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 or rent your personal data, and we never share your tracking data (vehicle locations, trips, or device telemetry) with anyone for marketing. The only marketing-related sharing is the advertising measurement described below, which you can turn off.

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. When you place an order we send Google the order number, order value, and the products bought, so we can measure sales. We do not send Google your name, email address, phone number, payment details, or any tracking data from your devices. See Google's Privacy Policy and how Google uses data from sites that use its services.
• Advertising measurement: we advertise with Google Ads (supplied by Google LLC). If you arrive by clicking one of our ads, Google records that click so it can tell us whether the ad led to an enquiry or a purchase. We do not use this for remarketing or to build an advertising profile of you.
• Meta advertising measurement: we advertise on Facebook and Instagram (supplied by Meta Platforms, Inc.) and use the Meta Pixel and Meta's Conversions API only to measure whether those ads lead to enquiries and sales. When you send an enquiry or place an order, we tell Meta that it happened, with the order value and product for a sale. So Meta can match the event to a Facebook or Instagram account, we include your email address and phone number in hashed form: scrambled into a code that cannot be turned back into the original, which Meta compares against its own hashed records. We do not send Meta your name, payment details, or any tracking data from your devices, and we do not use Meta for remarketing or to build audiences from our visitors. Meta may process this data outside New Zealand. See Meta's Privacy Policy.
• Customer support chat: if you use the chat widget on our website, your messages and any contact details you provide are stored on our servers and forwarded to our support team via Telegram so we can reply. First replies may be written by an AI assistant (Claude, supplied by Anthropic PBC), which processes your messages on our behalf and may do so outside New Zealand. Anthropic does not use this data to train its models. You can ask to speak to a person at any time.
• 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 for up to 7 years while your subscription is active.
• If your subscription ends, we can give you a copy of your tracking data on request, but we don't retain it.
• 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 three 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.
• Advertising measurement cookies: set by Google Ads and the Meta Pixel when you arrive from one of our ads, so we can count which ads lead to enquiries and sales. We do not use them for remarketing (following you around the web with our ads) or for personalised advertising.

We never send analytics or advertising providers your name, payment details, or any GPS or telemetry data from your tracked devices. For completed orders we send the order number, value, and products bought. Meta also receives your email address and phone number in hashed form when you send an enquiry or place an order, as described in section 3. Google never receives your email address or phone number.

Your choices

Analytics and advertising measurement (Google and Meta) are on by default, and we show a short notice on your first visit. You can turn all of it off at any time for this browser here. Opting out also stops us sending Meta the hashed enquiry and order events described above:

If you visit from the European Economic Area, the United Kingdom, or Switzerland, analytics and advertising measurement (Google and Meta) are off by default.

You can also block or delete cookies through your browser settings, or opt out of Google Analytics on every site 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.