PRIVACY POLICY
Effective Date: September 29, 2026
1. Introduction and Scope
FiglioTech, Inc. (“FiglioTech,” “we,” “us,” or “our”) provides the WaySense mobile application, websites, products, and related services (collectively, the “Services”). This Privacy Policy explains how we collect, use, disclose, and otherwise process information when you access or use the Services.
The Services are designed to help users understand driving activity, promote safer driving habits, and access related alerts, insights, communications, and account tools. Depending on configuration and permissions, the Services use device telemetry, location data, images, video, audio, and automated analysis technologies (including Machine Learning) to support these functions.
The Services can be used in different contexts, including:
• individual users
• households and Groups (including parents, guardians, and teen drivers)
• educational or driver-training settings
• business, employer, or fleet settings
Because the Services support multiple account structures and use cases, the information collected and how it is used may vary depending on:
• the account type
• user role and permissions
• device settings
• how the Services are configured and used
The Services are not intended to be the sole basis for employment, insurance, disciplinary, or safety decisions.
Our Services can be accessed globally, but this Privacy Policy is drafted with a primary compliance focus on users in the United States and Canada.2. Definitions and User Roles
For purposes of this Privacy Policy:
“Account Holder” means the person or entity that creates and controls an account, Group, or subscription plan. Depending on context, this may be an individual user, parent or guardian, household member, business, or Organization.
“Administrator” means a user granted elevated permissions within a Group or account, which may include managing settings, permissions, invitations, visibility, and other users.
“Group” means a shared account environment that allows multiple users to participate under a common subscription or account structure.
“Group Member” means a user participating in a Group who may have permissions based on their assigned role or settings.
“Machine Learning” or “Automated Processing” means use of models, rules, or algorithms to analyze information and generate outputs such as alerts, scores, summaries, or insights.
“Organization” means a business, employer, school, fleet operator, driving school, or other entity that uses the Services or administers access to the Services for users. Organizations may administer Groups or other supported account structures.
“Personal Information” means information that identifies, relates to, describes, or can reasonably be linked to an individual.
“Teen User” means a user under the age of majority using the Services under the supervision of a parent, guardian, or other authorized Account Holder.
“Telemetry Data” means information generated by the device or sensors, such as speed, acceleration, braking patterns, movement, gyroscope, crash detection signals, and related motion data.3. Age Eligibility and Youth Use
The Services are not intended for independent use by children under the age of 14 without appropriate parent or guardian involvement.
Users under the age of majority may use the Services:
• under the supervision of a parent or guardian
• through a Group controlled by an Account Holder
• through another authorized structure permitted by the Services
Where a Teen User participates in a Group, the Account Holder and Administrator(s) have visibility into certain driving activity, alerts, location information, settings, or related account information, depending on permissions and configuration.
Some features, controls, and permissions may differ based on age, account structure, subscription level, or user role.
If we learn that Personal Information has been collected in a manner inconsistent with applicable law, we will take steps to delete or restrict such information.4. Categories of Information We Collect
We collect different categories of information depending on how the Services are used.
4.1 Information You Provide Directly
We collect information you provide when you:
• create an account
• join a Group
• subscribe to a plan
• communicate with us
• configure profile settings
• designate emergency contacts
• use in-app communication features
• information you provide through social media interactions or communications with us
This may include:
• name
• username
• email address
• phone number
• date of birth
• password or login credentials
• parent or guardian contact information
• emergency contact names and phone numbers (Users are responsible for ensuring they are authorized to provide emergency contact information and that we are authorized by your emergency contacts to use their contact information, provided it is used solely to support emergency notification and related account functionality. Emergency contacts may receive communications if designated by a user for emergency related features, which may include communications via Short Message Service (SMS) text messages. We retain emergency contact information only as long as reasonably necessary to support those purposes or comply with legal obligations. If your emergency contact does not wish to receive emergency notifications from us about you, you must remove their contact information from the Services)
• Organization or business details
• communications content you send through available messaging features
• support requests and related correspondence
• feedback or content you share with us
4.2 Information Collected Automatically
When you use the Services, we automatically collect information about your device, use of the Services, and system activity, including:
• device type and operating system
• device identifiers
• IP address
• app version
• timestamps
• crash logs
• feature usage
• session activity
• interaction logs
We also collect technical diagnostics necessary to maintain performance, security, and reliability.
4.3 Telemetry and Driving Activity Information
When the Services are enabled or active, we collect Telemetry Data from your device or connected sensors, including:
• speed
• rapid acceleration
• hard braking
• movement patterns
• trip start and stop events
• route activity
• crash or collision indicators
• related motion signals
This information is used to generate alerts, scores, summaries, emergency features, and other driving-related outputs. Telemetry-based outputs depend on third-party data sources or device capabilities and may not always be complete or accurate.
4.4 Location Information
We collect location information when location permissions are enabled and the Services are active or operating relevant features. Depending on settings and product configuration, location information is used to:
• identify trip activity
• provide route or trip history
• show last known active location
• generate alerts or driving insights
• support Group visibility features where enabled
Users may control location permissions through device settings, though disabling permissions may limit functionality. Certain location restrictions may apply differently to Administrators or Account Holders than to other Group Members.
4.5 Images, Video, and Camera Features
If camera permissions are enabled and the device is properly positioned, the Services collect images or video through device cameras, including:
• outward-facing road views
• inward-facing cabin views
• event-triggered clips or snapshots
• images or recordings associated with detected incidents or alerts
Camera features are controlled through device permissions and in-app settings. They are not enabled solely by downloading the app. Depending on device type, plan features, and settings, users may be able to separately enable or disable inward-facing and outward-facing camera features.
4.6 Audio Information
If microphone permissions are enabled and the Services are collecting images or video through device cameras, the Services may also record audio content through your device microphone along with the images or video. Optional sound alerts or spoken notifications do not require audio recording.
4.7 Cookies and Similar Technologies
Our websites and certain online services use cookies, pixels, SDKs, and similar technologies to support functionality, analytics, communications, and user preferences. Additional details are provided below in the Cookies section.5. How We Use Information
We use the information we collect for the following purposes:
5.1 Provide and Operate the Services
To provide, maintain, and improve the Services, including to:
• create and manage accounts, subscriptions, and Groups
• authenticate users and maintain account security
• enable core application functionality
• support trip detection, trip history, and session management
• provide access to camera, microphone, location, telemetry, alerts, and related features
• facilitate in-app communications among authorized users
• provide customer service and technical support and respond to feedback
5.2 Driving Insights, Alerts, and Safety Features
To analyze activity and generate driving-related features, including to:
• generate alerts, notifications, scores, and summaries
• identify driving events and patterns such as speeding, rapid acceleration, hard braking, abrupt movement, or similar activity indicators
• identify driving patterns that may suggest inattentiveness, fatigue-related behavior, seatbelt usage, or other safety-relevant driving events
• provide coaching insights or feedback intended to support safer driving habits
• capture and summarize information related to potential incidents, crashes, or collisions where detected through available device capabilities or supported features
The Services are intended as supportive tools and may not detect every event, unsafe behavior, or potential risk and may misidentify or misclassify certain events or behaviors.
5.3 Emergency and Safety Notifications
Where enabled by the user, Account Holder, Administrator, or applicable settings, we use collected information to:
• notify designated emergency contacts of a detected incident or emergency event
• provide last known trip or location details relevant to the alert
• facilitate emergency-related communications or prompts
Emergency-related functionality depends on device settings, permissions, connectivity, or third-party operating system features. Emergency-related features are not a substitute for contacting emergency services or calling 911 where appropriate.
5.4 Communications
To communicate with users, including to:
• send service announcements
• provide account, billing, or subscription notices
• send security alerts
• respond to feedback, inquiries, submissions, and support requests
• provide in-app notifications or messages among authorized Group users
• respond to social media interactions or inquiries
• where permitted by law, send updates, promotions, or marketing communications (users may opt out of certain promotional communications where required by law)
5.5 Product Improvement and Development
To improve and develop the Services, including to:
• analyze trends and usage behavior
• troubleshoot bugs and errors
• improve, refine, develop, support, and enhance model performance, analytics, object detection capabilities, safety-related insights, automated systems, and feature accuracy across the Services for the benefit of users, Groups, Organizations, and the Services generally
• develop new products, services, and tools
• test features and user experience improvements
5.6 Security, Integrity, and Compliance
To maintain trust and lawful operation of the Services, including to:
• detect fraud, abuse, misuse, or unauthorized access
• enforce our terms, policies, and rules
• maintain platform stability and security
• comply with legal obligations and lawful requests
5.7 Additional Use Contexts
Depending on how the Services are used, information is used in the following contexts:
Household / Family Use:
• sharing trip visibility, alerts, or location with authorized Group Members
• parental/guardian oversight, coaching, or monitoring of Teen Users
• household communication and coordination features
Educational / Driving Instruction / Referral or Promotional Partner Use:
• providing discounts, onboarding, referral programs, or related offers through partner driving schools or other referral or promotional partners
• supporting user-selected sharing features, where available
Business / Fleet / Organization Use:
• driver oversight and administration
• training and coaching
• operational management
• safety and compliance programs
• internal review of trip activity or driving events
• internal review, coaching, management, or disciplinary processes determined independently by the Organization
• monitoring and oversight activities determined independently by the Organization6. Machine Learning and Automated Processing
We use Machine Learning or Automated Processing to support functionality of the Services.
6.1 Inputs
Automated systems, including Machine Learning, analyze:
• images and video and accompanying audio
• Telemetry Data
• location information
• trip activity
• device and usage signals
The Services may analyze visual cues, including eye movement, head position, facial orientation, or similar indicators, to support certain attentiveness, safety, or driving-related features. The Services are not designed to identify individuals through facial recognition technology, and FiglioTech does not collect, store, sell, lease, or otherwise retain biometric identifiers or biometric information for identification purposes.
6.2 Outputs
Automated systems, including Machine Learning, generate: alerts, scores, summaries, event classifications, coaching insights, notifications, and safety-related prompts.
6.3 Limitations
Automated outputs are estimates or indicators only and:
• may contain errors
• may miss events
• depend on device placement, permissions, environmental conditions, or third-party data
• should not be relied upon as the sole basis for legal, employment, insurance, disciplinary, or safety decisions
• should not be treated as definitive conclusions about any person’s conduct, condition, or intent
6.4 Ongoing Development
We may update how automated systems function over time as features evolve, models improve, or new capabilities are introduced.7. Groups, Roles, Visibility, and Controls
Many features of the Services operate through Groups and permission settings.
7.1 Roles
Depending on subscription type and configuration, a Group may include an Account Holder, one or more Administrators, and Group Members. Roles have different access levels and controls.
7.2 Visibility and Permissions
Depending on settings, a user’s trip activity, location, alerts, communications with Group Members, or related information may be visible to:
• the Account Holder
• Administrators
• other Group Members where permissions allow
Certain permissions can be configurable by the user, Account Holder, or Administrator. Account Holders and Administrators may have visibility into trip data regardless of certain member visibility settings that limit access for other Group Members, including other Administrators.
7.3 User Controls
Users can retain direct control over certain device-level settings regardless of Group participation, such as:
• camera and microphone permissions
• sound alerts
• location permissions (subject to feature impacts)
• auto-start settings
• notification preferences where available
Some changes may generate notifications to Account Holders or Administrators, including certain location-sharing or visibility changes.8. Third-Party Partners and Organizational Use
8.1 Driving School / Referral or Promotional Relationships
We may work with driving schools or referral, promotional or similar partners from time to time that provide referral links, discount programs, promotional offers, or educational opportunities. Unless expressly stated, these third parties do not automatically receive access to user account data solely because a user signed up through one of these relationships.
8.2 Organizations Using the Services
Businesses or Organizations may use the Services through Group-based structures or other supported account models. Where an Organization administers an account, it may have access to information relating to participating users based on system configuration, permissions, subscription features, and applicable law.
8.3 Independent Third Parties
Driving schools, employers, insurers, or other third parties that receive information from users or Organizations will have their own privacy practices and terms. We are not responsible for those independent practices.9. How We Share Information
We share information in the following circumstances:
9.1 With Service Providers
We share information with vendors and service providers that perform services on our behalf, such as providers of: cloud hosting and infrastructure; payment processing; customer support tools; analytics and diagnostics; messaging or communications tools; mapping, geolocation, or traffic-related services; and fraud prevention or security services. These parties access information only as reasonably necessary to perform services for us, subject to contractual or legal restrictions where applicable.
9.2 Within Groups and Shared Accounts
Where you participate in a Group or shared account environment, certain information will be visible to other authorized users depending on role (such as Account Holder or Administrator), permissions, subscription features, and configuration settings. This includes trip activity, location, alerts, messages, or other related account information.
9.3 With Organizations Administering Accounts
If you use the Services through an Organization, business, school, employer, or similar entity, that Organization may have access to information relating to your use of the Services consistent with the account structure, permissions, and applicable law. Such Organizations independently determine how they use information available to them through the Services.
9.4 At Your Direction
We share information when you ask us to do so or direct sharing through available features, including with emergency contacts, other Group Members, instructors, Organizations, or third-party integrations you authorize.
9.5 Legal Compliance and Protection
We disclose information if we believe in good faith that doing so is necessary to: comply with law, regulation, subpoena, court order, or legal request; protect the rights, safety, or property of FiglioTech, users, or others; investigate fraud, misuse, abuse, or security incidents; or enforce our agreements and policies.
9.6 Business Transfers
We will disclose or transfer information in connection with an actual or proposed merger, acquisition, financing, sale of assets, bankruptcy, or restructuring transaction, subject to customary confidentiality protections where appropriate.
9.7 No Sale of Personal Information
We do not sell Personal Information in exchange for monetary consideration in the ordinary sense of that term. Where applicable law uses a broader definition of “sale,” users may have rights described below.10. Data Retention
We retain information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to: provide the Services; maintain accounts and Groups; comply with legal obligations; resolve disputes; enforce agreements; and improve safety, security, and system integrity.
Retention periods vary depending on account type or subscription plan, user settings, role within a Group, type of data involved, and legal or operational requirements.
We delete, de-identify, or aggregate de-identified information when no longer needed.11. Your Choices and Privacy Rights
Depending on your location and applicable law, you may have rights regarding your Personal Information. These may include the right to request:
• access to certain information we maintain about you
• correction of inaccurate information
• deletion of certain information
• portability of certain information
• withdrawal of consent where processing is based on consent
• restriction or objection to certain processing activities
We may need to verify your identity before responding to requests. Some rights may be limited where another person’s rights are implicated, information is tied to a Group structure or shared account, or we must retain information for legal or legitimate business reasons.
11.1 Group and Organization Requests
If your information is associated with a Group or Organization-administered account, some requests may need to be handled through the Account Holder or Administrator, we may refer you to the relevant Organization where appropriate, and certain information may remain visible to others based on system architecture or legal obligations.
11.2 Device-Level Controls
You may also control certain information collection directly through your device or app settings, such as location permissions, camera and microphone permissions, notification preferences, sound alerts, and background activity settings (where available). Disabling certain settings may limit functionality.
11.3 Consent for Canadian Users
If you are located in Canada, we collect, use, and disclose Personal Information with consent where required by applicable law. Depending on the circumstances and sensitivity of the information, consent may be express or implied, as permitted by applicable law. By using the Services, enabling permissions, joining a Group, or voluntarily providing information, you are consenting to certain processing activities described in this Privacy Policy. You may withdraw consent to certain processing activities at any time, subject to legal or contractual restrictions and reasonable notice. Withdrawal of consent may limit or disable certain features of the Services. Where required by law, we will seek additional consent before using Personal Information for materially new purposes.
11.4 California and Other U.S. State Privacy Rights
Residents of certain U.S. states, including California and other states with applicable privacy laws, may have additional rights regarding their Personal Information, including the right to:
• know the categories of Personal Information collected
• know the categories of sources from which information is collected
• know the business or commercial purposes for collection, use, or disclosure
• know categories of third parties to whom information is disclosed
• access specific pieces of Personal Information, where required by law
• request deletion of certain Personal Information
• request correction of inaccurate Personal Information
• obtain a portable copy of certain Personal Information
• opt out of certain processing activities, including certain targeted advertising or uses defined by law as a “sale” or “sharing”
• limit certain uses of sensitive Personal Information where required by law
• appeal certain decisions relating to privacy requests where required by law
We will not discriminate against you for exercising rights available under applicable law. To exercise applicable rights, please contact us using the details listed below. We may need to verify your identity and authority before processing a request.
11.5 Cookies, Analytics, and Similar Technologies
Our websites and online services may use cookies, pixels, SDKs, local storage technologies, and similar tools to support functionality, security, account management, analytics, communications, and user preferences. These technologies may be used to:
• maintain user sessions and preferences
• understand how users interact with the Services
• improve functionality and performance
• diagnose technical issues
• measure the effectiveness of communications, referrals, or promotional activities
• support security and fraud prevention efforts
Depending on applicable law and the technologies used, users may be able to control certain cookies or similar technologies through browser settings, device settings, or other available controls. Disabling certain technologies may affect functionality of the Services.12. Children’s Privacy
The Services are not intended for independent use by children under the age of 14 unless access is otherwise permitted through a parent, guardian, or authorized Account Holder in accordance with applicable law.
Where required by law, we rely on parent, guardian, or Account Holder authorization for certain youth accounts or supervised use arrangements.
If you believe a child has provided Personal Information in a manner inconsistent with applicable law, please contact us so that we can review and take appropriate action.
For users under the age of majority, additional explanations are provided in our Youth Privacy Notice.13. Security
We use reasonable administrative, technical, and physical safeguards designed to protect Personal Information. However, no system or method of transmission over the internet is completely secure. Accordingly, we cannot guarantee absolute security of information. Users are responsible for maintaining the security of their credentials, devices, and account access.
14. Third-Party Services and Links
The Services may integrate with, link to, or rely on third-party products or services, including app stores, payment processors, mapping tools, analytics providers, communications platforms, or referral partners.
Third-party services operate under their own terms, privacy notices, and practices. We are not responsible for the independent content, security, availability, or privacy practices of third parties. We encourage users to review applicable third-party terms and privacy policies.15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect:
• changes to the Services
• legal or regulatory developments
• new products or features
• operational changes
• clarifications to our practices
When we make material changes, we will provide notice through the Services, by email, or by other appropriate means. The Effective Date above indicates when the current version became effective. Your continued use of the Services after an updated Privacy Policy becomes effective constitutes your acceptance of the updated Privacy Policy to the extent permitted by law.
16. Contact Us
If you have questions about this Privacy Policy or our privacy practices, you can contact us at:
FiglioTech, Inc.
Email: privacy@figliotech.com
Mailing Address:
830 A1A North, Suite 13-404
Ponte Vedra Beach, FL 32082