This Policy explains how Lucid ELD Inc. ("Lucid," "we," "us," or "our") handles biometric data and in-cab recordings created through optional driver-facing features of our cameras. It also gives our customers two ready to use templates: a driver consent form and a printable in-cab notice. This Policy is part of our Master Terms of Service.

Important: Our cameras are road-facing by default. The features described here apply only when a customer chooses to enable the optional driver-facing lens, in-cab video, in-cab audio, or facial analysis. These features are off by default, and the customer controls them and can disable or physically remove the in-cab lens at any time.

1. When This Policy Applies

This Policy applies only when a customer enables one or more driver-facing features for a vehicle. In the default road-facing mode, our cameras do not capture in-cab video, in-cab audio, or biometric data, and this Policy does not apply.

2. What We Collect and Do Not Collect

When driver-facing features are enabled, we may collect:

• Facial geometry and related biometric identifiers derived from in-cab video, used for features such as driver attention and safety event detection.
• In-cab video of the driver area.
• In-cab audio, where the customer enables audio recording.

We do not collect fingerprints, DNA, retina or iris scans, or voiceprints. We do not use biometric data to identify members of the public. We do not sell biometric data.

3. Purpose

Biometric data and in-cab recordings are used to provide safety and monitoring features that the customer has enabled, such as detecting driver attention, fatigue indicators, and safety events, and to support the customer's review of those events. We process this data to provide the Service to the customer.

4. Notice and Consent

The customer is the party that decides to collect biometric data and in-cab recordings from its drivers. Before enabling any driver-facing feature, the customer must give each affected driver the written notice required by law and obtain the driver's written consent, including the specific written consent required by biometric laws such as the Illinois Biometric Information Privacy Act. We provide a driver consent form and an in-cab notice in the appendices to help the customer meet these obligations. The customer is responsible for using them correctly and for any additional notice or consent its jurisdictions require.

5. No Sale or Improper Disclosure

We do not sell, lease, trade, or otherwise profit from biometric data, and we do not disclose biometric data except to provide the Service, with the consent that the customer obtained, to a service provider under contract, or as required by law or valid legal process.

6. Retention and Destruction Schedule

We retain biometric identifiers only as long as needed for the purpose described above, and we destroy them at the earliest of:

• when the initial purpose for collecting them has been satisfied;
• within 30 days after the customer disables the relevant driver-facing feature for the vehicle or driver, or after the driver is no longer associated with the customer's account; or
• within three years of the driver's last interaction with the Service.

In-cab video and audio are retained according to our general footage retention practice described in our Privacy Policy, except that event and incident recordings a customer saves are kept until the customer deletes them or a legal hold is lifted. When the retention period ends, we delete or permanently de-identify the data using reasonable measures.

7. Customer Obligations and Indemnity

A customer that enables driver-facing features agrees that it:

• controls these features and may disable them or physically remove the in-cab lens at any time;
• will provide all required written notice to drivers and obtain each driver's written consent before enabling the features;
• is solely responsible for compliance with all biometric, recording, all-party-consent, privacy, and labor laws that apply to its drivers and operations; and
• will indemnify Lucid for any claim arising from its enabling or use of these features or any failure to provide required notice or obtain required consent, as described in our Master Terms of Service.

8. Admin Attestation and Logging

When an Admin enables a driver-facing feature, the Admin must complete an attestation in the dashboard confirming that the customer controls the feature, that the required notice and written driver consent have been obtained, and that the customer is solely responsible for compliance. We log the attesting Admin, the timestamp, the IP address, the features enabled, and the vehicles affected.

9. Security

We protect biometric data using the safeguards described in our Privacy Policy, including access controls and encryption in transit, and we store it on servers located in the United States. We use a reasonable standard of care to protect biometric data, and we store and transmit it in a manner that is the same as or more protective than the manner in which we protect other confidential and sensitive information.

10. State Notes

• Illinois. The Illinois Biometric Information Privacy Act requires informed written consent before collecting biometric identifiers, prohibits selling or profiting from them, and requires a written retention and destruction schedule. This Policy provides that schedule, and the customer must obtain written consent using the consent form or an equivalent.
• Texas. Texas law requires notice and consent before capturing a biometric identifier for a commercial purpose and requires reasonable destruction within a set time after the purpose ends. The customer must provide notice and obtain consent.
• Washington. Washington law requires notice, consent, or another legal basis before enrolling a biometric identifier in a database for a commercial purpose. The customer must meet this requirement.
• Colorado. Colorado privacy law treats biometric data as sensitive data that requires consent before processing. The customer must obtain that consent.

These notes are summaries, not legal advice. Laws change and vary, and the customer is responsible for compliance in every place it operates.

11. Questions From Drivers

Drivers with questions about how their data is handled should first contact the customer that operates their vehicle, since that customer controls these features. Drivers may also contact us at support@lucideld.com.

12. Changes and Contact

We may update this Policy and will revise the effective date and provide notice of material changes. Contact: Lucid ELD Inc., 1000 Northbrook Drive, Suite 100, Trevose, PA 19053, support@lucideld.com, +1 (717) 703-0377.

Appendix A: Driver Biometric and In-Cab Recording Consent Form

Note for carriers: Give this form to each driver and collect a signature before enabling any driver-facing feature. Keep the signed forms in your records. Add your company name and adjust the form with your own counsel.

Driver consent to in-cab video, audio, and biometric features

[Carrier company name] uses a fleet safety system provided by Lucid ELD Inc. in its vehicles. When driver-facing features are turned on, the system may:

• record video inside the cab;
• record audio inside the cab, where enabled; and
• analyze facial geometry to support driver attention and safety event detection, which involves collecting biometric data.

Purpose. This data is used for fleet safety, monitoring, coaching, and review of safety events.

Retention. Biometric data is destroyed at the earliest of when its purpose is satisfied, within 30 days after the feature is disabled for your vehicle or you leave the company, or within three years of your last interaction with the system, as described in the Lucid Biometric and In-Cab Recording Policy.

Your consent. By signing below, I acknowledge that I have read this notice and the Lucid Biometric and In-Cab Recording Policy, and I consent to [Carrier company name] and Lucid collecting, storing, and using in-cab video, in-cab audio where enabled, and my biometric data as described, for the stated purposes.

Driver name: ______________________________

Driver signature: __________________________

Date: ____________________

Appendix B: In-Cab Notice Decal Text

Note for carriers: Print and post this notice where drivers and occupants can see it inside the cab. Use it in states that require all-party consent for audio recording, such as California, Pennsylvania, and Illinois, and anywhere else notice is appropriate. Confirm the wording with your own counsel.

NOTICE: This vehicle is equipped with a video and audio recording and driver safety system. Video and audio inside this cab may be recorded, and driver-facing safety features may collect biometric data. By entering or operating this vehicle, you acknowledge this notice. Questions: contact [Carrier company name].