AngelDrive Privacy Policy

Version 2026-08-23

This Privacy Policy (the "Policy") describes how Angel Labs, Inc. ("AngelDrive," "we," "us," "our"), collects, uses, discloses, and protects personal information in connection with the AngelDrive mobile application (the "App"), the website at angeldrive.com and its subdomains (the "Site"), and the related services we provide (together with the App and Site, the "Services").

AngelDrive is a driver-safety and legal-protection service. Access may be sponsored by the law firm associated with your activation code or account (the "Sponsoring Firm"), or you may sign up directly with no law firm involved (a "Direct User"). No law firm sponsors a Direct User’s account, receives any information about a Direct User, or contacts a Direct User. The Sponsoring Firm is not necessarily your lawyer, and sponsorship does not mean that it represents you. This Policy explains, among other things, the strict limits on what the Sponsoring Firm can see.

Neither this Policy nor your use of AngelDrive creates an attorney-client relationship between you and Angel Labs or, by itself, between you and the Sponsoring Firm. If the Sponsoring Firm represents you, that relationship is governed by a separate agreement. This Policy does not modify or waive any attorney-client privilege or work-product protection that otherwise applies.

Quick summary

This summary is for convenience only and does not replace the full Policy.

1. Scope of this Policy

This Policy applies to:

• the AngelDrive App and your use of it as a driver or as a member of someone's Halo;
• the angeldrive.com website and its subdomains, including marketing pages and any web pages we operate for account activation or support;
• the Sponsoring Firm dashboard we operate for law firms, with respect to the personal information about drivers that appears in it.

This Policy does not apply to:

• the Sponsoring Firm’s own handling of your information, which is governed by its privacy practices, applicable professional-responsibility rules, and any representation agreement you have with it;
• ClaimAngel products and services, which are operated separately and governed by the ClaimAngel Privacy Policy at claimangel.com/privacy;
• third-party websites, apps, or services we link to.

2. Personal information we collect

2.1 Information you give us

Account information. Your month and year of birth, mobile phone number (which is how you sign in), first and last name, and email address (which must be verified before your account is complete). We use month and year of birth to determine your age band and the protections that apply. We do not ask for or store your Social Security number or driver's license number.

Activation information. The activation code or Halo invite code you enter, and the law firm associated with it. An account is associated with at most one Sponsoring Firm. If you sign up directly and do not belong to any Halo whose Halo Organizer has a Sponsoring Firm, you are a Direct User and your account is associated with no firm. If you join through a Halo invitation and the Halo Organizer has a Sponsoring Firm, that firm becomes your Sponsoring Firm. For a user aged 13 through 17, we also process the guardian authorization record described in Section 11.

Halo information. When you create a Halo and invite someone, we process the invite code you generate. The invitation message itself is composed and sent from your own device using your phone's share sheet. We do not send it, and we do not receive or store the recipient's phone number from that action.

Saved Places and occupancy. If you create a Saved Place, we store the address or label you enter, exact coordinates, the geographic radius, whether the Place is associated with a home, and its visibility setting. The current editor makes a new Place visible to the Halo by default. We may also store recent occupancy samples indicating whether a member was detected inside a Saved Place. Saved Places can include sensitive locations such as a home, workplace, or school.

Crash documentation. Photographs, video and audio recordings, and any notes you choose to capture through the guided documentation flow after a crash, together with the time and location of capture and a cryptographic hash used to establish chain of custody. The App uses your camera and microphone only with your affirmative consent: when a possible crash is detected, the App asks whether you want to record video of the scene, take photographs, and complete a report. What you capture is stored on your device, and nothing is uploaded to our systems unless you separately and affirmatively agree to submit it. AngelDrive never records audio, video, or images automatically or in the background. You own what you capture. We receive only the limited rights described in the Terms and this Policy: to include submitted items in a crash evidence package, to use them as described in Section 3, and to provide the Services. Submitted items that are not included in an evidence package are deleted after a limited period.

Messages to the Sponsoring Firm. The content of any message you send to the Sponsoring Firm through the App.

Support and correspondence. Information you provide when you contact us.

2.2 Information we collect automatically from the App

Location and movement information. With your permission, we collect your device's precise geolocation, including latitude, longitude, accuracy, and timestamp. We also collect speed, heading, and motion state.

Please read this carefully, because it is the most important disclosure in this Policy:

AngelDrive collects location in the background, including when the App is closed and when your phone is locked. This is not incidental. The service cannot work otherwise. If your Halo is to see where you are, and if a crash is to be detected while you are driving, the App must be permitted to access your location "Always." If you grant only "While Using the App," AngelDrive will collect your location only while the App is open on screen, your Halo will see you go stale, and crash detection will not function reliably.

For general Halo location sharing, AngelDrive ordinarily records a location when your device has meaningfully moved or when a period of time has elapsed while you are stationary. When the App's real-time trip-location feature determines that you are on the move, however, the App may continuously gather GPS telemetry. This may include latitude, longitude, speed, heading, timestamp, and accuracy. This information is available to the App for the duration of the trip. This can create a detailed route of your movement even though AngelDrive does not collect one uninterrupted location stream at all times. Alongside location readings, we collect your device's current battery percentage, so the people in your Halo can distinguish a low battery from another reporting problem.

We convert coordinates into a human-readable place label (for example, "Bering Drive") using our own geocoding server running inside our private cloud environment. Your coordinates are not sent to Google, Apple, or any other outside mapping company for this purpose. Place labels derived from OpenStreetMap data are © OpenStreetMap contributors.

Driving and motion information. When the App determines that you are in a vehicle, it records the trip and analyzes how the vehicle was driven. Specifically, we collect:

• the route driven, as a series of location points with speed;
• speed relative to the posted speed limit, where speed-limit data is available;
• harsh events, including hard braking, rapid acceleration, and sharp cornering;
• phone handling while the vehicle is moving, and whether calls were taken while moving (and whether handheld or hands-free);
• the transport mode detected (for example, car or motorcycle);
• crash events, including estimated change in velocity, speed at impact, peak G-force, detection confidence, the location fixes preceding the event, and location accuracy at the time.

From these we derive a trip score and three equally weighted component scores: Speed, Smooth, and Focus.

This information is collected whenever you are moving in a vehicle, whether or not you are the driver. The App attempts to determine automatically whether you were the driver or a passenger, and trips it identifies as passenger trips are excluded from your overall score. You can also tell the App you were a passenger. Detection is not perfect, some component sub-scores may still reflect trips you did not drive, and a trip taken in a rideshare, taxi, bus, or train may be recorded before it is correctly classified.

When you use drive detection or crash detection in a vehicle, you confirm that you are the driver or that the driver knows your device is collecting location, motion, and driving-behavior information and has given any permission required by law. If you do not have the driver’s permission, use the available App or device-permission controls to disable drive detection and crash detection before the trip when it is safe to do so.

Device and technical information. Device model, manufacturer, operating system and version, App version and build, language, time zone, a device push-notification token, and pseudonymous identifiers we or our processors assign to your installation. We do not collect the Apple advertising identifier (IDFA) or any equivalent cross-app advertising identifier, and we do not ask for App Tracking Transparency permission.

Information processed through our licensing partners. Some information processed through the app may be processed using technology we license from partners who develop tools used by AngelDrive to determine location and movement (GPS position, speed, heading, and motion-sensor readings); device status (device, operating-system, Wi-Fi, and battery information and diagnostic metadata); pseudonymous identifiers; and derived trip, transport-mode, driver/passenger, driving-event, score, and possible-crash information. Some processing occurs on your device. Selected location, sensor, device, trip, and crash-related information may also be transmitted to these licensing partners but is anonymized.

If crash-validation feedback is enabled, it may include a pseudonym user ID or linkable pseudonymous identifier, vehicle type, crash date and time, whether the detection was a true or false positive, and estimated severity. AngelDrive treats a linkable identifier and event timestamp as pseudonymous personal information.

Diagnostic information. When the App encounters an error, we collect an error report containing the technical stack trace, the App version, and your AngelDrive user identifier. Location coordinates and personal identifiers are stripped from these reports before they leave your device, and diagnostics from the crash, evidence, guidance, and messaging parts of the App are excluded from error reporting entirely.

Product analytics. When product analytics are enabled, our analytics provider collects allowlisted events describing how the App is used, such as screens opened, features used, and flows completed. The provider identifies an App user through an opaque AngelDrive identifier and may receive the user's Sponsoring Firm identifier. AngelDrive does not attach the user's name, email address, or phone number to the analytics profile.

2.3 Information we collect automatically from the Site

When you visit angeldrive.com, the Site and its hosting infrastructure may receive your IP address, browser type, referring page, pages viewed, and similar request information. See Section 14 for information about cookies and analytics.

If you join the consumer waitlist or submit a firm-interest form, we collect the fields you provide. These may include your email address, name, phone number, message, state, role, and case-volume information. Those submissions are stored in administrative systems operated for us by a service provider.

2.4 Information others give us about you

If someone invites you to their Halo, we learn that they invited you once you redeem the code. Your account is then associated with the Halo Organizer’s Sponsoring Firm, if the Halo Organizer has one. That firm may receive the account, crash, evidence, and message information described in Section 5 even if you were not previously its client. If the Sponsoring Firm enrolls you directly, we receive your name, phone number, and email from the Sponsoring Firm in order to create your invitation.

2.5 What we do not collect

We want to be equally clear about what AngelDrive does not do:

• We do not collect your full date of birth. We collect only your month and year of birth to determine your age band.
• We do not record audio or video, and we do not access your camera or microphone, except within the crash-documentation flow described in Section 2.1 and only with your affirmative consent. We never record automatically or in the background.
• We do not read your text messages, call logs, contacts, or browsing history. When you call or text someone in your Halo, the App hands off to your phone's own Phone and Messages apps; the conversation never touches our systems.
• We do not collect the contents of group messages among Halo members. Halo group chat is your phone's native group message thread. We custody zero message content.
• We do not use advertising identifiers, and we do not build profiles about identifiable users for targeted advertising.

3. How we use personal information

We use personal information to:

1. Create and secure your account: determine your age band, send you a one-time sign-in code by text message or email, verify your email, and associate you with the Sponsoring Firm linked to your activation code or, for a family invitee, the Halo Organizer.
2. Show your location to the people you have chosen to include in your Halo, and show you theirs.
3. Detect a possible crash and support your response: alert you, prompt you to check in, guide you through documenting the scene, and, if your account has a Sponsoring Firm, make a pending crash record available in the Sponsoring Firm portal and email that firm when you confirm the event by tapping I'm safe.
4. Give you your driving insights: trip history, routes, and the Speed / Smooth / Focus scores.
5. Tell you when protection has stopped working: for example, if a permission has been revoked or your device has stopped reporting, so you can fix it.
6. Deliver messages you send to the Sponsoring Firm.
7. Keep the Services working: diagnose crashes and errors, measure feature usage, prevent abuse and fraud, and enforce our Terms.
8. Improve product-specific safety technology: use selected location, sensor, trip, driving-event, driver/passenger, and possible-crash data to test, validate, train, and improve the driving and crash-detection algorithms and machine-learning models used for the Services; ensure data quality and system reliability; and develop related safety features.
9. Communicate with you about your account, service changes, and support requests.
10. Comply with law, respond to lawful requests, and establish or defend legal claims.

We rely on your consent for the collection of precise location and driving data. You may withdraw that consent at any time as described in Section 10; withdrawing it will disable the core protective functions of the Services.

Before relevant location and sensor processing begins, the App presents a clear, just-in-time notice describing that processing and the product-specific model-improvement purpose. Acceptance of this Policy alone is not treated as consent to an optional use that applicable law requires us to present separately.

We do not use your location, your drives, or your driving scores to make decisions about legal-funding eligibility, insurance pricing, or credit, and we do not provide them to anyone who does.

We do not use crash photographs, crash video or audio recordings, crash notes, messages to the Sponsoring Firm, Halo content, or your name, phone number, or email address to train a general-purpose artificial-intelligence model without your consent. We may share aggregated or anonymized information with our licensing partners so that they may test, validate, train, and improve the technology they license to us, and for statistical research, benchmarking, publication, and internal business and marketing purposes. Sections 7 through 10 describe the applicable disclosure, retention, and controls.

4. How we disclose personal information

We disclose personal information only as described below.

To people you choose. Members of a Halo you belong to, as described in Section 6.

To the Sponsoring Firm. Only as described in Section 5, and never for a Direct User.

To service providers who process data on our behalf. See Section 7. These providers generally act on documented instructions under written agreements. We may also share aggregated or anonymized information with our licensing partners as described in Sections 3, 7, and 8. We do not authorize a provider to use identifiable or pseudonymous AngelDrive information for its own advertising.

In a business transfer. If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of that transaction. We will require the recipient to honor this Policy or give you notice and a choice before your information becomes subject to a materially different policy.

For legal reasons. We may disclose personal information when we believe in good faith that disclosure is required by law, subpoena, court order, or other legal process, or is reasonably necessary to protect the rights, property, or safety of AngelDrive, our users, or the public. This may include responding to an emergency involving a risk of death or serious injury.

With your direction. Where you ask us to.

Sales, sharing, and targeted advertising

AngelDrive does not, and will not, sell your personal information or monetize it with third parties. We do not show ads, disclose identifiable or pseudonymous personal information to data brokers, or intentionally sell or share personal information for cross-context behavioral advertising or targeted advertising. This restriction includes precise geolocation. We may use aggregated or anonymized information with our licensing/processing partners for product-specific model improvement and for statistical research, benchmarking, publication, and internal business and marketing purposes.

5. What the Sponsoring Firm can and cannot see

The Sponsoring Firm sponsors your access to AngelDrive. It is not necessarily your lawyer, and sponsorship does not mean that it represents you. If you join through a Halo invitation, your Sponsoring Firm is the Halo Organizer's Sponsoring Firm. Sponsorship does not give the firm access to your movements unrelated to a possible crash.

If you are a Direct User, this section does not apply to you. Your account has no Sponsoring Firm, and we do not make any information about you, including crash information, available to any law firm. A Direct User becomes subject to this section only by joining a Halo whose Halo Organizer has a Sponsoring Firm, after the affirmative acknowledgment and consent described in Section 6.

The Sponsoring Firm cannot see:

• Your current or past location unrelated to a crash. There is no view, report, or export that shows the Sponsoring Firm where a driver is or has been, other than the location of a crash included in an evidence package.
• Your drives or trip history.
• Your driving scores: not your overall score, not Speed, Smooth, or Focus, and not individual harsh-braking or phone-handling events.
• Your Halo membership or relationships: the firm does not receive a Halo roster or learn which other accounts are connected to you. A family invitee nevertheless appears to the same firm as a separately sponsored AngelDrive account because that account inherits the Halo Organizer's Sponsoring Firm.
• The content of your messages with Halo members, which never reaches our systems at all.
• The detail of how you use the App: which screens you open and which features you use.

The Sponsoring Firm can see:

• Your contact information: name, mobile number, and email, so it can reach you.
• Your enrollment and activity status: whether you have been invited, signed up, and completed setup, and the date you were last active in the App, so the Sponsoring Firm can confirm that your account is active. This is a status and a date; it contains nothing about where you were or what you did.
• A pending crash record, which may be visible in the Sponsoring Firm portal immediately after detection and before you respond to or dismiss the notification. It may contain the severity, the general region and the first three digits of the ZIP code, the date, the number of photographs captured, and your contact information. It does not contain your exact location or the photographs.
• A confirmed crash email, when you tap I'm safe and delivery succeeds. Dismissing the event as Not a crash filters it from firm queries and does not trigger that email. A countdown expiration or a choice to call 911 currently leaves the event pending and portal-visible but does not itself trigger the email.
• The full crash record, if the Sponsoring Firm elects to obtain the evidence package. That record contains the exact crash coordinates and a map, the on-device crash telemetry described in Section 2.2, the photographs and video and audio recordings you captured and submitted, with their timestamps and chain-of-custody records, and the guided documentation session. Access by Sponsoring Firm staff is recorded in an audit log. Once the Sponsoring Firm receives an evidence package, the firm’s own privacy practices and professional obligations govern its handling; the firm does not acquire ownership of your photographs or recordings.
• Messages you send to it through the App, delivered to the Sponsoring Firm's designated personnel.

If you dismiss a detected crash as a false alarm, it is filtered from Sponsoring Firm list and detail queries. The dismissal does not trigger an email to the Sponsoring Firm.

6. Your Halo: what the people you choose can see

A "Halo" is a group of people you invite so that you can see each other. A Halo holds up to 15 members, and you may belong to up to 5 Halos. The adult who owns and manages the Halo is the Halo Organizer.

What other members of a Halo see about you: your live location on a map, the place label and how long you have been there, your current battery percentage, whether your device is reporting normally, your name, and your mobile phone number.

What they do not see by default: your drives and driving scores are private. Trip sharing is off for every member unless it is turned on. The Halo Organizer may change another member’s trip-sharing setting. You may turn your own trip sharing off, but a later Halo Organizer change may turn it back on; the most recent change controls. Review the visible sharing status regularly. If trip sharing is on for you, every member of that Halo can see your drives, not only the Halo Organizer. A Halo Organizer must not enable another person’s trip sharing without that person’s informed agreement.

Invitations and firm association. Any member can generate a standard six-character invite code. A standard code expires after 14 days and may be redeemed up to 10 times. Anyone who has the App and the code can see the Halo's name, the inviter's first name, and the number of members before deciding to join. When a person joins and the Halo Organizer has a Sponsoring Firm, that firm becomes the person’s Sponsoring Firm for AngelDrive; a Direct User must first affirmatively acknowledge the identified firm and consent to the Section 5 disclosures and to contact from that firm, and the account then ceases to be a Direct User account. If the Halo Organizer has no Sponsoring Firm, joining creates no firm association. The joining screen must identify that firm and explain the firm disclosures in Section 5 before the person accepts. Treat a code like a key and share it only with people you intend to invite.

For a user aged 13 through 17, a standard invite is not sufficient. An adult Halo Organizer who has verified being at least 18 years old must create a Family Halo invitation. The Halo Organizer does not need to be the minor's parent or legal guardian. The invitation must be bound to the minor's verified phone number, single-use, and expire after 72 hours. The minor's account activates only when the invitation is redeemed and the minor's parent or legal guardian completes the guardian authorization described in Section 11.3, and the minor is then associated with the Halo Organizer’s Sponsoring Firm, if the Halo Organizer has one.

Stopping. You can stop sharing your location, leave a Halo, or delete a Halo you created, at any time from within the App. Leaving a Halo revokes the other members' access to your location immediately. The Halo Organizer can also remove any member.

Please understand the human reality of this feature. People you add to your Halo will be able to see where you are. Other members may take screenshots, tell other people, or otherwise pass on what they see, and we cannot control that. Add only people you trust. If you are in a situation where someone may be using location sharing to monitor or control you, you can leave a Halo at any time without the Halo Organizer's permission. For help, contact us at privacy@angeldrive.com.

7. Third parties that process data for us

We use the following categories of providers to operate AngelDrive.

These providers process personal information for us under written agreements and documented instructions that limit how they may use it. They currently include a cloud infrastructure and communications provider that hosts our systems and delivers email, text-message, and push notifications; the licensing partners whose technology supports background location, trip detection, driving insights, and crash detection, as described in Section 2.2; the notification services operated by your device platform; an error-reporting provider and a product-analytics provider, each configured as described in Section 2.2; a mapping provider that renders the static crash-location map viewed by the Sponsoring Firm; a weather service that receives approximate coordinates to associate weather conditions with a trip or crash; a payment processor for Sponsoring Firm payments, which does not receive driver location or driving data; and the administrative systems used to store website waitlist and firm-interest submissions. Each of these providers is required, under its agreement with us, to provide the same or equal protection of personal information as stated in this Policy.

We do not authorize any provider to use identifiable or pseudonymous AngelDrive information for its own advertising, and we do not sell personal information to anyone. We may share aggregated or anonymized information with our licensing partners so that they may test, validate, and improve the technology they license to us and use it for the other purposes described in Sections 3 and 8. Members of your Halo and the Sponsoring Firm are not our service providers: they receive information at your direction or as described in Sections 5 and 6 and handle it under their own duties and privacy practices.

How we describe a provider does not determine its legal status. The controlling agreements, instructions, technical use, and applicable law determine whether it is a processor, service provider, independent third party, or another type of recipient.

Reverse geocoding means turning coordinates into place names. It is performed on our own infrastructure inside our private cloud environment, not by a third-party geocoding service.

This description is current as of the version date above. We will update it when it changes.

8. Advertising and secondary uses

AngelDrive contains no advertising. We do not use personal information to target ads to you, disclose identifiable or pseudonymous information to advertising networks or data brokers, or participate in cross-context behavioral advertising. We and our licensing partners may use aggregated or anonymized information for product improvement, statistical models, research, benchmarking, publication, and internal business and marketing purposes. Nothing in this section authorizes advertising targeted to an identifiable AngelDrive user.

9. How long we keep personal information

We hold your data only as long as it serves the purpose you gave it to us for. The criteria that apply:

Deleting the App from your phone does not delete your account or the data described above. To delete your account, see Section 10.

10. Your choices and controls

Privacy Center. The App's Privacy Center allows you to review your current location and trip-sharing status, see the Sponsoring Firm associated with your account, if any, and the required crash-routing disclosure, see the categories of providers described in this Policy, control any optional model-improvement or aggregate-insight use, request a copy of your information, and begin account deletion. The Privacy Center also shows the Terms and Privacy Policy versions you accepted.

Location. You control location through your phone's settings, at any time. Set AngelDrive to "Never" and we stop collecting location entirely. Set it to "While Using" and we collect location only while the App is open. You can also pause sharing within the App while continuing to use other features. Turning location off will stop your Halo from seeing you and will prevent crash detection from working.

Motion and fitness / physical activity. Revoking this permission in your device settings disables driving detection and scoring.

Drive sharing. Off by default. Turn it on or off per Halo, at any time, in the App.

Notifications. Turn push notifications off in your device settings. Note that this includes crash and protection alerts.

Text messages. We send text messages to deliver your one-time sign-in codes. These are service messages, not marketing. Reply STOP to any message to opt out and HELP for help. Message and data rates may apply. Message frequency varies. Opting out of sign-in codes may prevent you from signing in. We do not send marketing or promotional text messages, and consent to receive automated messages is not a condition of purchase.

Email. Service emails (sign-in codes, verification, account notices) are necessary to use the Services. Any promotional email will include an unsubscribe link.

Withdrawing consent. You may withdraw your consent to the collection of location and driving data at any time in the App or by contacting us. On withdrawal we stop new collection, remove your identifying profile from our analytics provider, instruct applicable processors to delete or de-identify information as required, and disable protective features. Some data already collected is retained for the periods and exceptions in Section 9. Aggregated or anonymized information that can no longer reasonably be linked to you may not be capable of being retrieved or deleted as information about you.

Access, correction, deletion, and portability. You may ask us to give you a copy of your personal information, correct it, or delete it, by contacting us at privacy@angeldrive.com. We will verify your identity through the phone number or email on your account before acting. We will respond within 45 days, and may extend once by a further 45 days with notice. There is no charge unless a request is manifestly unfounded or excessive.

Note two real limits, honestly stated:

• Crash records, evidence, and messages to the Sponsoring Firm may be retained despite a deletion request, where we have a legal obligation to preserve them, where they are subject to a legal hold, or where they are needed to establish or defend legal claims. If your account is deleted while a claim is pending, tell us, and tell the Sponsoring Firm.
• Processors may require time to complete a verified deletion request. We will pass an authenticated request to our applicable processors and licensing partners and will track completion. Data that has already been robustly anonymized and can no longer reasonably be linked to you may not be retrievable as your personal information.

We will not discriminate against you for exercising any of these rights.

11. Children and teens

AngelDrive is designed for users aged 13 and older, and a Halo may include teenagers.

11.1 Age screening before minor accounts

At the beginning of onboarding, AngelDrive requires month and year of birth through a neutral age screen and uses it only to determine the protections that apply. The age screen appears before phone entry, analytics or licensed-technology initialization, push-token registration, or device-permission requests.

11.2 Under 13: not permitted

AngelDrive is not available to anyone under 13. If the birth date entered indicates the person is under 13, AngelDrive will not create an account and will not retain the information entered other than as needed to enforce this restriction.

We do not knowingly collect personal information from a child under 13. If you believe a child under 13 has provided us personal information, contact us at privacy@angeldrive.com and we will delete it and close the account.

11.3 Ages 13 to 17: parent or guardian required

A person aged 13 to 17 may use AngelDrive only after redeeming a Family Halo invitation created by an adult Halo Organizer and only with the authorization of the minor's parent or legal guardian. After phone verification, the minor's account remains restricted. AngelDrive must not begin location, motion, driving, crash-detection, Halo-sharing, analytics, push-token, or licensed-technology processing while the account is restricted. The Halo Organizer who creates the invitation must have verified, in the manner we require during onboarding, that the Halo Organizer is at least 18 years old, but does not need to be the minor's parent or legal guardian. Before the minor's account activates, the minor's parent or legal guardian must, in the manner we prescribe, accept this Policy and the Terms on the minor's behalf and attest that he or she is the minor's parent or legal guardian, that the minor's stated month and year of birth are accurate, and that he or she has authority to authorize the minor's use. The guardian authorization record may include the parent or guardian's name and contact information, the attestations given, and the date and method of acceptance. The Family Halo invitation must be bound to the minor's verified phone number, single-use, and expire after 72 hours. Neither a standard Halo invitation nor a Family Halo invitation alone activates a minor account. When the invitation is redeemed and the guardian authorization is complete, the minor joins the Family Halo and inherits the Halo Organizer’s Sponsoring Firm, if the Halo Organizer has one.

For an account we identify as belonging to a minor:

• we collect only the personal information reasonably necessary to provide the Services;
• we do not sell the minor's personal information, share it for cross-context behavioral advertising, or use it for targeted advertising or profiling. This rule applies to every user;
• we do not use crash photographs, video or audio recordings, notes, messages, Halo content, contact information, or precise location from a known minor for general-purpose model training; and
• we do not authorize optional research, publication, internal-marketing, business-intelligence, or model-development uses of a known minor’s personal information beyond what is strictly necessary to provide and secure the specific Services requested by the minor and parent or guardian.

A parent or guardian may review, correct, or request deletion of a minor's personal information, and may withdraw consent to further collection, at any time, by contacting us at privacy@angeldrive.com. On withdrawal we will delete the minor's information and close the account.

11.4 Precise location of minors

AngelDrive collects precise geolocation from users aged 13 to 17 because location sharing with the family members they have joined and crash detection are the Services being requested. AngelDrive does not sell it, disclose it for advertising, or use it to infer unrelated characteristics about a minor.

12. Additional U.S. state privacy disclosures

This section applies to residents of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, and to residents of other states as their privacy laws take effect ("State Privacy Laws").

12.1 Notice at collection

The table below uses the category definitions of the California Consumer Privacy Act, the most detailed of the State Privacy Laws. The other State Privacy Laws do not use identical categories, but they require disclosure of similar information about the categories of personal information collected, the purposes of processing, and the categories of recipients. This table is intended to satisfy those requirements as well.

The “No” entries in the final column reflect AngelDrive’s treatment of the processing described in this Policy.

Minors. AngelDrive does not intentionally sell, share for cross-context behavioral advertising, or use for targeted advertising the personal information of any consumer, including consumers under 16 and under 18.

We collect one category of sensitive personal information: precise geolocation. We use it to provide the Services you have asked for. These Services include showing your location to your Halo, detecting possible crashes, recording trips, and generating driving insights. We also use it for security, legal compliance, and the product-specific validation and improvement described in Section 3. We do not use it to infer unrelated characteristics about you.

12.2 Your rights

Subject to verification and to the exceptions in applicable law, you have the right to:

• know what personal information we have collected, the sources, the purposes, and the categories of recipients;
• access a portable copy;
• correct inaccurate personal information;
• delete your personal information;
• opt out of sales, sharing, targeted advertising, and profiling with legal or similarly significant effects. AngelDrive does not intentionally engage in these activities and honors Global Privacy Control signals on the Site.
• limit the use of sensitive personal information. We already limit it to the permitted purposes described above;
• be free from retaliation for exercising any right;
• appeal a denial of a request.

How to exercise them: email privacy@angeldrive.com with your account name and the mobile number on your account, or write to the address in Section 16. Authorized agents may submit requests with written authorization; we may require you to verify your identity directly.

Appeals: if we deny your request, you may appeal by replying to our decision within 30 days with "APPEAL" in the subject line. We will respond within 45 days with a written explanation. If your appeal is denied you may complain to your state Attorney General.

12.3 Shine the Light

California residents may request information about disclosures of personal information to third parties for those third parties' direct marketing purposes. We make no such disclosures.

12.4 Notice of financial incentive

We offer no financial incentives in exchange for personal information.

13. How we protect personal information

We maintain administrative, technical, and physical safeguards designed to protect personal information. Server-side safeguards include encryption for supported cloud databases and storage, transport encryption, managed key services, role-based access controls, separate identity systems for drivers and Sponsoring Firm staff, short-lived evidence links, access logging, evidence versioning, and a production write-protection period for evidence.

Some information is also stored on your device. Protection depends in part on the device operating system, device lock, and platform storage controls.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Keep your device locked and your phone number secure, since access to your phone number is how sign-in codes are delivered.

Protect yourself from impersonation. AngelDrive will not unexpectedly call, text, or email you to ask for your one-time sign-in code, password, Social Security number, full payment-card number, or government-issued identification number. Do not give a sign-in code to anyone. If a message claiming to be from AngelDrive asks for this information, do not respond. Contact support@angeldrive.com through a contact method published in the App or on angeldrive.com.

Use an appropriate channel for sensitive communications. Ordinary email may not provide the confidentiality appropriate for crash evidence, medical information, or a sensitive communication intended for the Sponsoring Firm. Use the App or a communication method approved by the Sponsoring Firm. Do not assume that a message sent to AngelDrive support is confidential or protected by attorney-client privilege.

14. Cookies and the Site

On angeldrive.com we may use cookies and similar technologies to operate the Site, measure aggregate performance, and remember preferences.

Website waitlist and firm-interest submissions are stored as described in Section 7.

You can control cookies through your browser settings.

15. Changes to this Policy

We may update this Policy. When we do, we will change the version and effective date at the top and post the revised Policy at angeldrive.com/privacy.

If we make a material change, particularly a change to the categories of personal information we collect, the purposes for which we use it, or the parties to whom we disclose it, we will notify you in the App or by email before the change takes effect and, where required, ask you to consent again.

Your continued use of the Services after a non-material change takes effect constitutes acceptance of the revised Policy.

Previous versions. After this Policy is revised, we will keep prior AngelDrive versions at angeldrive.com/privacy/archive. Each archived version will show its version number, effective date, date it was replaced, and a stable downloadable copy.

16. Contact us

Privacy questions, requests, and complaints: privacy@angeldrive.com

Mail: Angel Labs, Inc. Attn: Privacy Officer 5801 Congress Avenue Boca Raton, FL 33487