Latitude AI Privacy Notice

Effective Date: April 18^th, 2023

This Privacy Notice (“Notice”) describes the types of information about you that Latitude AI LLC, our parent company Ford Motor Company, and our affiliates or subsidiaries (“Latitude AI,” “we,” “us,” “our”) collects, uses, and discloses when you visit our website or any other online location where this Notice is made available to you and through our on-road test vehicles (collectively, the “Services”). This Notice also informs you of your rights and choices with respect to the personal information we collect about you.

Our Services may contain links to other, third-party websites that we do not operate. If you click on a third-party link and visit another website we do not operate, we encourage you to review the privacy policy of the other website.

By using the Services, you agree to our Terms of Use. This Notice, and the data practices described in this Notice are incorporated into our Terms of Use. If you do not agree with the practices described herein, discontinue use of the Services. Any changes to this Notice will become effective upon posting of the revised Notice on our Services.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section below. For state-specific disclosures, please see the additional disclosures at the end of this Notice. Additionally, please note that the U.S. State Notices at Collection, Rights, and Choices also serves as our Notice at Collection for California residents for purposes of the California Consumer Privacy Act (CCPA).

This Notice has been designed to be reasonably accessible to people with disabilities. If you experience any difficulties accessing the information in this Notice, please contact us at info@lat.ai.

We collect two types of information: Personal Information and Other Information.

Personal Information is information:

• relating to, describing, capable of being associated with, or reasonably linkable (directly or indirectly) with you;
• that identifies or can be used to identify you;
• that can be used to authenticate you or provide access to an account through our Services; or
• that relates to you and that might be sensitive.

Personal Information includes Sensitive Personal Information (as that is defined by applicable state laws). We may collect and use Personal Information for typical business management, operational and commercial purposes (including to defend and protect us and others from harm or legal claims, and as required by applicable law), and as described more specifically below.

In connection with the Services, we collect the following categories of information:

• Identifiers. We receive personal identifiers (such as your name, email address, and telephone number) when you fill out a form or contact us through the Services.
• Communications. We receive information you provide to us through your communications with us by email, posts to social media pages, or another methods.
• Service usage data and device connectivity and configuration data, including identifiers and electronic activity information via cookies. We collect information about your computer or mobile device and your visits to the Services, including identifiers (such as the relevant IP address(es)), information about your device (such as estimated geographical location and browser type), and internet or other electronic activity information (such as interactions with the Services including, browsing history, search history, website usage information).
• Inferences. We draw inferences from Identifiers and Service usage data and device connectivity and configuration data. This information may be used for the purposes described as to such categories.
• In connection with the operation of our on-road test vehicles (“Vehicles”), we may, for our research purposes, and as otherwise described in this privacy policy, collect:
  • Vehicle Telemetry Data. Vehicles are equipped with cameras and sensors to detect and record its surroundings through electromagnetic, optical, and acoustic waves (e.g. radar, video, LIDAR, GPS, and microphones). The data includes the vehicle origin and destination, speed, direction, miles driven, and route information. This information is not used to identify any individuals.
  • Video Camera and Audio Data. Vehicles are equipped with video cameras and microphones to record their surroundings. Any image, audio recording, or other indication of a person (or a pet, house, mailbox, stop sign, etc.) is not used to identify any individuals.
  • Geolocation data. The above information is accompanied by geolocation data. This information is not used to identify any individuals.

Please note that we do not apply any facial recognition or other personally identifying technology to the images and other data collected by the Vehicles.

We collect the above categories of information from the following categories of sources:

• You. We collect the information you provide to us, such as when you contact us or apply for a job with us.
• Cookies and Similar Technologies. We may use online tracking technologies, such as cookies, web beacons and/or embedded scripts, to help us remember devices associated with users of our website, analyze the parts of our website that users visit, the length of time spent at any particular page, the general geographic location of the IP address and the specific functionalities that users choose to use. Essentially, cookies are a user”s identification card for our servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our website. An embedded script is programming code that is designed to collect information about your interactions with us. All of these help us remember and respond to what you do on our website.
• Our parent company, affiliates, and subsidiaries
• Social Networks, when you engage with our content, reference our Services, or grant us permission to access information from social networks.
• Partners, that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
• Publicly-available sources, including data in the public domain.
• Vehicles, which collect Vehicle Telemetry Data, Video Camera and Audio Data, and Geolocation Data.

We use the information we collect for business and commercial purposes in accordance with the practices described in this Notice. Our business and commercial purposes for using information include:

• Operating and managing our Services;
• Performing services requested by you, such as processing your applications and responding to your comments, questions, and requests;
• Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
• Preventing and addressing breaches of our policies or terms, and threats or harm;
• Monitoring and analyzing trends, usage, and activities;
• Improving the Services and other Latitude AI websites, apps, marketing efforts, products and services;
• Processing Vehicle Telemetry Data, Video Camera and Audio Data, and Geolocation Data to train and improve the ability of our Vehicles to safely drive autonomously, for research and operation of the Automated Driving System (“ADS”) to identify and classify static and dynamic objects and respond appropriately, and to improve software so that the ADS can identify and classify static and dynamic objects and respond appropriately. This information is not used to identify any individuals;
• Enforcing our rights and agreements;
• Processing as necessary to identify, contact, or bring legal action regarding the rights and property of ours or our parent company, affiliates, and subsidiaries;
• Complying with laws, regulations, court orders and subpoenas or similar requests for information by authorities;
• Maintaining the security of our premises and protecting your safety and the safety of our customers, guests, contractors, employees, and others;
• Performing audits;
• Conducting research and compiling analytics, including to identify usage trends, and to improve and update our products and services;
• Assisting us in fraud prevention or investigation;
• Fulfilling any other purpose at your direction; and
• With notice to you and your consent.

We disclose information we collect with other entities in accordance with the practices described in this Notice. The categories of Personal Information referenced in this section can be found in the Notice at Collection below. The categories of entities to whom we disclose information, including in the last 12 months, are as follows:

• Within our corporate family of parents, subsidiaries, affiliates, and joint ventures we disclose all we disclose all categories of Personal Information in order to efficiently carry out our Services and to the extent permitted by applicable law.
• To service providers and contractors (such as IT service vendors, website hosting facilities, email distribution services, and security vendors) we disclose all categories of Personal Information in order to support our Services. We contractually prohibit our service providers and contractors from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
• To Government Authorities and for Legal Rights and Actionswe disclose all categories of Personal Information in response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share all categories of Personal Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Latitude AI, the Services, our employees, or others; and in connection with our Terms of Use and other agreements. We may also use Device, Internet and Network Activity Information, Online Identifiers (IP Address, cookie IDs and Device ID) to identify users, and may do so in cooperation with copyright owners, Internet Service Providers, wireless service providers or law enforcement agencies in our discretion. Such disclosures may be carried out without notice to you.
• To Acquirerswe may disclose all categories of Personal Information to an acquirer, assignee or other successor entity in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business
• To facilitating requests, we disclose all of the categories of Personal Information at your request or direction.
• With your consent, we disclose all of the categories of Personal Information.

The Services are intended for a general audience and not directed at children. We do not knowingly collect Personal Information (as defined by the U.S. Children”s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected Personal Information in violation of COPPA, contact us at info@lat.ai. We will remove the Personal Information in accordance with COPPA.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, misuse, unauthorized access, disclosure, alteration, destruction, or modification. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you collected through the Services.

The Services are hosted in the United States. By using our Services, you understand that your information will be transferred to our data center and servers in the United States and potentially to other parties with whom we may share information as described in this Notice. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country of residence. If you are outside the United States and do not agree to the transfer of information about you to the United States, you should not use the Services.

These additional disclosures apply only to individuals with rights under U.S. State Privacy Laws. For purposes of this section, the terms “consumer”, “Personal Information”, “categories of Personal Information”, “cross-context behavioral advertising”, “targeted advertising”, “business purpose”, “third party”, “sell”, and “share” have the meanings ascribed to them respectively in the U.S. State Privacy Law.

In the past 12 months, we have collected the following categories of Personal Information:

• Personal Identifiers such as your name, postal address, telephone number, title, and email address.
• Device, Internet and Network Activity Information, Online Identifiers (IP Address, cookie IDs and Device ID), including usage data of the Services (e.g., which pages of our Services were visited, the order in which they were visited, which hyperlinks were “clicked,” the date and time the app on your device accesses our servers, the URLs from which you linked to our Services, and what information and files have been downloaded to or presented through the app), information collected through cookies, web beacons and other technologies, aggregated information about your visits to, or use of, our Services, as well as across other sites, and various attributes associated with your device (e.g., IP address, Mac address, data and time of connection and disconnection, Internet Service Provider, installed fonts, language and browser settings, and time zone in order to create a device fingerprint or identifier so that we can recognize your device). While that information alone may not reveal your specific individual identity, we may associate this usage and Other Information we collect with Personal Information about you.
• Audio and Visual Information, including when you are in our office and video footage/photographs of you are collected by CCTV cameras, video and/or audio security footage, or as requested of you by Latitude AI security personnel.
• General Location Information
, as inferred by zip code and IP address
• In connection with the operation of our Vehicles:
  • Vehicle Telemetry Data. Vehicles are equipped with cameras and sensors to detect and record its surroundings through electromagnetic, optical, and acoustic waves (e.g. radar, video, LIDAR, GPS, and microphones). The data includes the vehicle origin and destination, speed, direction, miles driven, and route information. This information is not used to identify any individuals.
  • Audio and Visual Information. Vehicles are equipped with video cameras and microphones to record their surroundings. Any image, audio recording, or other indication of a person (or a pet, house, mailbox, stop sign, etc.) is not used to identify any individuals.
  • Precise Geolocation data. The above information is accompanied by precise geolocation data (such as latitude/longitude). This information is not used to identify any individuals.

Aggregate or De-identified Information. We collect, use, and disclose information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. We will maintain and use de-identified information in de-identified form and will not attempt to re-identify the information, except to make sure the information is truly de-identified.

For more information on information we collect, including the sources we receive information from, review the Collection of Information section. We collect and use these categories of Personal Information for the business and commercial purposes described in the Use of Information section, including to provide and manage our Services.

Latitude AI does not sell, or share for cross-context behavioral advertising, Personal Information about you. We use and partner with different types of entities to assist with our daily operations and manage our Services. Please review the Disclosure of Informationsection for more detail about the parties we have disclosed Personal Information to.

We retain Personal Information for as long as is needed to carry out the purposes we've described, or as otherwise required by law. The criteria used to determine the applicable retention period for Personal Information includes the length of time we have an ongoing relationship with the consumer and whether there is a legal obligation to which we are subject that requires us to retain the Personal Information. Where we have no continuing purpose to process the Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because the Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from any further processing until deletion is possible.

To the extent provided under applicable laws, you have the right to know certain information about our data practices. In particular, you may have the right to request the following from us up to two times every 12 months:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information was collected;
• The categories of Personal Information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the Personal Information was disclosed; and
• The business or commercial purposes for collecting, selling, or sharing the Personal Information.

You may also have the right to request the specific pieces of Personal Information we have collected about you.

In addition, you may have the right to correct and delete the Personal Information we have collected about you, subject to certain exceptions allowed under applicable law.

To exercise any of these rights, please submit a request through our online form available here or email us at info@lat.ai. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request. Please note that we do not apply any facial recognition or other personally identifying technology to the images and other data collected by the Vehicles, and thus, we cannot provide, delete, or correct any such information in response to a consumer request.

We do not collect or process sensitive Personal Information with the purpose of inferring characteristics about a consumer.

Under certain applicable laws, you can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent's permission to do so and verify your identity directly.

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

You may have a right to appeal decisions concerning your ability to exercise your consumer rights. Please e-mail us at info@lat.ai to request an appeal concerning decisions on your consumer request.

We do not offer financial incentives (as described under U.S. State Privacy Laws) as part of our Services.

We do not knowingly collect information of minors under 16.

Customers who are residents of California may request (i) a list of the categories of Personal Information disclosed by us to third parties during the immediately preceding calendar year for those third parties” own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in the “Contact Us” section below and specify that you are making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of Personal Information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of Personal Information for monetary consideration by the business to a third party for the third party to license or sell the Personal Information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at info@lat.ai.

We reserve the right to update or change our Notice at any time and you should check this Notice periodically. Your continued use of the Services after we post any modifications to the Notice on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Notice then posted. If we make any material changes to this Notice, we will notify you either through the email address you have provided us, or by placing a prominent notice on the Services.

If you have any questions or concerns regarding this Notice, please feel free to contact us at the following email, telephone number, or mailing address:

Email: info@lat.ai
Telephone Number: (412) 525-3483
Address: 2545 Railroad St., Suite 400, Pittsburgh, PA 15222