Privacy Policy – Mobile Apps

Redtail Telematics respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use one or more of our Mobile Apps, and tell you about your privacy rights and how the law protects you.

Contents

1. Consent to the Operation of an App
2. The Data We Collect About You
3. How Is Your Personal Data Collected?
4. How We Use Your Personal Data
5. Your Legal Rights
6. Glossary

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1. Consent to the Operation of an App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data.

Before using any of our Apps, you will be required to indicate your consent to our processing of your personal data (including your name, email address and device information) as described in this policy, and the policy associated with the App.

Once you provide consent, you may change your mind and withdraw consent at any time by contacting us, but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

You can contact us at:

dpo@redtailtelematics.com.

or

Redtail Telematics Ltd Plextek Building London Rd Great Chesterford CB10 1NY United Kingdom

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2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Redtail Telematics Apps collect, use and display data relating to the purpose of each App, and your use of a Redtail Telematics device or devices. Some of this data may already exist within the Redtail Platform, collected through the process of registering for an account on the Platform, and the rest is collected through your use of the App.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name and job title.
• Contact Data includes email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes feedback and survey responses.
• Contact Data Usage includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with the business you represent, and there is a failure to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into (for example, to provide the business you represent with software and services). In this case, we may have to cancel any provision of software and/service that the business you represent has with us but we will notify you if this is the case at the time.

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3. How Is Your Personal Data Collected?

We use different methods to collect data from and about you, including through:

• Direct interactions
  You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

   

  • request a trial of our software;
  • subscribe to our software and services and newsletter;
  • request marketing to be sent to you;
  • enter a competition or survey;
  • provide us with your business card; or
  • give us some feedback.
• Automated technologies or interactions.
  As you interact with our website, we may automatically collect Technical Data about your equipment, actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources.
  We may receive personal data about you from various third parties and public sources as set out below:

   

  • Technical Data from the following parties:
    1. analytics providers such as Google based outside the EU;
    2. advertising networks such as Google Adwords based outside the EU;
  • Identity and Contact Data from publicly availably sources such as Companies House.
  • Identity and Contact Data from our wholly owned subsidiary company, [Redtail Telematics Inc, based outside the EU.
  • Identity and Contact Data from the following sites: Twitter, YouTube, Linked-In, Google Plus based outside the EU.

We will collect and process the following data about you:

• Information you give us. This is information about you that you provide to use the App. Also, if you contact us with a query or to report a problem with the App, we will keep a record of that correspondence, including your contact details.
• Information we collect about you and your device. Each time you use the App, it can also collect certain information automatically, including, but not limited to, the type of mobile device you use, the IP address of your mobile device, your mobile operating system, and information about the way you use the App.
• Location Data. We may also use the location services (assisted GPS) within your device to determine your current location, but only if you give permission when requested. You can withdraw your consent to this at any time by disabling Location Data, or by removing the permission you have given to the App, in your settings.

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4. How We Use Your Personal Data

We will only use your personal data when you give us permission or the law allows us to do so, and solely where it is necessary to fulfil the purpose of the App. Most commonly we will use your personal data in the following circumstances:

• where you have consented before the processing;
• where we need to perform a contract we are about to enter or have entered with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we need to comply with a legal or regulatory obligation.

Any data collected through our Apps is held by Redtail Telematics, and no data is transferred to any other third-party. All data transfers between App and Redtail Telematics’ servers take place over an SSL-encrypted secure internet connection, and data is stored by Redtail Telematics on Microsoft’s Azure platform within the European Economic Area (EEA). We do not transfer your personal data outside the EEA.

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorised employees and contractors who need to know that information in order to operate, develop or improve the App and/or service. Please be aware that, although we endeavour provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

We may disclose user provided and automatically collected information:

1. as required by law;
2. when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
3. with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement;
4. if Redtail Telematics is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

You can stop all collection of information by an App easily by uninstalling it. You may use the standard uninstall process of your mobile device. You can also request to opt-out via email, at dpo@redtailtelematics.com.

We will retain automatically collected information for up to 24 months, and thereafter may store it in aggregate. If you would like us to delete data that you have provided via an App, please contact us at dpo@redtailtelematics.com and we will respond in a reasonable time.

In order to use our Apps, you must consent to our collection and processing of your information as set forth in this Privacy Policy. If you have any questions regarding privacy while using our Apps, or have questions about our practices, please contact us via email at dpo@redtailtelematics.com.

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5. Your Legal Rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

Please click on the links below to find out more about these rights:

• • Request access to your personal data;

• • Request correction of your personal data;

• • Request erasure of your personal data;

• • Object to processing of your personal data;

• • Request restriction of processing of your personal data;

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• • Request transfer of your personal data;

• • Withdraw consent at any time.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time, by contacting us at:

Redtail Telematics Ltd Plextek Building London Rd Great Chesterford CB10 1NY United Kingdom

or dpo@redtailtelematics.com.

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6. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you and the business you represent the best service and software and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties Redtail Inc, our wholly owned subsidiary, acting as processor and which is based in the USA and undertakes business support including sales on behalf of the Company.

External Third Parties

• Service providers acting as processors based in the EU and/or USA who provide IT hosting services to help us operate our business and our website or administer activities on our behalf.
• Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom and USA who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain software or services to you. We will advise you if this is the case at the time you withdraw your consent.