PRIVACY POLICY

Effective Date: August 20, 2026

GenLogs Corporation (“we,” “us,” “ours” or “GenLogs”) respects your privacy. This privacy policy (“Privacy Policy”) explains how we collect, process, store, and share personal information in connection with the GenLogs Service (as defined below), our roadside sensor network, our business operations, and related activities. “You” or “your” includes our customers, users of the Service, motor carriers participating in our carrier programs, and other persons about whom we collect or process personal information.

For purposes of this Privacy Policy, the “Service” means GenLogs’ Truck Intelligence offerings made available to customers and users, including (i) the GenLogs platform — the web application, mobile applications, browser extensions, and APIs through which customers access GenLogs’ data, intelligence, and analytics (the “Platform”); (ii) GenLogs’ website at genlogs.io; and (iii) related tools, dashboards, interfaces, products, and services offered by GenLogs from time to time. GenLogs also operates a roadside sensor network, cameras, connected devices, and related data collection infrastructure (including telematics and related operational data collected through such devices) that supports the Service but is not provided to customers or users as part of the Service. This Privacy Policy covers personal information collected in connection with the Service and the sensor network alike.

By providing personal information to us, you acknowledge that you accept our privacy practices and policies outlined below, and you consent that we may collect, process, store and share personal information as described in this Privacy Policy.

1.  Notice at Collection of Personal Information

1.1  Definition of Personal Information

We collect, process, store, and share information that identifies, relates to or could reasonably be linked, directly or indirectly, with a particular individual or household (“personal information”). Personal information does not include information publicly available from government records, or which is not personal, like anonymous, deidentified or aggregated data (even if it originally comes from personal information).

Categories of Personal Information We Collect

Depending on your relationship with us, we may collect, process, store, and share with third parties, the following categories of personal information:

  • Business contact information, such as full name, business address, email address and phone number

  • Account credentials, such as username and password

  • Professional or employment-related information, such as your job title, employer information and professional background

  • Financial information, including information used to pay for access to the Service, such as credit card, bank account and wire transfer information, and insurance policy information

  • Commercial information, such as the billing details we use to bill you for the Service, your billing and payment history, and any records of products or services purchased or considered

  • Internet and device identifiers, activity and analytics, such as information we automatically collect through cookies and tracking technologies used on our Service, including user activity on the Service, a user’s browser, operating system and device information, IP address and approximate geolocation

  • Precise geolocation, if you enable location sharing with us through your device

  • Audio, electronic, visual, thermal or similar information, such as audio or video recordings and images captured by our sensors and cameras. Our sensor and camera systems are not designed to derive biometric identifiers (such as facial geometry or other biometric data as defined under applicable biometric privacy laws) from the data they collect. 

  • Preference information, including preferences related to marketing, privacy and communications

  • Inferences drawn from any of the personal information listed in this section

  • Other information you choose to provide to us

1.2  Other Information We Collect

We collect information about commercial vehicles, which is generally not considered personal information under applicable privacy laws because the information is publicly available, not about an individual and/or deidentified, or falls under another exception to the definition of personal information. Other information we collect, process and store, and share with third parties includes:

  • Vehicle information, such as license plate and VIN number, and vehicle and equipment identifiers and characteristics that we derive from images we collect using automated recognition technologies

  • Carrier information, such as carrier name, US DOT number, MC number, and operational, safety, and compliance information; telematics and related operational data obtained from connected devices or third-party sources; and documents and records submitted by carriers or their personnel in connection with our carrier programs, such as tax forms, identification documents, insurance certificates, and electronic logging device records

  • Images of the exteriors of commercial vehicles, including trailers, containers, and other equipment they transport

  • Approximate and precise geolocation of a vehicle

Our systems are designed not to collect or store information regarding non-commercial vehicles. We have procedures in place to automatically obscure or remove non-commercial vehicle information inadvertently collected.

Our Business Purposes for Collecting and Sharing Personal Information

We collect, process, store and/or share all of the categories of personal information identified above (unless a limited subset of categories is indicated) for our following business purposes, our legitimate interests and the legitimate interests of users or third parties to:

  • Provide the Service, including maintain the Service, enable customers and users to access and use the Service, manage our relationship with our customers and users, process transactions and otherwise assist and respond to customers and users

  • Support our business operations, including to bill and collect payment for use of the Service, administer and protect our Service and systems, verify the identity of users, and use hosting, technology and communication providers and other vendors that support our business operations

  • Market the Service, for example, we process and share limited categories of personal information (contact information, professional information, commercial information, internet and device information (including geolocation data), preference information and inferences) to send you marketing communications

  • Improve the Service, for example, we process and share limited categories of personal information for our internal research and development purposes and to troubleshoot, test and conduct data analysis, to update and otherwise improve the Service’s functionality, to make informed business decisions and to improve user experience, such as using information about how users navigate and interact with the Service to improve its design and usability

  • Deidentify personal information, including aggregating and anonymizing personal information so that it is no longer personal information

  • Meet legal and compliance requirements, including to perform audits, monitoring and reporting; support information security and anti-fraud operations; investigate and respond to disputes; exercise and defend legal claims; protect the rights, property or safety of our customers, our users, you, us or a third party; respond to legal process (including subpoenas) and governmental, court or law enforcement requests, investigations or orders; and comply with and enforce applicable laws, regulations, policies, procedures and agreements

  • Evaluate or conduct business changes, including a merger, acquisition, sale, equity or debt financing, bankruptcy or other transaction in which a third party invests in or acquires control of our business or assets (in whole or in part)

GenLogs uses artificial intelligence and machine learning technologies in connection with the Service. Our AI and machine learning systems may be used to generate signals, insights, and analytics from the data we collect, including to identify patterns in commercial vehicle activity and carrier compliance. We do not use AI or automated decision-making to make decisions that produce legal or similarly significant effects on individuals. Additional information about GenLogs’ use of AI and machine learning, and the safeguards we apply to those uses, is available in our AI Usage & Governance Policy.

We only use sensitive personal information as necessary to provide the Service and for other purposes permitted under applicable law without separate consent, including security, fraud prevention, and ensuring physical safety.

We process personal information on the basis of our legitimate business interests described above, to perform our contractual obligations, to comply with our legal obligations, or with your consent.

Categories of Parties With Whom We Share Your Personal Information

We share personal information with the categories of parties listed in this section.

1.3  Third Parties

We may share personal information with the following categories of third parties for all of our business purposes described above:

  • Our affiliates for purposes consistent with this Privacy Policy

  • Our vendors who provide us with services and products that help us provide the Service and operate our business, including hosting, technology and communication providers; cyber security and other security providers; analytics and marketing providers; artificial intelligence providers; and our attorneys, advisors, auditors and accountants

  • Parties as directed by customers, we may share personal information with third parties as directed by the customer who is the controller for such personal information

  • Parties for marketing purposes, we may share the following categories of personal information with third parties for our marketing purposes: contact information, professional information, commercial information, internet and device information (including geolocation data), preference information and inferences

  • Parties to whom we make business contact information available through the Service, subject to the applicable customer agreement and in-product terms

  • Parties you access, authorize or authenticate, including third parties you access through the Service, such as identity or account verification providers and payment processors; information provided to such third parties are subject to such third parties’ privacy policies; please consult the applicable third party’s privacy policy for more information on how the third party uses your personal information

  • Parties for legal purposes, including governmental authorities, law enforcement, courts or other third parties in connection with any of the activities set forth in the bullet beginning with “Meet legal and compliance requirements” in the section above

  • Parties for business changes, for example, personal information that we collect may be shared with or transferred to a third party if we consider or undergo a merger, acquisition, sale, equity or debt financing, bankruptcy or other transaction in which a third party invests in, finances or acquires control of our business or assets (in whole or in part)

1.4  Customers

The Service is designed to make motor carrier and other information, together with GenLogs-generated signals, insights, and analytics, available to GenLogs customers. Such customers receive that information in connection with their use of the Service and are bound by the data use restrictions in their Master Subscription Agreement and the GenLogs Terms of Service.

  • We share personal information regarding a customer’s users with such customer and its users (we do not share information regarding a customer’s users with another customer without consent)

  • If we obtain personal information about other individuals from or on behalf of a customer (for example, personal information regarding a non-user employee or contractor of a customer), then we may share such personal information with such customer

  • Our customers are considered “controllers” or “owners” of personal information we collect and process on their behalf under applicable privacy laws; and our customers are not considered “third parties” under applicable privacy laws or this Privacy Policy with respect to personal information we collect and process on their behalf

  • This Privacy Policy does not control how our customers or users use personal information, which may be different from the uses described in this Privacy Policy; we have no responsibility for how our customers or users use personal information

1.5  We Do Not Sell or Share Your Personal Information for Targeted Advertising

We do not sell personal information. For purposes of this Privacy Policy, “sell” means the disclosure of personal information to a third party in exchange for money or other valuable consideration.

We do not share personal information with third parties for cross-contextual behavioral advertising or targeted advertising.

We do not share personal information with third parties for such third parties’ direct marketing purposes, except as described in this Privacy Policy or as authorized under the agreements and in-product terms governing use of the Service.

1.6  Retention of Personal Information

We retain personal information for as long as we deem to be necessary or advisable for our business purposes described above (such as providing the Service). This may include keeping your personal information after you have stopped using our Service; for example, we may retain your personal information to market the Service to you (unless you opt-out), comply with legal obligations, resolve disputes or collect fees owed. As a general matter, GenLogs’ Service is designed to generate cumulative insight over time from the data we collect, and we do not routinely delete information that contributes to the historical record of commercial vehicle activity, carrier compliance practices, or platform analytics.

1.7  Applicability of this Privacy Policy

This Privacy Policy covers how we treat personal information that we acquire from you, or in connection with our Service, or in connection with our other business. This Privacy Policy does not cover, and we are not responsible for, the policies or practices of customers, other users or third parties that you may access or be connected with through the Service or otherwise through us.

1.8  Sources of Personal Information

We collect personal information from the following categories of sources:

  • Directly from you, such as when you use our Service or when you communicate or interact with us in any way, including mail, email, phone, chat, QR code or social media

  • Indirectly from you, for example, we collect cookie data and other information from your device, browser or activity on our Service

  • From or on behalf of customers, for example, customers may provide us with the personal information of their employees or contractors

  • From motor carriers participating in our carrier programs, with respect to any personal information about their drivers, employees, or other personnel that they may include in document uploads or attestations

  • From third parties or public sources, for example, from our data and analytics providers or governmental records

Generally, you are not under a statutory or contractual obligation to provide personal information to us. However, if you do not provide the personal information required for us to facilitate certain services, verify your identity or process transactions, you may be unable to access the Service and we may be unable to facilitate services or otherwise conduct business with you.

2.  Providers and Customers and Third-Party Links

This Privacy Policy does not cover, and we are not responsible for, the privacy policies or practices of customers, users or any third parties, which have their own rules for how they collect and use personal information. Please make any privacy requests directly to customers, users or third parties with respect to personal information in their control.

The Service may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not endorse or control these third-party websites and are not responsible for their privacy practices or any information on their websites. When you leave our Service, we encourage you to read the privacy policy of every website you visit.

3.  Personal Information of Others You Share with Us

You may not disclose the personal information of another individual to us unless you have their prior written consent or are otherwise authorized under applicable law to share their information with us. This Section does not apply to business contact information that customers or motor carriers provide to us for use in the Service, which is governed by the applicable customer agreement and the GenLogs Platform Contact Use Terms. To the extent that you provide another individual’s personal information to us or we collect another individual’s personal information on your behalf, you acknowledge and agree that you are responsible for compliance with all applicable laws concerning such personal information, including:

  • Providing all applicable notices

  • Receiving the proper authority or consent to allow us to collect, store, process and share such personal information

  • Responding to data subject requests

4.  Personal Information of Children

We do not collect any personal information directly from children under 16 years of age. If you are a child under the age of 16, please do not attempt to use our Service or send us any personal information. If we learn we have collected personal information directly from a child under 16 years of age, we will delete that data as quickly as possible.

To our knowledge, we do not sell, or share for cross-contextual behavioral advertising or targeted advertising purposes, the personal information of children under the age of 16.

5.  CJIS Data

We do not collect, process or store Criminal Justice Information Services (CJIS) data. Thus, CJIS requirements are not applicable to our Service.

6.  Opt Out of Marketing Communications

You may request that we no longer send marketing communications to you. To opt out please send an email to support@genlogs.io. You may also unsubscribe using the link included in our marketing emails. In your request, please indicate if you wish to opt out of all marketing communications or identify which specific types of marketing communications you no longer wish to receive (email, postal mail, telephone calls or text messages). You will continue to receive transaction and service-related communications.

7.  Our Use of Cookies

7.1  Our Use of Cookies and Other Tracking Technology

The Service uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “cookies”) to gather data about visitors to the Service, analyze trends and operate and improve the Service. Cookies are small pieces of data — usually text files — placed on your computer, tablet, phone or similar device when you use that device to access the Service. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own cookies on your devices.

7.2  Monitoring and Recording Communications

We may use cookies and other tracking technology to monitor and record communications made through the Service, including chat, email, phone and text messages. You consent to us monitoring and recording communications made through the Service and to us using and sharing such recordings for the purposes described in this Privacy Policy.

7.3  Do Not Track

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. The Service is not currently configured to respond to Do Not Track signals or other mechanisms that provide users the ability to exercise choice regarding the collection of personal information about a user’s online activities over time and across third-party websites or online services.

7.4  Disable or Delete Cookies from Your Browser or Device

You can decide whether or not to accept certain cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. To explore what cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu.

You can also delete all cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit the Service and some of the functionalities of the Service may not work.

8.  Data Security and Processing

8.1  Security of Personal Information

We will maintain reasonable technical and organizational safeguards for the protection of the security and confidentiality of personal information from unauthorized access, use, disclosure or transfer. Despite our efforts to ensure security, we cannot guarantee or warrant that personal information will not be accessed, acquired, disclosed for an improper purpose, altered or destroyed by an unauthorized person or as a result of a breach of our security safeguards or those of our hosting provider or other vendors or service providers. We cannot ensure the security of any data transmitted to us over the internet. While we strive to protect personal information, no security measures are completely infallible, and we cannot guarantee absolute security. To the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure by us of personal information. Therefore, we urge you to take adequate precautions to protect personal information as well, including, without limitation, never sharing your account username or password.

8.2  International Transfer, Storage and Processing

We operate from the United States and the personal information we collect or receive is stored and processed in the United States and may be processed in other countries around the world subject to the provisions of this Privacy Policy.

If you are located in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, please note that we may transfer data, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and may afford materially less privacy protections for your personal information than your jurisdiction. You consent to the transfer of personal information to the United States or any other country in which we, our affiliates or vendors maintain facilities. You consent to the use and sharing of information about you as described in this Privacy Policy.

9.  Automated License Plate Recognition

This Section is GenLogs’ usage and privacy policy for automated license plate recognition (“ALPR”) systems and the information collected through them. It is published to meet requirements applicable to operators and users of ALPR systems under the laws of certain states, including California Civil Code sections 1798.90.51 and 1798.90.53.

In this Section, “ALPR information” means information collected through our automated license plate recognition capability, including license plate characters, associated images, and the date, time and location of collection.

This Section applies to ALPR information whether or not that information is personal information as described in Section 1.1. The exclusions and limitations in Section 1.1 do not narrow this Section.

9.1  Authorized Purposes

We operate our ALPR capability, and collect and use ALPR information, only for the following purposes:

  • Identifying commercial motor vehicles, trailers, containers and other equipment, and associating them with the motor carriers that operate them

  • Generating network, lane, corridor and other analytics regarding commercial vehicle movement

  • Supporting the detection, investigation and prevention of cargo theft, fraud, and unlawful or unsafe commercial vehicle operation

  • Supporting lawful public safety and commercial vehicle enforcement activity by government customers, subject to the restrictions in their agreements with us and in our acceptable use terms

  • Operating, securing, maintaining, testing and improving the Service, the sensor network, and our models

  • Meeting legal, regulatory and compliance obligations, and responding to legal process

9.2  Authorization to Access ALPR Information

Access to the ALPR system and to ALPR information is limited to employees, affiliates, and independent contractors whose role requires it, including engineering and technical operations personnel who build, operate and maintain the system, and personnel who support customer use of the Service.

Individuals authorized to access ALPR information must complete GenLogs’ ALPR data handling briefing and acknowledge this Section, and must complete that briefing at least annually. The briefing covers authorized and unauthorized use of ALPR information and the other legal and policy restrictions that apply to ALPR access.

Customers and their users access ALPR information through the Service under their own agreements with us. They are separately responsible for their own obligations under applicable law, which may include maintaining a usage and privacy policy of their own.

9.3  Monitoring and Review

Access to the ALPR system is controlled on a role basis, and access to ALPR information is recorded as described in Section 9.5. The information security measures described in Section 8.1 apply to the ALPR system.

The custodian identified in Section 9.9 reviews a sample of access records at least annually to check that access was made by authorized personnel and is consistent with this Section. The custodian is supported in that review by an internal cross-functional body that provides oversight of the matters described in this Section 9.3 and in Section 9.8.

9.4  Security

We maintain reasonable security procedures and practices, including operational, administrative, technical and physical safeguards, designed to protect ALPR information from unauthorized access, destruction, use, modification or disclosure. Section 8.1 describes our security practices generally and applies to ALPR information.

9.5  Records of Access

When ALPR information is accessed, or when we provide access to it, we maintain a record of that access, including the date and time of the access, the license plate number or other data elements used to query the system, and the username of the person accessing the information together with the organization or entity with which that person is affiliated. We retain these records as required by applicable law and for security, audit and compliance purposes.

ALPR information may be accessed and used only for the authorized purposes described in Section 9.1, and each person accessing it is required to record the purpose for the access where the Service provides for it.

9.6  Sale, Sharing and Transfer

We make ALPR information available to the following categories of recipients:

  • Customers, under written agreements that restrict their use of the information to the purposes described in Section 9.1

  • Service providers acting on our instructions and under written contract, to host, secure, operate and support the Service

  • Government agencies, under written agreements and subject to acceptable use terms, or in response to valid legal process

  • Parties to a business change of the kind described in Section 1.3

We do not make ALPR information available to the general public. Before ALPR information is provided to any recipient, we require a written agreement restricting its use to the purposes permitted by this Section and by applicable law.

Recipients who access ALPR information through the Service do so under binding terms that limit how they may use it. Commercial subscribers are subject to the acceptable use and data use restrictions in the GenLogs Terms of Service and their applicable subscription agreement. Government, law enforcement and regulatory agencies access the Service only under a separate written agreement with GenLogs, which includes acceptable use terms.

We do not provide ALPR information to any recipient where we have reason to believe it will be used for civil immigration enforcement; to investigate or prosecute a person in connection with seeking, providing or receiving health care; or to identify or impose civil or criminal liability on a person based solely on that person’s participation in constitutionally protected activity.

9.7  Retention and Destruction

We retain ALPR information relating to commercial motor vehicles for as long as it serves the purposes described in Section 9.1. Because the Service is designed to generate cumulative insight over time, that information is generally retained for the life of the Service rather than on a fixed schedule.

ALPR information that does not relate to a commercial motor vehicle is not retained. Where such information is inadvertently collected, our systems obscure or remove it on identification, as described in Section 1.2.

We review retained ALPR information periodically against the purposes described in Section 9.1, and obscure or remove ALPR information that is no longer needed for those purposes.

Section 1.6 describes our general approach to retention. To the extent Section 1.6 and this Section 9.7 differ with respect to ALPR information, this Section 9.7 controls.

9.8  Accuracy and Correction of Errors

We use reasonable measures to ensure the accuracy of ALPR information and to correct data errors. These include automated quality controls applied when images are converted into computer-readable data, and correction or removal of ALPR information that we determine to be inaccurate. Errors may be identified through those controls or reported to us by customers. The internal cross-functional body described in Section 9.3 provides oversight of this correction process.

9.9  Custodian

The official custodian of the GenLogs ALPR system and of ALPR information, responsible for implementing this Section, is the Chief Executive Officer, acting on behalf of GenLogs Corporation as owner of the system. The custodian may be contacted at support@genlogs.io.

9.10  State-Specific Provisions

Some states impose additional or different requirements on the collection, use, retention, sharing or destruction of ALPR information. Where the law of a state imposes a requirement that differs from this Section, we apply that state’s requirement to ALPR information within its scope.

10.  Changes and Amendments to Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we do, we will post the revised policy on the Service with a new “Last Updated” date. Your continued use of the Service, or your provision of personal information to us following the posting of changes constitutes your acceptance of such changes. We encourage you to visit this page regularly for any changes.

11.  Contact Us

You may contact us with questions, concerns, complaints, or disputes related to this Privacy Policy and our privacy policies and practices.

Company:  GenLogs Corporation

Address:  1045 N. Utah Street, Suite 105, Arlington, VA 22201

Email:  support@genlogs.io