policies or other agreements with us;
• Comply with legal and contractual requirements in connection with the Services, such as providing information about you pursuant to a court order, or to parole officers and other authorized monitoring entities (Intoxalock, ADS, and Keepr), and providing information to insurance carriers for the purpose of obtaining rates, applying for, and purchasing insurance about (Breathe Easy);
• Respond to claims and legal process (for example, subpoenas); and/or,
• Protect against legal liability.

B. Third Party Service Providers

We use third party service providers that provide services on our behalf or help us perform functions in connection with our Services, such as administration services; customer relationship management services, agent and agency licensing; technical services relating to the installation, maintenance, servicing, and upgrading of our products; identity verification services, hosting services; customer service; data management services, data migration services; payment processing services; debt collection services; and analytical services (e.g. device, website).

We also may share your personal information with these providers to market and promote our Services to you online, or through offline advertising methods such as direct mail. If you opt-in to a short code or SMS campaign with us, We may share your personal information with service providers, however, they will not use your information for their own text message marketing purposes.

C. Business/Advertising Partners

We may share personal information with other companies where you use a service that is cobranded and jointly operated with another company, or where you use the Services to interact with another company.

We also share personal information with advertising partners (e.g., ad networks, social networks, and other parties) to serve you third-party advertisements, including interest-based advertisements, on our Services and on other services. Specifically, we share information collected through cookies and similar technologies with our advertising partners, which may also be subject to their privacy policies. To learn about how to control how we share your information with marketing partners see the “Your Choices Regarding Your Personal Information” section below.

D. Affiliates/Mindr Brands

We share your information within Mindr’s family of brands and affiliated entities (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control) for purposes consistent with this Privacy Notice. This includes sharing your personal information with our brands and affiliated entities for their direct marketing and promotional purposes and so they can provide services to you. Our brands and affiliated entities will be required to maintain that information in accordance with this Privacy Notice.

E. Parties Associated with a Corporate Transaction

If We become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, We may transfer Your information to a third-party or parties in connection therewith.

F. At Your Direction

We may share your information with third-parties for purposes consistent with this Privacy Notice and with your direction or authorization. For example, you may voluntarily elect to disclose your information with other users of the Services whom you are connected to or third-parties such as DUI schools, your attorneys or your counselor.

G. De-identified/Aggregate Information

We may share de-identified or aggregated information relating to users of our Services with affiliated entities or third parties. This de-identified or aggregated information does not contain personal information about a particular user or information that may be reasonably linked to a unique user.

IV. Cookies and Other Tracking Technologies

We, along with third parties, use cookies, pixels, local storage objects, web beacons, call tracking and other similar technologies. These technologies are used for tracking, analytics, advertising, and personalization and optimization of the Services.

A. Cookies. Cookies are small files that are transferred to and stored on your computer through your Web browser that enable the website’s or service provider’s system to recognize your browser and capture and remember certain related information. You can instruct your browser to either stop accepting cookies, clear your browser cookies or adjust browser consent or other settings yourself. But if you do not accept certain cookies, you may not be able to use all portions of the Services due to functionality limitations. Here are the types of cookies that may be deployed by your browser:

• Persistent cookies remain on the visitor’s computer after the browser has been closed.
• Session cookies exist only during a visitor’s online session and disappear from the visitor’s computer when they close the browser software.
• Flash cookies (also known as local shared objects) are data files that can be created on your computer by the websites you visit and are a way for websites to store information for later use. Flash cookies are stored in different parts of your computer from ordinary browser cookies. You can disable the storage of flash cookies. For additional information about managing and disabling flash cookies, please visit http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

B. Web beacons. Web beacons are small strings of code that provide a method for delivering a graphic image on a Web page or in an email message for the purpose of transferring data. We use web beacons to compile aggregated data about web usage and traffic. We do not use web beacons to access information that directly identifies you. You can disable the ability of web beacons to capture information by blocking cookies.

We use cookies and other tracking technologies on our Services to help us understand and save your preferences and interests so We can personalize your future visits.

We allow some of our business partners, such as our analytics providers, advertising networks, social sharing provider, and social media connections, to set cookies and other tracking technologies when you visit our Services, which may track users across websites and over time.

We also use cookies and tracking technologies to compile aggregate data about website traffic and website interactions so that We can offer better website experiences and tools in the future. For example, We use Google Analytics to better understand who is using our Services and how people are using them. Google Analytics uses cookies to collect and store information such as Service pages visited, places where users click, time spent on each Service page, Internet Protocol address, type of operating system used, location-based data, device ID, search history, gender, age, and phone number. Please see http://www.google.com/policies/privacy/partners/ for information about how Google Analytics uses this information, and visit https://tools.google.com/dlpage/gaoptout for information about the Google Analytics Opt-out Browser Add-on.

We use call tracking technologies to compile aggregate data about phone traffic for analytics and internal performance reporting purposes. Anonymous call tracking data may be shared with third-party tools for the purpose of internal performance reporting.

You can manage your cookie preferences here.

Cookie Settings

V. Security

We implement a variety of security measures to protect the safety of your personal information when you enter, submit, or access your personal information.

While We take reasonable measures to protect the information you submit via our Services against loss, theft and unauthorized use, disclosure, or modification, We cannot guarantee its absolute security. No Internet, email, or mobile application transmission is ever fully secure or error free. Email or other messages sent through our Services may not be secure. You should use caution whenever submitting information through our Services and take special care in deciding which information You provide us.

We cannot guarantee that transmissions of your personal information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. Please take steps to keep your account credentials secure and do not reuse passwords across multiple websites/accounts. You are solely responsible for the security of your account credentials and the activities that occur under your account. We assume no liability for the disclosure of your information due to transmission errors, third-party access, or causes beyond our control.

VI. Jurisdiction

Our Services are hosted in and managed and controlled by us from the United States and is not intended to subject us to the laws or jurisdiction of any jurisdiction other than that of the United States. Any information collected through our Services is stored and processed in the United States. If you use our Services outside of the United States, you consent to having your data transferred to the United States. United States data protection and other relevant laws may not be the same as those in your jurisdiction. This includes the use of cookies and other tracking technologies as described above.

VII. Data Retention

Unless otherwise required by law, We will retain your personal information to the extent necessary to fulfill the purpose for which that personal information was collected. Please note that We may be required to retain your personal information for a reasonably longer period of time to the extent necessary to comply with regulatory or legal obligations, resolve disputes, enforce our agreements or for any other business purpose in accordance with applicable laws.

We may retain de-identified or aggregated data, including usage data, for analytics purposes. Please note that some or all of the information We have collected may be required for our Services to function properly.

VIII. Links to Other Websites or Applications

This Privacy Notice applies only to our Services. Our Services may contain links to other websites or apps or may forward users to other websites or apps that We may not own or operate and to which this Privacy Notice does not apply. The links from our Services do not imply that We endorse or have reviewed these websites or apps. The policies and procedures We describe here do not apply to these websites or apps. We neither can control nor are responsible for the privacy practices or content of these websites or apps. We suggest contacting these websites or app providers directly for information on their privacy policies. Nonetheless, We seek to protect the integrity of our Services, and welcome any feedback about these linked websites and mobile applications.

IX. Your Choices Regarding Your Information

You have choices regarding the use of Your information.

• Access, Correction, and Deletion – If you have an account with one of our Mindr brands, you can access, copy, download, correct, or delete personal information that we collect about you, by logging into your account. You may also use the form found here to submit a request.

The Right to Know/Access: You have the right to know about the personal information we collect from or about you, and to request a copy of that personal information. Generally, you may be able to access your personal information through your online user account if you have created one.

The Right to Correct: You have the right to correct inaccurate personal information that We maintain about you. You may access your account through our websites or mobile app and update your personal information. For personal information that cannot be changed via your account or as an alternative means of updating your personal information, you may contact us to request the change – please see Contact Information below. We will use commercially reasonable efforts to honor your requests within the limits defined by applicable law.

The Right to Delete: You have the right to request that We delete the personal information We have collected about you, subject to certain limited exceptions. For example, We may retain an archived copy of your records consistent with applicable law, to continue to provide our services to you, or for other legitimate business purposes.

• Marketing Opt-Out – You can opt-out of receiving our promotional or marketing communications. If you receive promotional mail, email or SMS/text messages from us, you can opt-out by following the directions in that message. You can opt out of our marketing text messages by replying “STOP”. Alternatively, for mail, email, phone, or SMS/text message, contact us by writing to Mindr, Attn: Marketing Opt Out, 11035 Aurora Avenue, Des Moines, IA 50322, with your request and include (i) your name and account number (if applicable), (ii) if you are requesting communications to cease via mail, email, phone, or SMS/text message, (iii) the specific mailing address(es), phone number(s) or email address(es) to which the opt-out applies, and (iv) the specific Mindr brand to which your opt-out request applies (e.g., Intoxalock or DUICare). Alternatively, please use the form found here to submit your opt-out request.
• Do Not Track – Your browser or device may offer you a “Do Not Track” (DNT) option, which allows you to signal to operators of websites, web applications, mobile applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites or applications. Unlike the Global Privacy Control (GPC) described below, there is not a common understanding of how to interpret the DNT signal; therefore, our websites and Services do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the GPC, cookie controls, and advertising controls described herein.
• Targeted advertising – To opt-out from or otherwise control targeted advertising, you have some options.
  • You can use the Do Not Sell or Share My Personal Information link in the footer of our websites
  • You can use the GPC setting in a web browser or browser extension as described below.
  • You can use the opt-out controls offered by the organizations our advertising partners may participate in, which you can access at NAI (http://optout.networkadvertising.org) and DAA (http://optout.aboutads.info/
  • You can use the other cookie or mobile ID controls described below. These choices are specific to the device or browser you are using. If you access our services from other devices or browsers, take these actions from those systems to ensure your choices apply to the data collected when you use those systems.
• Browser or platform controls –
  • Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
  • Global Privacy Control. Some browsers and browser extensions support the “Global Privacy Control” (GPC) or similar controls that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. When We detect such a signal, We will make reasonable efforts to respect your choices indicated by a GPC setting or similar control that is recognized by regulation or otherwise widely acknowledged as a valid opt-out preference signal.
  • Appealing a denied request – If you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, We may decline requests in certain cases. For example, We may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, We may decline a request where We are unable to authenticate you as the person to whom the personal information relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you live in a jurisdiction that provides for a right to appeal denied requests, and you receive a response from us informing you that We have declined your request, in whole or in part, you may appeal that decision by submitting your appeal using the contact method described at the bottom of this Privacy Notice.
• Please see the U.S. State Privacy Notice for additional details on how to exercise your rights if you reside in a state with an applicable state privacy law.

X. Children

Our Services are not intended for children under 16 years of age. We do not knowingly collect personal information from an individual under age 16. If You are under the age of 16, please do not submit any personal information through our Services. If You have reason to believe that We may have accidentally received personal information from an individual under age 16, please contact us immediately as provided in Section XI, below.

XI. Changes to Privacy Notice

We reserve the right to update or modify this Privacy Notice at any time without prior notice, however you will be notified if We make any material changes that affect the use of your personal information before it takes effect. If you do not agree with the changes to how your personal information will be used, please do not continue to use this website. Your continued use of the website or Services after you have been notified of changes to the Privacy Notice will mean that you accept and agree to the changes to this Privacy Notice. Please review this Privacy Notice periodically, and especially before you provide any information. This Privacy Notice was made effective on the date indicated above.

XII. How to Contact Us

Please feel free to contact us by calling 1-844-535-0260, by writing to Mindr, 12421 Meredith Drive, Suite 100, Urbandale, IA 50323, or by visiting the Contact Us page if you have any questions about this Privacy Notice.