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Zenlit

Privacy Policy

  1. INTRODUCTION

This Zenlit Labs Privacy Policy ("Privacy Policy") governs your use and access of certain services, products or apps that we offer, including with or through our affiliates. At Zenlit Labs, one of our main priorities is the privacy of our visitors and users. ("hereinafter Zenlit", "we", "us", "our") having its registered office at Santa Clara, 2540 Mission College Boulevard, Suite 100, CA 95054, Phone 408 245 3800.

By downloading, accessing, or using the Safety Promotion Mobile Application ("Zenlit"), participating in our programs, or engaging with any related features including the issuance, receipt, or redemption of Zenlit Token ("ZNLT"), you acknowledge that you have read and understood this Privacy Policy and agree to its terms. If you do not accept the terms of this Policy, you should not use the Zenlit App or any of its functionalities. This Policy applies exclusively to the services and data processing activities operated by us through the Zenlit App and associated backend systems. It does not extend to third-party services, platforms, or partners that are not owned or controlled by us. To understand how such partners process your Personal Data, we encourage you to review their respective privacy policies. We are fully committed to protecting your privacy and maintaining transparency about how your Personal Data is collected, used, stored, shared, and secured. This Privacy Policy outlines our practices regarding data protection and explains the legal bases for processing your data, our adherence to applicable U.S. privacy regulations, and your rights in relation to your information. It also describes how and why your Personal Data may be shared with authorized service providers and third parties in connection with your use of the Zenlit App.

While many features of the Zenlit app can be used without identifying you directly, some functionalities may involve the collection of data that could be classified as "Personal Information" under applicable law. In such cases, Zenlit Labs acts as a "business" or "controller" of that data, depending on the context and purpose of the processing. This Privacy Policy explains what data we collect, the purposes for which we collect it, how we use and share it, and the choices available to you regarding your Personal Information.

We recognize the importance of transparency and accountability in our data practices. As such, we will update this Privacy Policy as necessary to reflect changes in our services, legal obligations, or internal practices. The "Last Updated" date at the top of this Policy indicates when it was most recently revised. If we make any material changes, we will notify you through in-app messaging or via the official website prior to the update taking effect. We encourage you to read this Policy regularly to remain informed about how we protect your data.

If you have additional questions or require more information about our Privacy Policy, please do not hesitate to contact us.

  1. DEFINITIONS

The following terms---"Business," "Service Provider," "Consumer," "Personal Information," "Processing," "Deidentified Data," and "Sensitive Personal Information"---used in this Policy shall have the meaning given to them under applicable U.S. federal and state privacy laws, including the California Consumer Privacy Act (as amended by the CPRA), the Virginia Consumer Data Protection Act, and similar legislation ("Applicable data protection laws"). Other capitalized terms used in this Privacy Policy, but not explicitly defined by applicable U.S. law, are used in accordance with their common industry understanding or as defined elsewhere in this document or in the User Agreement.

Other Capitalized terms used in this Privacy Policy shall have the same meaning given to them in the User Agreement and Terms.

  1. WHAT DATA DO WE COLLECT?

Depending on how you interact with the Zenlit application and its associated features, we collect different categories of data from a variety of sources. Some of this information is provided directly by you --- for example, when you create a user profile, participate in token-based incentives, or manually adjust your preferences within the app. Other data is collected automatically through your use of the app's connected services and technologies. This includes geolocation data used to create driving behavior insights captured through sensors or integrations, and other contextual information essential to delivering personalized, safety-enhancing experiences. The extent and type of data we collect depend on how you use the app, your settings, and your participation in optional features such as route planning, safety scoring, token reward redemption, and wallet linking. All collected data is processed in a proportionate manner and strictly for the purposes outlined in this Privacy Policy.

Therefore, when you use the Zenlit application, we may collect several categories of information to deliver core functionalities, personalize your experience, and ensure compliance with applicable legal and technical standards.

Users can choose to register or log in to the Zenlit app either:

(i) by signing up with your email address. If you choose to log in using your email address, we will collect and process the following information at the point of registration or profile setup: your full name, email address, and phone number. This information is necessary to create and manage your account, support app features, and enable communications relevant to your participation in the reward system.

(ii) by signing up and using your existing Google or Apple account. If you choose to log in with your Google or Apple account, we will receive basic profile information made available by Google or Apple, such as your full name, email address, and your Google-linked profile image. This information is used to create and manage your user profile within the app and will be processed in accordance with this Privacy Policy. We do not access or store your Google or Apple password or other sensitive authentication information.

In addition to login-related information, the app collects the following categories of data:

  • Driving Behavior Data, such as GPS coordinates, trip start and end times, routes taken, vehicle speed, acceleration, braking patterns, and phone usage during driving. This information is gathered via GPS sensors, on-device capabilities, and integrations with third-party telematics providers. It is essential for computing your individualized Safety Score, which in turn determines token eligibility and driving feedback.

  • Referral Program Data, including your referral code, referrer and referee user identifiers, timestamps of referral invitations and acceptances, reward eligibility status, and the number of successful referrals completed. This data is recorded when you participate in our referral program and is used to validate eligibility, prevent fraud or abuse, enforce program limits, and issue ZNLT token rewards in accordance with program rules. We do not access or upload your personal contacts, nor do we send messages on your behalf; all referrals are user-initiated. Referral data is retained for a limited period necessary to manage rewards and detect abuse.

  • Device and Technical Information, including your device model, Bluetooth connectivity, Phone's accelerometer and other sensors, unique device identifiers (pseudonymized) and mobile network provider. This data is collected automatically using SDKs, and API integrations and is used to ensure app compatibility, troubleshoot performance issues, and monitor usage patterns for security and optimization purposes.

  • Usage Data, such as how you interact with different features within the app, how often you engage with specific modules, session durations, and crash or error logs. This helps us understand product engagement, enhance user experience, and improve app performance.

  • Token Transactions, which include the amount of ZNLT Token earned, held, or used, as well as interactions with smart contracts, blockchain wallet addresses, and transaction logs. While blockchain data is inherently pseudonymous, if a wallet is linked to your user profile, associated token activity may become identifiable and thus treated as Personal Information under this Policy.

  • Inferred Data, generated through algorithmic analysis of the categories above, such as your driving behavior trends, safety risk profiles, eligibility for promotions, and similar derived insights. These inferences help us tailor the service, optimize rewards, and provide meaningful feedback.

We process all this information in accordance with applicable data protection laws, ensuring that it is used solely for legitimate purposes, kept secure, and never reused beyond the original intent without your informed consent or legal basis.

We do not store your private keys or recovery phrases at any time. Your wallet security remains solely under your control. Please note that if you lose your private keys or recovery phrases, you will permanently lose access to your wallet and any ZNLT tokens or other digital assets stored within it. On-chain transactions may be irreversible, and certain transaction metadata (such as your wallet address, transaction hash, and transaction amounts) is publicly visible on the blockchain. We may store transaction metadata linked to your account for purposes such as fraud prevention, rewards accounting, and customer support. Platform-operated keys, where applicable, are secured using segregated methods such as hardware wallets, multi-sign configurations, and secure cloud-based secrets management systems. These measures never grant us access to users' personal private keys or recovery phrases.

  1. HOW DO WE USE THE DATA COLLECTED?

We use the data we collect through Zenlit to operate, maintain, enhance, and personalize your experience with the app. This includes ensuring the functionality and security of the application, optimizing system performance, and enabling the core features of the service. More specifically, your personal information and behavioral data are processed to calculate and validate your individual Safety Score (or ZenScore), which serves as a foundational element for many of the services provided through the platform.

Your Safety Score allows us to determine your eligibility for various benefits and to generate ZNLT Tokens that reflect your driving behavior and improvements over time. These tokens may be used to unlock access to exclusive offers, discount vouchers, or partner-provided benefits available in a dedicated in-app marketplace. We may also use your Safety Score to assign digital driving badges, recognize milestones, or offer personalized coaching tips to improve your driving habits.

Trip-related data, such as geolocation, speed, braking, and phone usage while driving, is integral to the accurate computation of your Safety Score. This data is also useful in refining the scoring algorithm over time, validating the credibility of reward eligibility, and enhancing risk-based profiling that may be used to offer personalized recommendations or upsell opportunities through our marketplace.

Additionally, we process collected data to:

(a) communicate with you, including by sending service-related messages, push notifications, or promotional communications (where permitted);

(b) conduct aggregated analytics and statistical modeling to better understand user behavior and improve platform features;

(c) detect and prevent fraudulent or abusive activities;

(d) comply with legal obligations, including recordkeeping, regulatory reporting, and user rights enforcement.

(e) your data also helps us evaluate trends and create aggregated performance reports. These insights can be used to adapt incentives, enhance user retention strategies, and inform our product development decisions. In some cases, de-identified data may be used for research and development or public road safety studies.

(f) where legally required, we may also use your data to comply with law enforcement requests, enforce our terms and conditions, investigate fraud or abuse, or prevent potential harm to our users or the public.

All data processing is conducted in a manner consistent with applicable privacy laws, our contractual commitments, and the expectations set forth in this Privacy Policy. Where required, certain data uses may be subject to your explicit consent or offer an opt-out mechanism, particularly where processing goes beyond core service delivery.

  1. PROFILING AND AUTOMATED DECISION-MAKING TRANSPARENCY

Certain features of the Zenlit App involve profiling and automated decision-making within the meaning of applicable data protection laws. In particular, your Safety Score is generated automatically based on data collected during your trips, including driving behaviour data as described herein.

The Safety Score is recalculated periodically and is used to determine your eligibility for ZNLT rewards and the level of perks or offers available in the in-app marketplace.

While the scoring process is largely automated, human oversight is maintained to ensure fairness and address exceptional cases. If you believe your Safety Score does not accurately reflect your driving behavior, or if you wish to contest the outcome of any automated decision that affects your rewards or marketplace access, you may contact us via privacy@telenav.com or through the in-app support feature. We will review your case, consider additional context, and, where appropriate, adjust your Safety Score or associated rewards.

Please note that profiling in this context is solely for the purpose of delivering core app functionality, incentivizing safe driving, and providing related benefits. We do not use your Safety Score for unrelated purposes such as marketing to third parties or making decisions about creditworthiness, insurance premiums, or employment eligibility, unless you separately consent to such uses or where permitted by law.

  1. SHARING AND DISCLOSURE OF INFORMATION

[We do not sell your personal information]{.underline}.

However, Telenav may share personal data with third parties strictly on a need-to-know basis and only to the extent necessary for the purposes described in this Privacy Policy. All recipients are subject to appropriate contractual and technical safeguards to ensure the protection and confidentiality of your personal data. All data collected through the Zenlit application is owned and controlled by the Telenav group of companies, which includes Telenav, Inc. and its affiliated entities. As the legal data owner, Telenav ensures that any data disclosures are made strictly in accordance with applicable privacy laws, contractual safeguards, and internal governance policies.

We may disclose personal data to the following categories of recipients:

  • Telenav affiliates and Group entities

We may share data within the Telenav group of companies as part of our global operations, subject to our intragroup data protection framework.

  • Vendors, partners, and service providers

We may share your data with Service Providers and Business Partners who support the operation, maintenance, and improvement of the Zenlit ecosystem. This includes hosting providers, analytics vendors, customer support tools, behavioral data processors, mapping services, and blockchain infrastructure providers. These third parties are contractually bound to process the data solely for the purpose of delivering their contracted services and are required to uphold strict confidentiality, security, and data minimization obligations. They are not permitted to use your personal data for their own purposes. Zenlit Labs remains liable for any misuse by vendors acting on its behalf, unless it can demonstrate that it is not responsible for the event giving rise to the damage.

  • Advertising and Token Marketplace Partners

We may engage with such Partners to enable the use of ZNLT within affiliated reward ecosystems. For example, when you use ZNLT to acquire offers or vouchers in the in-app marketplace or from third-party vendors, those partners may be provided with token-related data such as your wallet address, token balances, and eligibility to make such acquisitions. However, we do not share detailed behavioral, driving, geolocation history or other data that are not part of the processing pursued by such Partners.

  • Professional advisors and legal representatives

Where necessary, we may disclose data to auditors, legal counsel, or consultants for the purposes of legal compliance, dispute resolution, court orders, government investigations, or regulatory inquiries. We may also share your data when we believe it is necessary to detect, prevent, or respond to suspected fraud, abuse, violations of our Terms of Use, or threats to public safety.

  • Research and analytics partners

In anonymized or aggregated form, we may share data with third parties engaged in traffic analytics, system improvement research, or urban mobility studies.

  • Merger, Acquisition, or Corporate Transaction,

if Zenlit , Telenav, or any affiliated entity is involved in a business combination, restructuring, or sale of assets, your personal information may be transferred to the successor entity. In such cases, we will ensure continuity of privacy protection standards, and your data will remain subject to the commitments outlined in this Privacy Policy unless legally superseded or updated with appropriate user notice.

Finally, certain categories of data may be disclosed in connection with specific use cases that enhance the value of the services provided to you. For instance, your Safety Score or associated analytics may be shared with insurance providers to support usage-based insurance programs or risk-based product offerings, which may include affiliated entities within the Telenav Group. Similarly, anonymized or aggregated insights derived from your driving data may be made available to research partners, or entities involved in traffic safety studies or product development initiatives.

These disclosures are carried out in accordance with applicable data protection standards and are subject to appropriate safeguards.

You retain meaningful control over how your data is used in these contexts, and we provide clear mechanisms for you to opt out of any data sharing that extends beyond the core functionality of the platform. Where such sharing occurs, it is limited to the minimum data necessary to fulfil the intended purpose and always respects the principles of data minimization and user transparency.

In all instances, Telenav retains ownership of all data collected through Zenlit and ensures that any third-party access, use, or disclosure is subject to robust oversight, regulatory alignment, and user transparency.

  1. SECURITY

Your privacy is important to us, and we maintain reasonable, appropriate security procedures to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data. For instance, Telenav limits access to Zenlit Labs systems that store such information to authorized personnel. Zenlit Labs also uses the Secure Sockets Layer (SSL) protocol to ensure our transmission of Personal Data is secured through encryption.

While Zenlit Labs maintains various security measures to prevent unauthorized access to or disclosure of your Personal Data, no security measures are absolute or wholly guaranteed. We recommend you protect yourself against any unauthorized access to your account by keeping your password and log in credentials confidential.

If required by law, we will notify you if it determines unauthorized acts violate the law, this Policy, or other security breaches.

  1. RETENTION

Telenav has implemented policies and rules regarding the retention of personal data that fully comply with the Applicable Data Protection Laws. The retention periods are determined as to serve the purposes for which they are collected and processed and are reviewed periodically to meet the standards relating to the limitation of data storage.

The length of time we retain Personal Data, and the criteria we use for determining that time, are dependent on the nature of the Personal Data and the purpose for which it was provided. For example, we retain your Personal Data related to managing your application account (such as name, email address, account content and preferences) for as long as they are retained by you within your account. We may typically maintain other data, such as records of your activity within the application, for a short period before anonymizing such data for further authorized use. We may also retain your Personal Data for other purposes permitted under Applicable Data Protection Laws, including, for example, the defense of any legal claims. We may keep, Personal Data based on what is applicable to the product or service you are using.

You may contact us at: privacy@telenav.com for additional information about our retention policies regarding your Personal Data.

  1. YOUR RIGHTS AND CHOICES

Depending on your U.S. state of residence, you may be entitled to exercise certain rights regarding your personal information under applicable privacy laws, including but not limited to the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CPRA"), the Colorado Privacy Act ("CPA"), Virginia's Consumer Data Protection Act ("VCDPA"), the Connecticut Data Privacy Act, and Utah's Consumer Privacy Act. These rights are designed to give you more transparency and control over how your personal information is handled.

Right to Know and Access: You have the right to request that we disclose the categories of personal information we collect about you, the sources from which we collect it, the business or commercial purposes for collecting or sharing it, and the categories of third parties with whom it is shared. You may also request a copy of the specific pieces of personal information we have collected about you, subject to verification of your identity.

Right to Delete: You have the right to request that we delete personal information we have collected from or about you. This right is subject to certain exceptions --- for instance, where the data is necessary to provide our services, comply with legal obligations, detect security incidents, or protect against fraudulent or illegal activity. To exercise this right, you may submit a request by sending an email to privacy@telenav.com or by following the instructions provided at the following link: https://www.zenlit.com/account-deletion

Right to Correct Inaccuracies: You may request that we correct inaccurate personal information maintained about you. Upon verifying the validity of such a request, we will make commercially reasonable efforts to correct the information.

Right to Opt-Out of the Sale or Sharing of Personal Information: You have the right to opt out of the sale or sharing of your personal information with third parties, including for purposes of cross-context behavioral advertising. You may exercise your right to opt out at any time via in-app settings or by submitting a request to our designated privacy contact.

Right to Limit the Use of Sensitive Personal Information (where applicable): In jurisdictions like California, you may also have the right to limit the use and disclosure of sensitive personal information to only what is necessary to perform the services or provide the goods reasonably expected by an average consumer. Zenlit only collects limited sensitive data (e.g., geolocation, driving behavior data) as necessary for the operation of the app and in a manner consistent with the purposes disclosed in this Privacy Policy.

Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights. We will not deny you goods or services, charge different prices or rates, or provide a different level or quality of service solely because you exercised any of your legal privacy rights.

Right to Appeal (in certain jurisdictions): Residents of states such as Colorado, Virginia, and Connecticut have the right to appeal our decision if we decline to take action on your privacy request. If your appeal is denied, you may also contact your state's Attorney General for further review.

Right to Data Portability: In certain cases, you may have the right to obtain your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

In certain jurisdictions, including California, specific categories of data we process, such as precise geolocation data and driving behavior information, are classified as Sensitive Personal Information ("SPI") under applicable privacy laws. We collect and process this SPI solely to deliver the Zenlit App's core services, which include enabling navigation, route tracking, trip analysis, Safety Score computation, token reward eligibility, and ensuring the security and integrity of the app by detecting fraud, preventing misuse, and troubleshooting issues. We do not use SPI for purposes unrelated to these core functions, including cross-context behavioral advertising, profiling for unrelated marketing, or sale of SPI to third parties.

Please note that certain rights may only apply in specific states, and the availability of these rights is subject to verification and any applicable legal exceptions. If you are a resident of a state that enforces additional or different consumer privacy rights not outlined above, we will honor those rights in accordance with local law.

You may exercise any of your rights by submitting a request via our designated email address at privacy@telenav.com or through the privacy settings available in the Zenlit app. Before fulfilling your request, we may ask for additional information to verify your identity or the authority of the person making the request on your behalf. If your request relates to a connected blockchain wallet, we may require additional verification.

  1. CHILDREN'S PRIVACY

Zenlit is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that a user is under 18, we will delete their information as quickly as possible. If you believe we may have collected data from a child, please contact us immediately.

IF YOU ARE UNDER THE AGE OF 18 YOU MAY NOT USE THE APP IN ANY WAY.

  1. GOVERNING LAW

By choosing to use our Platform or otherwise provide information to Telenav, you agree that any dispute over privacy or the terms contained in this Policy will be governed by the laws of the State of California, United States of America; provided, however, (i) this Policy shall be governed by the Applicable Data Protection Laws or (ii) such other governing law as may be mandated by the jurisdiction in which you reside. Except where prohibited by applicable law you also agree to arbitrate such disputes and to abide by any limitation on damages contained in our Terms of Use, Terms and Conditions of Service, or other applicable agreement we have with you.

Telenav is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

  1. CHANGES TO THIS PRIVACY POLICY

We may update this Policy according to changes in our business functions, measures concerning the protection of Personal Data and Applicable Data Protection Laws. If we make changes to this Policy, we will notify you through the Navigation APP in vehicle. Where changes to this Policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have.

  1. CONTACT US

We are very open about privacy and recognize your trust as a great value. If you have any questions about this statement or any privacy issues in our applications or services, feel free to contact our Data Protection Officer by email at:

Telenav, Inc

Attention: DPO

2540 Mission College Boulevard, Suite 100

Santa Clara, CA 95054

Phone: 408 245 3800

Email: privacy@telenav.com

If you want to stop receiving information as per the above, you can opt out at any time by contacting us at the email address indicated in this Privacy Policy. At all times, access to the User's Personal Data by the Company's own staff and third-party intermediaries, will be restricted to the bare minimum required for the Company to perform our business and the provision of the Company Services.

Version 1.0
September 09, 2025