Privacy Policy

1. Introduction

Your privacy is important to RTK.ai ("we," "our," or "us"). We developed this Privacy Policy to provide you with information on how we collect, use, disclose, and protect your personal data when you use our iLens Smart AR HUD Glasses and related wearable devices, mobile applications, and services (collectively, the "Services").

This Privacy Policy applies to all users of our Services and all products in the iLens product line. By using our Services, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account or use our Services, we collect:

• Account Information: Name, email address, password, and account preferences
• Profile Information: Date of birth, gender, height, weight, and fitness preferences
• Contact Information: Information you provide when contacting customer support
• Communications: Feedback, survey responses, and correspondence with us

2.2 Information Collected Automatically

When you use our iLens devices and mobile applications, we automatically collect:

• Device Information: Device model, operating system, unique device identifiers, firmware version
• Usage Data: Features accessed, settings, display preferences, interaction patterns
• Log Data: IP address, browser type, access times, pages viewed, referring pages
• Performance Data: Battery usage, device diagnostics, error reports, crash data
• Location Data: GPS coordinates and location information when using navigation features (with your permission)

2.3 Health and Fitness Data from Connected Wearable Devices

Third-Party Wearable Device Integration:

When you choose to connect third-party wearable devices (such as smartwatches, fitness trackers, or health monitoring devices) to our Services, we may access and process the following types of data through their respective APIs and data platforms:

• Activity Data: Steps, distance traveled, calories burned, active minutes, floors climbed
• Heart Rate Data: Real-time heart rate, resting heart rate, heart rate zones, heart rate variability
• Workout Information: Exercise type, duration, intensity, training load, recovery time
• Sleep Data: Sleep duration, sleep stages, sleep quality scores
• GPS and Location Data: Route maps, elevation, pace, speed during activities
• Body Metrics: Weight, body composition, body mass index (if shared)
• Women's Health Data: Menstrual cycle tracking data (if enabled and authorized)
• Stress and Wellness: Stress level, energy monitoring, respiration rate, relaxation metrics
• Training Metrics: Aerobic capacity estimates, training status, fitness age, performance indicators

Important Notes on Third-Party Wearable Data:

• We only access data from connected devices after you explicitly authorize the connection in the iLens app
• You control exactly which types of data are shared through your connected device's permission settings
• You can revoke access to your wearable device data at any time through your device's account settings or the iLens app
• We retrieve historical data and real-time synced data as permitted by the connected platform
• Your wearable device data is accessed in accordance with each platform's developer agreements and applicable data protection laws

2.4 Data from Other Third-Party Services

With your permission, we may integrate with various fitness tracking platforms, health apps, and wearable device ecosystems, including but not limited to:

• Garmin Connect
• Apple Health / HealthKit
• Google Fit
• Samsung Health
• Fitbit
• Polar
• Suunto
• Strava
• Other compatible fitness and health platforms

3. How We Use Your Information

We use the collected information for the following purposes:

3.1 Service Delivery and Core Functionality

• Display real-time health, fitness, and activity data on your iLens Smart Glasses
• Sync data between your wearable devices, mobile app, and iLens glasses
• Provide navigation and route guidance features
• Enable workout tracking and performance monitoring
• Process and store your activity history and statistics

3.2 Product Development and Improvement

• Analyze usage patterns to improve our Services
• Develop new features and functionalities
• Test, troubleshoot, and optimize device performance
• Conduct research and development for future products

3.3 Personalization

• Customize your iLens display settings and preferences
• Provide personalized fitness insights and recommendations
• Tailor content and features based on your activity patterns

3.4 Communication

• Send technical notices, updates, and security alerts
• Respond to your inquiries and provide customer support
• Send administrative messages related to your account
• With your consent, send promotional communications about new features or products

3.5 Safety, Security, and Legal Compliance

• Protect against fraud, unauthorized access, and security threats
• Enforce our Terms of Service and other agreements
• Comply with legal obligations and respond to lawful requests
• Protect the rights, property, and safety of RTK.ai, our users, and others

4. How We Share Your Information

4.1 Third-Party Service Providers

We share your information with trusted third-party service providers who perform services on our behalf, including:

• Cloud Storage Providers: For secure data storage and hosting
• Analytics Services: To understand usage patterns and improve our Services
• Customer Support Platforms: To provide efficient customer service
• Payment Processors: If you make purchases through our Services

These service providers are contractually obligated to protect your information and use it only for the purposes we specify. They cannot use your data for their own purposes.

4.2 Integration Partners

When you connect third-party fitness tracking services and wearable device platforms to our Services:

• We access data from these services based on the permissions you grant
• Your use of these integrated services is governed by their respective terms and privacy policies
• We recommend reviewing the privacy policies of any third-party services you connect
• We do not share your data back with these platforms except as necessary to maintain the integration functionality
• You can disconnect any integrated service at any time through your iLens app settings

4.3 With Your Consent

We may share your information with other parties when you give us specific permission to do so, such as:

• Sharing activity data on social media platforms (if you choose)
• Participating in challenges or competitions with other users
• Connecting with friends or fitness communities

4.4 Business Transfers

If RTK.ai is involved in a merger, acquisition, bankruptcy, dissolution, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website before your information is transferred and becomes subject to a different privacy policy.

4.5 Legal Requirements and Safety

We may disclose your information if required to do so by law or if we believe in good faith that such action is necessary to:

• Comply with legal obligations, court orders, or governmental requests
• Protect and defend our rights or property
• Prevent fraud or security issues
• Protect the personal safety of users or the public

4.6 Aggregated and De-Identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you. This data may be used for research, analytics, or marketing purposes.

5. Data Retention

We retain your personal information for as long as necessary to:

• Provide our Services to you
• Comply with legal, tax, and accounting obligations
• Resolve disputes and enforce our agreements
• Maintain security and prevent fraud

When you delete your account, we will delete or anonymize your personal information within 90 days, except where we are required by law to retain it longer. Some information may remain in backup systems for a limited time as part of our disaster recovery procedures.

Connected Device Data Retention: When you disconnect a third-party wearable device or fitness platform, or revoke access permissions, we will cease accessing new data from that service. Historical data previously synced may be retained according to the retention periods described above, or deleted upon your request.

6. Data Security

We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect it, including:

• Encryption: Data in transit is encrypted using industry-standard TLS/SSL protocols. Data at rest is encrypted using AES-256 encryption
• Access Controls: Strict access controls limit who can access your personal information. Access is granted only on a need-to-know basis
• Authentication: Secure authentication mechanisms, including password requirements and optional two-factor authentication
• Security Monitoring: Continuous monitoring for security threats and vulnerabilities
• Regular Audits: Periodic security assessments and third-party audits
• Employee Training: Regular security and privacy training for our employees
• Incident Response: Established procedures for responding to security incidents

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

7. Your Privacy Rights

You have certain rights regarding your personal information. The specific rights available to you may depend on your location and applicable laws.

7.1 Rights Available to All Users

• Access: Request access to your personal information and receive a copy of the data we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to certain exceptions)
• Account Closure: Close your account at any time through the app settings or by contacting us
• Export: Request a copy of your data in a portable format
• Opt-Out: Opt out of promotional communications (note: you will still receive essential service-related messages)

7.2 Managing Connected Services

For data received from third-party wearable devices and fitness platforms:

• You can disconnect any connected device or service at any time through the iLens app settings
• You can modify data sharing permissions through your connected device's account settings
• You can view and manage all connected services in your iLens account settings
• Disconnecting a service will stop new data collection, but previously synced data may be retained according to our retention policy

7.3 How to Exercise Your Rights

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within the timeframe required by applicable law (typically within 30 days).

To protect your privacy and security, we may need to verify your identity before processing your request.

8. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at [email protected], and we will delete such information from our systems.

9. International Data Transfers

Your information may be transferred to and maintained on servers located outside of your country of residence, where data protection laws may differ from those in your country.

When we transfer personal data internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by relevant authorities
• Adequacy decisions regarding the destination country
• Other legally approved mechanisms

By using our Services, you consent to the transfer of your information as described in this Privacy Policy.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities and to distinguish you from other users. This helps us provide you with a better experience and improve our Services.

Types of Cookies We Use:

• Essential Cookies: Required for the website and app to function properly
• Performance Cookies: Help us understand how visitors interact with our Services
• Functionality Cookies: Remember your preferences and settings
• Analytics Cookies: Allow us to analyze usage patterns

You can control cookies through your browser settings. However, disabling cookies may limit your ability to use certain features of our Services.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors.

When we make material changes to this Privacy Policy, we will:

• Post the updated Privacy Policy on this page
• Update the "Last Updated" date at the top
• Send you an email notification (for significant changes)
• Provide prominent notice within our Services

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

13. Regional Privacy Information

13.1 For Users in South Korea (대한민국 이용자)

If you are located in South Korea, we comply with the Personal Information Protection Act (PIPA) and related regulations. As a user in Korea, you have the following rights:

• Right to Access: You may request to view your personal information we hold
• Right to Correction: You may request correction of inaccurate or incomplete information
• Right to Deletion: You may request deletion of your personal information
• Right to Suspension: You may request suspension of processing of your personal information
• Right to Data Portability: You may request your data in a commonly used format

Personal Information Protection Officer:

Name: To be designated
Email: [email protected]

Filing Complaints: If you believe your rights have been violated, you may file a complaint with:

• Personal Information Protection Commission: 1833-6972 (www.pipc.go.kr)
• Personal Information Dispute Mediation Committee: 1833-6972
• Korea Internet & Security Agency (KISA): 118 (privacy.kisa.or.kr)

13.2 For Users in Other Asian Countries

We comply with applicable data protection laws in your country, including:

• Japan: Act on the Protection of Personal Information (APPI)
• Singapore: Personal Data Protection Act (PDPA)
• China: Personal Information Protection Law (PIPL)
• Thailand: Personal Data Protection Act (PDPA)

13.3 For Users in the European Economic Area (EEA)

If you are located in the EEA, RTK.ai is the data controller of your personal information. Under the General Data Protection Regulation (GDPR), you have additional rights including:

• The right to lodge a complaint with a supervisory authority
• The right to object to processing based on legitimate interests
• The right to withdraw consent at any time

Our lawful basis for processing your data includes: consent, contract performance, legal obligations, and legitimate interests.

13.4 For Users in California

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), including:

• The right to know what personal information we collect, use, and share
• The right to delete personal information
• The right to opt-out of the sale of personal information (Note: We do not sell personal information)
• The right to non-discrimination for exercising your privacy rights

13.5 For Users in Other Regions

For users outside of the regions mentioned above, we comply with applicable local data protection laws. Please contact us for specific information about your privacy rights in your region.