Privacy Policy

This Privacy Notice is for Low Voltage Limited (doing business as Spectre GPS) (“we”, “us”, or “our”). It describes how and why we collect, store, use, and share your personal information when you use our services, including when you:

• Visit our website at spectre-gps.co.nz
• Download and use our mobile application (Spectre GPS)
• Use our telematics platform
• Engage with us in other related ways, including marketing or events

Questions or concerns? Contact us at [email protected].

Table of Contents

1. What information do we collect?
2. How do we process your information?
3. When and with whom do we share your personal information?
4. How long do we keep your information?
5. How do we keep your information safe?
6. Do we collect information from minors?
7. What are your privacy rights?
8. Cookies, analytics, and Do-Not-Track
9. Do we make updates to this notice?
10. How can you contact us about this notice?
11. How can you review, update, or delete the data we collect from you?

1. What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide when you register on our services, make a purchase, or contact us. This may include:

• Names and usernames
• Email addresses
• Phone numbers
• Billing and shipping addresses
• Payment details (processed by Stripe; we never store card numbers directly)
• Contact preferences

Sensitive information. We do not process sensitive personal information.

Information collected through our application

If you use our mobile application or telematics platform, we also collect:

• Geolocation data: GPS position from your tracked devices, either continuously or while using the app, to provide location-based services. You may adjust permissions in your device settings.
• Device telemetry: speed, ignition state, digital input/output status, voltage, and other sensor data transmitted by your GPS hardware.
• Trip and event history: historical position logs, trip summaries, and system events (ignition, geofence crossings, alerts).
• Push notifications: if you grant permission, we may send notifications about your account or fleet events. You may turn these off in your device settings.
• Driver ID location: if you enable Driver ID Mode, the app periodically reports your device's approximate location to our servers using a low-power, battery-efficient location source, including in the background. We store only your device's most recent approximate position (not a continuous trail) and use it solely to decide whether your device is near a vehicle before sending you an “are you driving this?” prompt. This data is not shared with third parties. You may disable Driver ID Mode at any time in the app, which stops the reporting.

Information collected automatically when you visit our website

When you browse our storefront, some information is collected automatically by analytics cookies and similar technologies. This does not identify you by name, and we do not combine it with your account or tracking data:

• Usage data: pages viewed, links clicked, time on page, and the site or search that referred you.
• Device and browser data: browser type and version, operating system, screen size, and language.
• Approximate location: an approximate city or region derived from your IP address by our analytics provider.
• Cookies and identifiers: a random identifier stored in your browser so repeat visits can be counted as one visitor. See section 8 below.

2. How Do We Process Your Information?

We process your personal information for the following purposes:

• Account creation and authentication: to create and manage your account and keep it secure.
• Delivering our services: to provide GPS tracking, alerts, reporting, and related platform features.
• Processing orders: to fulfil hardware purchases and manage delivery.
• Administrative communications: to send order confirmations, account notices, policy updates, and alert notifications.
• Security and fraud prevention: to monitor for suspicious activity and protect our platform and users.
• Service improvement: to diagnose issues and improve platform reliability and features.
• Driver attribution (Driver ID Mode): if you enable Driver ID Mode, to confirm whether your device is near a vehicle so we only prompt the right driver and trips are attributed correctly. Your device reports its approximate last-known position (low-power, last-known only) for this purpose.

3. When and With Whom Do We Share Your Personal Information?

We do not sell, rent, or share your personal data or tracking data with third parties for marketing purposes.

We may share information in limited circumstances:

• Payment processing: Stripe processes payments on our behalf and is subject to their own privacy policy. We do not receive or store your full card number.
• Infrastructure providers: we use third-party hosting and cloud infrastructure to operate our services. These providers process data only on our instructions.
• Website analytics: we use Google Analytics (supplied by Google LLC) to understand how visitors use our storefront. Google processes this data on our behalf and may store it outside New Zealand. We do not send Google your name, email address, order details, or any tracking data from your devices. See Google's Privacy Policy and how Google uses data from sites that use its services.
• Customer support messaging: if you use the chat widget on our website, Intercom processes the messages and contact details you provide so we can reply to you.
• Legal obligations: we may disclose information where required by law or to protect the rights and safety of our users or the public.

4. How Long Do We Keep Your Information?

We retain your information only as long as necessary for the purposes set out in this notice:

• Order and billing records are retained for accounting and warranty purposes.
• GPS tracking and telemetry data is retained while your subscription is active.
• Upon account cancellation or deletion, tracking data is removed within 90 days.
• Account credentials are removed promptly upon a verified deletion request.

5. How Do We Keep Your Information Safe?

We have technical and organisational measures in place to protect your personal information, including TLS encryption for connections to our apps and dashboard, access controls, and secured infrastructure. However, no electronic transmission or storage technology can be guaranteed to be 100% secure. While we take reasonable steps to protect your data, we cannot guarantee absolute security against all threats.

6. Do We Collect Information from Minors?

Our services are not directed at children under 13 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a minor, please contact us and we will promptly delete it.

7. What Are Your Privacy Rights?

Under the New Zealand Privacy Act 2020, you have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Request deletion of your personal information
• Withdraw consent where processing is based on consent

To exercise any of these rights, contact us at [email protected]. We will respond within 20 working days.

8. Cookies, Analytics, and Do-Not-Track

Cookies we use

Our storefront uses two kinds of cookies and similar technologies:

• Essential cookies: needed for the site to work, keeping you signed in, remembering your cart, and securing checkout. These cannot be turned off without breaking the site.
• Analytics cookies: set by Google Analytics to measure how many people visit, which pages they read, and where they arrived from. This tells us what to improve. We use it in aggregate: we do not use it to identify you personally, build an advertising profile, or target you with ads.

We never send analytics providers your name, email address, phone number, order contents, payment details, or any GPS or telemetry data from your tracked devices.

Your choices

You can block or delete cookies through your browser settings, and you can opt out of Google Analytics entirely using Google's browser opt-out add-on. Blocking analytics cookies does not affect your ability to browse or buy from us.

Do-Not-Track

Most web browsers include a Do-Not-Track (“DNT”) feature. No consistent technology standard for recognising DNT signals has been finalised, so we do not currently respond to them. If that changes, we will update this notice.

9. Do We Make Updates to This Notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by a revised “Last updated” date at the top of this page. We encourage you to review this notice periodically. Continued use of our services after changes constitutes acceptance of the updated notice.

10. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, contact us at:

11. How Can You Review, Update, or Delete the Data We Collect from You?

To request access to, correction of, or deletion of your personal information, email us at [email protected] with your request. We will respond within 20 working days in accordance with the New Zealand Privacy Act 2020.