1.
Central - Privacy And Cookie Policy
Last Revised: February 10, 2023
GreenRoad Driving Technologies Ltd. its subsidiaries and
affiliates, GreenRoad (“GreenRoad” or “we”)
respects the privacy of its services' users and is committed to protect its users™
information. We believe that you have a right to know our practices regarding
the information we may collect and use when you use our GreenRoad
Central internet
platform (the “Platform”). Please read the following carefully to
understand GreenRoad™s views and practices regarding
your personal information and how GreenRoad will treat it.
This Privacy and Cookie Policy (“Privacy and Cookie Policy”) details how
your Personal Information is used and processed by GreenRoad or its affiliates
anywhere in the world (as detailed under Section 1 below), whether you are a
fleet driver (“Driver”) or fleet manager (“Admin”).
TABLE OF
CONTENT
1.
Who we
are
2.
Your
acknowledgment of this policy (important, please read!)
3.
Which
information may we collect about Users?
4.
How do
we collect information about our Users?
5.
What
are the purposes of the collection and processing of information?
6.
Sharing
Personal Information with Third Parties
7.
Your
Rights
9.
Minors
10.
Third
Party Service Providers
13.
Security
14.
Data
retention
15.
Changes
to the
1. WHO WE ARE
In this policy, references to GreenRoad, or to
"we" or "us" are to: (i)
GreenRoad Driving Technologies Ltd., which is a registered company in the state
of Israel (No. 513524587) located at 26 Harokmim St.,
Holon, Israel; (ii) GreenRoad Technologies UK Ltd., which is a registered
company in the UK (No. 5840761) at Landmark office 2nd Floor, 3 Brindley Place,
Birmingham B1 2JB, United Kingdom; and GreenRoad Inc., which is a registered
company in the US (No.205312505) located at 8900 Shoal Creek Blvd Suite 111,
Austin TX 78757, USA.
Individuals wishing to contact us about data protection issues may do so by writing
to contacting us at the above addresses, or by emailing us at drivegreen@greenroad.com.
You may also contact our Data Protection Officer at dpo@greenroad.com
2. YOUR ACKNOWLEDGMENT OF THIS POLICY
(IMPORTANT, PLEASE READ!)
Please note:
•
The
Platform is authorised by the company, enterprise, business or other organisation
you are affiliated with, work at, employed by, or member in, in your capacity
as a driver
and/or an administrator
(respectively: “User” or “you” and "the
Organisation"). The Platform is intended for use solely by individuals
that received authorisation from their Organisation to access the Platform. The
information we collect and process about you is strictly related to your Organisation
and to the services that we provide to them.
•
All
information that GreenRoad collects from
you and processes,
including as part of your use of the Platform, is owned and controlled by your
Organisation, who is defined as the "controller" of
such information under the EU Data Protection Law). Please note that
GreenRoad acts as a third party data "processor" on
behalf of your Organisation, and that it is your Organisation in its capacity
as a "controller" which initiates the personal data
collection, determines from whom to collect such data and defines how to use
the collected data. We will process your information strictly on behalf of your
Organisation and in accordance with our contractual agreements with it, its
lawful instructions and/or as permitted by law.
•
For
further queries, please review the privacy policies of your Organisation and
the agreements associated with your engagement with the Organisation, as
provided to you by your Organisation. If, in the context of using the Platform,
you have reached out to your Organisation and have
not received a reply, you may approach GreenRoad, and we will make a commercially reasonable effort
to assist you.
•
Please
note that your Organisation is a third party beneficiary to this Privacy and
Cookie Policy, but may also have its own privacy policies, and that your Organisation
will have the right to enforce the terms of this Privacy and Cookie Policy as a
third party beneficiary of this Privacy and Cookie Policy.
BY
ACCESSING AND/OR USING THE PLATFORM, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD
THE OPPORTUNITY TO BECOME AWARE OF AND AGREE (IN JURISDICTION WHERE SUCH
CONSENT IS REQUIRED) TO THIS PRIVACY AND COOKIE POLICY AND GREENROAD™S
PRACTICES DESCRIBED THEREIN, INCLUDING TO THE COLLECTION, USE, PROCESSING, DISCLOSURE, RETENTION OR
DISPOSAL OF YOUR
PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DO NOT AGREE TO ANY TERM
PROVIDED HEREIN, PLEASE CONTACT YOUR ORGANIZATION AND CEASE ANY ACCESS OR USE
OF THE PLATFORM.
3. WHICH INFORMATION MAY WE COLLECT ABOUT USERS?
We may collect two types of data and information from Users of our Platform:
•
3.1.
Non-personal Information. The first type of information that we may collect is
non-identifiable and anonymous information. Put simply, we are not able to identify the specific Users from whom we have collected
the Non-personal Information, unless it is cross-referenced with Personal
Information. The non-personal
Information gathered consists of technical information and behavioural
information that does not pertain to a specific individual. For example,
technical information may include information such as the type and version of
your device and its operating system, screen resolution, keyboard language,
Wi-Fi connectivity, the type and name of your device, etc. Behavioural
information may include the User™s click-stream on the
Platform, the activities of the User on the Platform and additional information
of a similar nature.
•
3.2.
Personal Information. The second type of information we
may collect is individually identifiable information. Put simply,
this information may identify an individual or is of a private and/or sensitive
nature, such as your
location history (“Personal Information”). Personal Information
includes:
3.2.1. Personal Information which is provided voluntarily by
Drivers and/or Admins:
o
Activating
the Platform: During the Platform's activation
process, you will be required to provide us with
the username and password assigned to you by your Organisation
and/or by GreenRoad.
o
Communications
with GreenRoad: We
may collect any information you provide in any
communications with GreenRoad, by any means, including to customer services or
customer support calls. We may record your customer support calls for quality
assurance purposes and for improving our services.
3.2.2. Personal Information with respect to Drivers
collected via GreenRoad's technology:
o
GreenRoad
collects and processes certain information relating to the Driver, as
determined by the Driver's Organisation, from the Driver's vehicle, either via
devices installed in the vehicle
and/or via the Driver's use of GreenRoad's GreenRoad
DRIVE™ mobile
application ("GreenRoad DRIVE"). This
information may be presented to Drivers and Admins, in whole or in part, via
the Platform, and may include the following:
Safety levels and
driving behaviour data: we access, collect,
process, monitor and/or remotely store certain information from the Driver's
vehicle via GreenRoad devices or GreenRoad partner devices
installed in the Driver's vehicle or via the GreenRoad DRIVE™ app. The scope and
extent of such information is determined by your Organisation and may include
one or more of the following: the Driver's driving speed, detection of safety
incidents, idling events, backing events, fuel consumption, vehicle health
status, Mobileye events, ECO statistics, and the
distance, duration, start and end times of the
Driver's journeys.
Video: if a camera has been
installed in the Driver's vehicle as part of our services, we shall process
video footage of safety events and we may also monitor the Driver, by using an
inside-facing camera installed in the Driver's cabin.
Geolocation data: we
will access, collect, process, monitor and/or remotely store geolocation data,
including GPS coordinates and other similar information, to determine the Driver's
location and historic journey information via devices installed in the Driver's
vehicle or via the GreenRoad DRIVE™ app.
Information relating to the Driver's identity: we
access, collect, process, monitor and/or remotely store certain information
relating to the identity of the Driver, by collecting information stored on the
Driver's RFID or Dallas Key that his/her Organisation has provided to him/her.
Information relating to the Driver's journey: the
Driver may voluntarily provide us with certain information related to his/her journeys via devices installed in
the Driver's vehicle or via the GreenRoad DRIVE™ app. For example, the Driver may categorise each
journey as a Private or Business
journey.
o
Please
note that:
Since the Driver's
Organisation will determine the exact information to be collected and
processed via the GreenRoad DRIVE™ app and/or GreenRoad (or GreenRoad's
partner) devices installed in the Driver's vehicle, if you wish to receive further
information with respect to such data collection methods and practices, please
refer to your Organisation. Additional
information may be found under the GreenRoad DRIVE™ app's Privacy and Cookie Policy, which
is available hereunder.
Some or all of the abovementioned information may not be
viewed by all Users (e.g. Drivers may have limited
access to such information via the GreenRoad
DRIVE™ app or GreenRoad Platform,
as determined by the Organisation). Notwithstanding, such information may be
processed by GreenRoad, even if you are unable to view such information through
the Platform.
3.2.3. Information provided by your Organisation:
o
GreenRoad
may receive additional information about you from your Organisation, and the
scope of such information provided to us is determined by your Organisation.
Such information includes your full name, and may include one or more of the
following categories of Personal Data, as determined by the Organisation:
Your birth date;
Your personal ID as
it appears in your Organisation's organisational and HR systems;
Your driver's
license number, date of issue and licensing authority abbreviation;
Your employment date with the Organisation;
Your phone number;
Your email address; and
Your gender.
o
Please
note that some or all of the abovementioned
information may be processed by GreenRoad, even if you are unable to view such
information while using the GreenRoad
DRIVE™ app or GreenRoad Platform.
3.2.4. Personal Information collected through use of the
Platform:
o
We
collect technical and behavioural information through your use of the Platform,
including:
Geolocation data: while
using the Platform we will access, collect, process, monitor and/or remotely
store geolocation data, including GPS coordinates and other similar information
to determine your location.
Incentives: we may provide
incentives for the benefit of Drivers, whether
in the form of coupons or other types of awards, in our
sole discretion. The history of such
incentives provided shall be recorded.
Technical and behavioural information: to
the extent that the technical and behavioural information detailed under
Section 3.1 above will be linked to or associated with a specific individual, then such information
will be considered as Personal Information.
Identifiers: unique identifiers such as
Internet Protocol (IP) address, Cell MAC, Ad-id, IMEI, Unique Device Identifier
(UDID), and others will be collected
through use of the Platform.
3.2.5. Please note:
o
We may
cross-reference Personal Information with other Personal Information we have stored about
you. Any
Non-personal Information connected or linked to or associated with any Personal
Information shall be deemed as Personal Information as long
as such connection, linkage or association exists.
o We use third-party tracking services and usage logs to
track and analyse data from Users of the Platform and for purposes of security
and fraud prevention. For more information, please refer to Section
10 below. We may also use cookies to gather information regarding
your use of the Platform and the information for which you searched and
accessed. For more information
please refer to Section 12 below.
4. HOW DO WE COLLECT INFORMATION ABOUT OUR USERS?
We use four main methods to
collect information:
4.1. We
collect information through your entry, connection, access and/or use of the
Platform. In other words, when you access or use the Platform, we are aware of your
usage of the Platform, and may gather, collect and record the information
relating to such usage. For example, when you use the Platform, we will gather
technical and behavioural parameters (such as online identifiers) relating to your
use of the Platform.
4.2. We
collect information which you provide us voluntarily. For example, we
collect information when you communicate with us for technical support. We will
inform you prior to collecting your Personal Information if it is requested on
a voluntary basis, and also inform you as to the
consequences of not providing voluntary Personal Information.
4.3. We
collect information through GreenRoad Technology. When Drivers drive
their vehicles,
GreenRoad (and its partners') devices installed in the Driver's vehicle, or the GreenRoad DRIVE™ app used by the Driver,
continually collect information regarding the status of the vehicle, the behaviour of the driver and
security incidents. This information is then transmitted to us.
4.4. We collect information provided to us by your
Organisation. For example, your Organisation provides us with Personal
Information such as your full name, user name and
password in order for us to provide your Organisation with our services.
5. WHY DO WE COLLECT AND PROCESS INFORMATION?
5.1. Non-personal
Information is processed in order to:
o
Enhance
the User™s experience of the Platform;
o
Create statistical
information and learn about the preferences of Users and general trends of Platform usage (e.g.
understanding which
features are more popular than others); and
o
Keep the
Platform safe and secured and to prevent fraud.
5.2. Personal
Information is processed in order to:
o
Register
and administer your Platform Account;
o
Verify
the User's identity when he/she signs in to the Platform;
o
Carry
our obligations arising from our agreement with your Organisation, in our
capacity as your Organisation's service provider. Please note that such
obligations include full disclosure of any Personal Information collected
and/or processed via the Platform to your Organisation;
o
Enable
the operation of the Platform;
o
Personalise
your experience on the Platform;
o
Send
push notifications to the User's device after the User has agreed to accept
push notifications from GreenRoad. Users can deactivate certain push
notification by changing their settings within our Platform;
o
Be able
to contact Users for the purpose of providing them with technical assistance
and support;
o
Ensure
that content on the Platform is presented in an optimal way for you and for your device (e.g. optimally
formatted for display on tablet, mobile phone or laptop);
o
Send you
updates, notices, announcements, and additional information related to
GreenRoad including with respect to changes made to our Platform's terms of use
and privacy policy, either by email
or through the post;
o
Conduct
internal operations, including troubleshooting, data analysis, testing,
research and statistical purposes;
o
Keep the
Platform safe and secured and to prevent
fraud and crime;
o
Comply
with our legal obligations while protecting GreenRoad™s and
your Organisation's rights and legitimate interests, including in order to
handle insurance claims.
Note to
our Users in the EU:
In order for
GreenRoad to process your Personal Information, as detailed herein, such
processing must be justified as having a basis
for processing, the criteria of which
has been determined exclusively by your Organisation. Please note that the
processing may be justified on the basis that:
o
the
processing is based on your consent (i.e. you have provided your Organisation
with your consent regarding the specific type of data
processing required);
o
the
processing is necessary for the performance of a contract between you and your
Organisation (e.g. the execution of an employment
contract);
o
the
processing is necessary to enable your Organisation to comply with a legal
obligation (e.g. disclosure of information to
authorities); or
o
the
processing is in your Organisation's legitimate interests, subject to your
interests and fundamental rights.
If you
have any question or require any clarifications regarding the basis for
processing your Personal-Information, please refer to your Organisation.
Note to non-EU Users:
BY ENTERING, CONNECTING TO, ACCESSING OR USING THE
PLATFORM, YOU CONSENT TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL
INFORMATION AS SPECIFIED HEREIN.
6. SHARING PERSONAL INFORMATION WITH
THIRD PARTIES
6.1.
GreenRoad respects your privacy and will not disclose, share, rent, or sell
your Personal Information to any third party, other than as permitted under
this Privacy and Cookie Policy.
6.2. Please
note: All information that GreenRoad shall collect from you and
process through your use of the Platform may be fully disclosed to your Organisation
which is the owner, and where applicable considered as the "controller",
of such information.
6.3. We
may share your information in the following cases:
o
Group
Companies: the Personal Information you
provide to us may be accessed by members of GreenRoad group of companies in
order to fulfill the purposes detailed herein.
o
GreenRoad
Personnel: Personal Information that we collect
and process may be transferred to or accessed by personnel of GreenRoad for the
sole purpose of enabling the operation of the Platform and to carry our
obligations arising from any agreement entered into between GreenRoad and your
Organisation (as detailed in Section 5 above). Please note that all GreenRoad
personnel that will have access to your Personal Information are under an
obligation of strict confidentiality with respect to such Personal Information.
o
Service
Providers: we may share Personal Information with vendors,
commercial software providers, consultants and data processers who perform
services on our behalf, including without limitation, companies that provide
analysis services,
messaging services and services which host the Platform. For more information
regarding our Service Providers, please refer to Section 10 below.
o
In
addition, we may share Personal Information in the following cases: (a)
to satisfy any applicable law, regulation, legal process, subpoena or
governmental request; (b) to enforce this Privacy and Cookie Policy or any
other agreement or terms of service between you and GreenRoad and to defend
against any claims or demands asserted against us by you or on your behalf; (c)
to detect, prevent, or otherwise address fraud, security or technical issues;
(d) to protect the rights, property, or personal safety of GreenRoad, its Users
or the general public; and (e) when GreenRoad is undergoing any change in
control, including by means of merger, acquisition or purchase of all or
substantially all of the assets of GreenRoad (while such acquired company or
investor may be located in countries outside of your jurisdiction).
6.4. For avoidance of doubt, GreenRoad may transfer and
disclose Non-personal Information to third parties at
its discretion, including without limitation for statistical, analytical and
research purposes and for customisation, development and improvement of our
Platform.
7. YOUR RIGHTS
GreenRoad acknowledges that
you have the right to access and change the Personal
Information we collect about you and
process. If you wish to access or to correct, amend, or delete Personal
Information, please contact your Organisation.
Note to our Users in the EU:
We hereby inform you of the following rights (by virtue of EU law) with respect
to the processing of your Personal Information:
•
Right to
access: you may have the right to request a review of your
Personal Information held by GreenRoad.
•
Right to
rectification: if the Personal Information
processed by GreenRoad is incorrect, incomplete or not processed in compliance
with applicable law or this Privacy and Cookie Policy, you may have the right
to have your Personal Information rectified.
•
Right to
erasure: under certain conditions, you may be entitled to
require GreenRoad to delete
or "block" your Personal Information (e.g.
if the continued processing of a specific data is not justified).
•
Right to
Portability: you may have the right to
transfer your Personal Information between data controllers (i.e.
to transfer your Personal Information from your Organisation to another
entity).
•
Right to
object to or withdraw consent: where the lawful
basis for processing your Personal Information is either "public
interest" or "legitimate interests", those lawful bases are not
absolute, and you may have a right to object to such processing. If the
processing of your Personal Information is based on your consent, you have the
right to withdraw your consent to such processing at any time.
•
The
right to restrict processing: under certain
circumstances, you may have the right to object to the processing of your
Personal Information due to your particular situation.
•
Right to
lodge a complaint: you have the right
to lodge a complaint before the relevant data protection authority or
supervisory authority of your jurisdiction.
To exercise these rights, where
applicable, please contact your Organisation, or, if applicable, use
the appropriate functionality available on the Platform.
8. LOCATION OF YOUR PERSONAL INFORMATION
The information collected from you by GreenRoad, as
detailed in this Privacy and Cookie Policy, may be transferred to, and stored on, servers which may be located in countries outside of your jurisdiction, including in countries that are not considered to
offer an adequate level of protection under your local laws. It may also be
processed by GreenRoad and its suppliers, service providers or partners' staff
operating outside your country.
GreenRoad is committed to protecting your Personal Information and will take
appropriate steps to ensure that it is
processed and stored securely and in accordance with applicable privacy laws,
as detailed in this Privacy and Cookie Policy. Such steps include the establishment of data
transfer agreements, or ensuring that
our third-party service providers comply with GreenRoad's data transfer protection measures.
Note to our Users in the EU:
If you are located in the EU, you have a right to
request further information regarding the data transfer mechanisms we use with respect to data
transfers to third countries. In order to keep your Personal Information safe,
we apply strict safeguards when transferring it outside of the EEA, which may
include the following:
•
Transferring
your personal information to countries approved by the European Commission as
having adequate data protection laws, such as Israel;
•
Entering
into standard contracts that have been approved by the European Commission and
which provide an adequate level of high quality
protection with the recipients of your Personal Information;
•
Transferring
your Personal Information to organisations that are Privacy Shield
Scheme certified, as approved by the European Commission.
•
Applying binding corporate rules
within the GreenRoad group of Companies.
BY
SUBMITTING YOUR PERSONAL INFORMATION THROUGH THE GREENROAD
DRIVE™ APP OR THE GREENROAD PLATFORM,
YOU ACKNOWLEDGE, AND, IN
JURISDICTIONS WHERE
SUCH CONSENT IS REQUIRED, AGREE TO, SUCH
TRANSFER, STORAGE AND/OR
PROCESSING OF PERSONAL INFORMATION.
9. MINORS
The GreenRoad Platform is
intended for use by Users over
the age of sixteen (16). Therefore, GreenRoad does not intend and does not
knowingly collect Personal Information directly from children under the age of
sixteen (16) and does not wish to do so. We reserve the right to request proof
of age at any stage so that we can verify that minors under the age of sixteen
(16) are not using the GreenRoad Platform.
10. THIRD PARTY SERVICE PROVIDERS
10.1.
While you use the GreenRoad Platform, we may be using third party service providers who may collect,
store and/or process your information, as detailed in this Privacy and Cookie
Policy.
10.2.
Note that we collect, hold and/or manage your Personal Information through GreenRoad's authorised third party vendors of certain
products or services (such as hosting cloud services), including, as applicable, their affiliates. They are limited to processing this
information as required to provide us with such requested services, and not for any other purposes.
10.3.
Such vendors may be located in a country that does not
have the same data protection laws as your jurisdiction. For more information
relating to the location of your Personal Information, please refer to Section
8 above.
10.4.
Such third parties service providers include,
without limitation, the following categories of
service provides:
o Platform performance measuring and
monitoring. Our
third parties service providers include New Relic, whose privacy policy may be found at: https://newrelic.com/termsandconditions/privacy; Google
Analytics, whose privacy policy may be found at:https://policies.google.com/privacy; and MixPanel,
whose
privacy policy may be found at: https://mixpanel.com/legal/privacy-policy/
o Deep linking platform. Our third
parties service providers include Branch, whose privacy policy may
be found at: https://branch.io/policies/#privacy
o Hosting. Our third
parties service providers include AWS, whose privacy policy may be found
at: https://aws.amazon.com/privacy/;
o Communications. Our third
parties service providers include Twilio, whose privacy policy may
be found at: https://www.twilio.com/legal/privacy;
SendGrid, whose
privacy policy may be found at: https://sendgrid.com/policies/privacy/;
and Batch, whose privacy policy may be found at: https://batch.com/privacy-policy.
o Maps. Our third
parties service providers include Google Maps, whose privacy policy may
be found at: https://policies.google.com/privacy.
Please read
such third-party service providers' Terms of Use
and Privacy
policies to understand their privacy practices.
11. LINKS TO THIRD PARTY WEBSITES
Certain
links provided therein permit our Users to leave the GreenRoad Platform and to enter
non-GreenRoad websites or services. GreenRoad is not responsible or liable for
such linked websites and services' privacy practices and/or any other
practices. The majority of such linked websites and services
provide legal documents, including Terms of Use
and Privacy Policies that govern their
use. It is always advisable to - and
we encourage you to - read such
documents carefully before using those websites and services, inter alia, in
order to know what kind of information about you is being collected.
12. COOKIES & SIMILAR METHODS
12.1. What are cookies? Cookies are small text files which are
stored on, and accessed from, your computer or mobile device when you visit the
GreenRoad Platform. We use cookies, web
beacons, pixels, clear gifs, unique identifiers and other similar tools
(collectively, "Cookies")
on our Platform to differentiate your device from those of other Users of the GreenRoad Platform, to improve the Platform's
performance, to deliver a better and more personalised service according to the
User's individual interests and the device or browser used, to track Users' use
of the Platform, to gather information about the Users' approximate geographic
location (e.g. city) to provide localised content, to prevent fraud and/or
abuse, to estimate our audience size and usage patterns, to perform
other analytics, to develop our Platform and to provide our service providers
with data that may be used by such service providers for targeted advertising (e.g. Google Analytics).
In this
Privacy and Cookie Policy, reference to "Cookies" includes cookies
and all other files that collect information in a similar manner. Please note
that most Cookies do not collect information that identifies you, and will instead
collect more general information such as how Users arrive at and use our
Platform, or that identify a User™s general location.
12.2. How long will Cookies
stay on my device? Most of
the Cookies we use are erased from your device immediately after your browser
session terminates ("Session Cookies"). Other Cookies remain saved on
your device and enable us to recognise your device when you return to our Platform ("Persistent
Cookies"). Persistent Cookies allow us to make our Platform more
user-friendly, effective and safe,
and to record your acceptance of the
following Cookie Policy.
Please note that the data collected through Cookies will not be kept for longer
than is necessary to fulfil the purposes mentioned above.
12.3. First and Third Party Cookies -
First-Party Cookies are Cookies that
belong to us and that we place on your device. Third-party Cookies are Cookies
that another party, which provides us a service, places on your device through
your use of our Platform. For example, to administer our Platform and for
research purposes, we have contracted with third-party
service providers to track and analyse statistical usage and volume information
from our Platform Users. Third-party Cookies may also be placed on your device
by our business partners so that they can use them to advertise products and
services to you elsewhere on the Internet.
12.4. Do we track whether
users open our emails? Our
emails may contain a single "web beacon pixel" which enables us to
verify whether our emails (and any links or advertisements within the email)
are opened. We may use this information to determine whether our emails are of
interest to Users, to approach Users who do not open our emails and to verify whether they wish to continue receiving them, and to inform our advertisers regarding
the aggregate audience size for their
advertisements. Please note that this web beacon pixel will be deleted once you delete the email from your
email account. If you do not wish the web beacon pixel to be downloaded to your
device at all, please set your email account settings to receive emails from us
in plain text rather than HTML.
12.5. What sort of Cookies
does our website use? Generally,
our Cookies perform the following functions:
o Essential Cookies “ these are Cookies that are
essential for efficent navigation around the Platform and effective use
of its features. For example, they
allow us to remember your Cookie preferences and to verify if something isn't
working properly, so that we can fix
it quickly.
o Analytical and Performance Cookies “ these are Cookies that are used to
analyse how our Users interact with our Platform and to monitor the Platform's performance. For example,
we might use performance Cookies to keep track of which pages are visited frequently
and the locations from which our Users
come. We might also use these Cookies to highlight Platform services that we
think will be of interest to you based on your usage of the Platform. We
generally use third party Cookies to carry out these services, for example, Google Analytics.
o Functionality Cookies - these are Cookies that allow us to operate
the Platform in accordance with your preferences when browsing the Platform.
For example, such Cookies save you the trouble of typing in a username every
time you access the Platform, and recall your customisation preferences, such
as your preferred text size, fonts, languages, and other parts of the Platform
that are alterable.
12.6.
Can a Platform User block Cookies? Most devices
and browsers will allow you to erase Cookies from your device™s hard drive,
block acceptance of Cookies, or receive a warning before a cookie is stored.
However, if you block or erase Cookies, your experience of the Platform may be
limited. Please note that unless you block the acceptance of Cookies, the
Platform will utilise all Cookies upon
your use of the Platform, unless
applicable laws require the provision of separate
consent for the use of each type of Cookie,
in which case we will use such Cookies only after we receive your separate
consent to such use and subject to your right to withdraw such consent at any
time. For detailed instructions regarding the blocking of Cookies, please refer
to your browser 'help', 'tool' or 'edit' section,
or see http://www.allaboutcookies.org/manage-cookies/.
If you want to remove previously-stored
Cookies, you can manually delete the Cookies at any time. However, this will
not prevent the Platform from placing further Cookies on your device unless and
until you adjust you settings as described above.
Opting out of Performance Cookies -
It is possible to opt-out of having Performance Cookies record your browsing activity within the Platform . Please note that we
use Google Analytics and Mixpanel as our service
providers to track User activities on the Platform, and they use ßpersistent Cookies. You may
opt-out of Mixpanel's tracking by following the
instructions on the following link: https://mixpanel.com/optout/.
Google provides a browser-add on which allows users to opt-out of Google
Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout .
13. SECURITY
13.1.
We take appropriate measures to maintain the security and integrity of our
Platform and to prevent
unauthorised access to it or use thereof through generally accepted industry
standard technologies and internal procedures.
13.2.
Your Personal Information is hosted on AWS servers which provide advanced
strict security standards via both
physical and logical means.
13.3.
Some of the security measures that we employ include, without limitation:
highly secure service design and implementation using state of the art
encryption and architectures mechanisms;
restriction of access to your Personal Information to individuals who need
access to it in order to process it on GreenRoad™s
behalf; and implementation of a
secured permission management and auditing system using specific and
proprietary firewall and network access filtering as well as security group
mechanisms.
Please note, however, that there are inherent risks in
transmission of information over the Internet or other methods of electronic
storage and we cannot guarantee that unauthorised access or usage will never occur.
13.4.
GreenRoad will comply with applicable law in the event of any breach of the
security, confidentiality, or integrity of your Personal Information and will
inform you of such breach if required by applicable law.
13.5. TO THE
EXTENT THAT GREENROAD HAS IMPLEMENTED
THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, GREENROAD SHALL NOT BE
RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY
INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION,
DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL
INFORMATION.
14. DATA RETENTION
GreenRoad
will retain the Personal Information that your Organisation has instructed us
to process for it for as long as needed to provide GreenRoad's
services to your Organisation, and in accordance with the contractual terms
stipulated between GreenRoad and your Organisation. Your Organisation can at
any time instruct us to delete such Personal Information.
In addition, GreenRoad will retain Personal Information as necessary to comply
with our legal obligations, resolve disputes, and in accordance with GreenRoad's agreements with your Organisation, all subject
to applicable privacy laws.
15. CHANGES TO THE PRIVACY AND COOKIE POLICY
GreenRoad
reserves the right to change this Privacy and Cookie Policy at any time, so
please re-visit this page frequently to check for any changes. In case of any
material change, we will make reasonable efforts to post a clear notice on the
Platform, and/or
we will send you an e-mail regarding such changes to the e-mail address that
you may have provided us with. Such material changes will take effect seven (7)
days after such notice was provided on our Platform or sent to you via e-mail,
whichever is earlier. Otherwise, all other changes to this Privacy and Cookie
Policy are effective as of the stated “Last Revised” and your continued use of
the Platform on or after the Last Revised date will constitute acceptance of,
and agreement to be bound by, those changes. In the event that the Terms should
be amended to comply with any legal requirements, the amendments may take
effect immediately, or as required by the law and without any prior notice.
16. HAVE ANY QUESTIONS?
If you have
any questions (or comments) concerning this Privacy and Cookie Policy, please
send us an email to the following address: DPO@greenroad.com and we will
make an effort to reply within a reasonable timeframe.
GREENROAD EDGE™
AND GREENROAD DRIVE™
- PRIVACY AND COOKIE
POLICY
Last Revised: February 10, 2023
IMPORTANT:
BY USING THE PROPRIETARY APPLICATIONS OF GREENROAD
DRIVING TECHNOLOGIES LTD AND ITS
SUBSIDIARIES AND AFFILIATES (COLLECTIVELY (“COMPANY” or “WE”)
KNOWN AS GREENROAD DRIVE APP AND/OR GREENROAD EDGE AND/OR THE CONTENT, FEATURES
AND SER VICES THEREIN (COLLECTIVELY, THE “SERVICES” YOU “YOU”)
CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND CONSENT THAT ALL
PERSONALLY IDENTIFIABLE INFORMATION ("PII") THAT YOU SUBMIT OR THAT
IS PROCESSED OR COLLECTED THROUGH THE SERVICES MAY BE PROCESSED BY THE COMPANY
IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THE FOLLOWING PRIVACY POLICY (“PRIVACY
POLICY”).
IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN PLEASE DO NOT USE THE SERVICES.
WE DEFINE "PII" TO MEAN ANY
INFORMATION RELATING TO AN IDENTIFIED OR IDENTIFIABLE NATURAL PERSON; AN
IDENTIFIABLE NATURAL PERSON IS ONE WHO CAN BE IDENTIFIED, DIRECTLY OR
INDIRECTLY, IN PARTICULAR BY REFERENCE TO AN IDENTIFIER SUCH AS A NAME, AN
IDENTIFICATION NUMBER, LOCATION DATA, AN ONLINE IDENTIFIER OR TO ONE OR MORE
FACTORS SPECIFIC TO THE PHYSICAL, PHYSIOLOGICAL, GENETIC, MENTAL, ECONOMIC,
CULTURAL OR SOCIAL IDENTITY OF THAT NATURAL PERSON.
YOU ARE NOT LEGALLY REQUIRED TO PROVIDE US WITH PII,
HOWEVER, SOME OF THE SERVICES REQUIRE YOU TO DO SO PURSUANT TO THIS PRIVACY
POLICY. IN THESE CASES, IF YOU CHOOSE TO WITHHOLD OR DELETE ANY PII REQUESTED
BY US, IT MAY NOT BE POSSIBLE FOR YOU TO ACCESS CERTAIN SERVICES. IF YOU DO NOT
AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN PLEASE DO NOT USE THE
SERVICES.
We recognise that privacy is
important. This Privacy Policy applies to all of the
services, information, tools, features and functionality available on the
Services offered by the Company or its subsidiaries or affiliated companies and
covers how PII that the Company collects and receives, including in respect of
any use of the Services, is treated. If you have any questions about this
Privacy Policy, please feel free to contact our
Data Protection Officer. Our data protection
officer may be contacted by sending an email to DPO@greenroad.com
Please also read the End User
License Agreement applicable to you at Terms of Use which describes the terms
under which you use our Services.
TABLE OF CONTENTS
1.
PII We Collect and How We Use It
2.
Cookies
4.
Links
5.
Minors
6.
PII
Sharing
7.
Data
Security and Data Retention
9.
Your
Rights
10.
Enforcement
11.
Changes
to This Privacy Policy
14.
Questions
1. The PII We
Collect and How We Use It
In order to provide and improve our Services, we may
collect PII, including the following types of information: contact
information (including
full name, email address, ID, phone number);
transaction information (including invoices, evidence related to orders/
transactions and cancellations, service record, details about an individual™s
account/profile in the merchant™s records, online access/download history,
billing and shipping address);
location information and IP addresses.
1.1. Information You Provide. For
registration purposes and to support some of
the features that we provide via our
Services, we ask
you for PII, including contact information including your full name, email address,
video recordings, birth date, ID, employment date, driver license information,
gender and phone number.
1.2. Location Data. In order to provide our Services and
feedback regarding driver behaviour, we will access, collect,
process, monitor and/or remotely store geolocation data, including GPS
coordinates and other similar location information, to determine your current location
and historic journey information. This data
will be collected during when Services are in On
Duty mode on a daily basis. To the
extent that your vehicle
is permitted to be used by other members of your family, please obtain their
consent to the collection of this
information as a precondition to their use.
1.3. User Communications. When
you send emails or
other communications to the
Company, we may retain those communications in order to process your inquiries,
respond to your requests and improve our Services. We may send you push
notifications to send you news, reminders and updates in respect of the Services.
We may also send you newsletters and promotional communications. You may
opt-out of this service at any time by sending an email to the following
address: DPO@greenroad.com
1.4. User Information. When
you use the Services, we automatically receive and record information from your
browser, including (without
limitation)
information and statistics about your online/offline status, your IP address,
safety level and risky driving behaviour data, historic journey information
geolocation data (including country and city), location data, browser
identifiers, internet service provider, connection speed, search history, type
of browser, your regional and language settings and software and hardware
attributes. Our system automatically records and
stores
technical information regarding the method and nature of your use of the
Services. An IP address is a numeric code that identifies your browser on a
network, or in this case, the Internet. Your IP address is also used to gather
broad demographic information. We use all
the PII identified in this section in order to understand your usage trends and
preferences, including recent visits to our Services and how you navigate around the different sections of our
Services, both for
analytics purposes and in order to make our Services more intuitive.
1.5.
Aggregate and Analytical Data. As part of our ongoing
efforts to
better understand and serve our customers, we may conduct research regarding customer demographics,
interests and behaviour based on the PII and other information provided to us.
This research may be compiled and analysed on an aggregate basis, and we may
share this aggregate data with our affiliates, agents, suppliers and business
partners. This aggregate information does not identify you personally. We may
also disclose aggregated user statistics to describe our services to current
and prospective business partners, and to other third parties for other lawful
purposes. We also use aggregate data for monetisation.
2. Cookies
In order to collect the data described herein, we use temporary cookies
that remain on your browser for a limited period of time.
We also use persistent cookies that remain on your browser until our Services are removed, in
order to manage and maintain them and
record your usage patterns.
Cookies by themselves cannot be used to discover the identity of the user. A
cookie is a small piece of information which is sent to and stored on your
browser. Cookies do not damage your browser. Most browsers allow you to block
cookies, but you may not be able to use some features on the Services if you
block them. You may set most browsers to notify you if you receive a cookie
(this enables you to decide if you want to accept it or not). We also use web
beacons via the Services to collect information. Web beacons, or "gifs", are
electronic images used in our Services or in our emails. We use Web beacons to
deliver cookies, count visits and to determine if an email has been opened and acted upon. For more information,
please see our Cookie Policy available at: GreenRoad™s Cookie Policy
3. GreenRoad VideoSense™ Pro
We also carry out video surveillance, pursuant to our GreenRoad VideoSense™
Pro Privacy Policy,
available at: GreenRoad
VideoSense Pro Privacy Policy
4. Links
We may provide links to
other services, sites and applications as a convenience to our users. We are not responsible for the
privacy practices or content of other sites and applications, and you visit them at
your own risk. This privacy statement applies solely to PII collected by
us.
5. Minors
If you are a child under the age of 18, you must obtain
parental consent prior to using our Services. We will
not knowingly contact or engage with children under the age of 18 without
parental consent. If you have reason to believe that a child has provided us
with his/her PII,
please contact us at the address given above and we will endeavour to delete
that PII from our databases.
6. PII Sharing
We may share your PII with our affiliates, agents,
representatives and service providers (e.g., Google Maps, HERE Global, SendGrid,
Firebase, Batch and SaaS SMTP provider) and with your employer. We require
these parties to process such information in compliance with this Privacy
Policy and subject to security and other appropriate confidentiality
safeguards. We will
also share PII in the following circumstances: (a) as required for providing
the Services; (b) for posted speed functionality; (c) for remote control
features; (d) for push notifications; (e) for maintenance and improvement of
the Services; (f) if we become involved in a reorganisation,
merger, consolidation, acquisition, or any form of sale of some or all of our
assets, with any type of entity, whether public, private, foreign or local;
and/or (g) to satisfy applicable law or prevention of fraud or harm or to
enforce applicable agreements and/or their terms, including investigation of
potential violations thereof.
7. Data Security and Data Retention
We follow generally accepted industry standards to protect
against unauthorised access to or unauthorised alteration, disclosure, or
destruction of PII. However, no method of transmission over the Internet, or
method of electronic storage, is 100% secure. Therefore, while we strive to use
commercially acceptable means to protect your PII, we cannot guarantee its
absolute security. We keep your PII only for as long as reasonably necessary
for the purposes for which it was collected in accordance with our data
retention policy or to comply with any applicable legal or ethical reporting or
document retention requirements. Without derogating from the foregoing, we will
retain location data for the term of the Services and up to seven (7) years
thereafter.
8. Data Integrity
We process PII only for the
purposes for which it was collected and in accordance with this Privacy Policy
or any applicable service agreements. We review our data collection, storage,
and processing practices to ensure that we only collect, store and process the
PII needed to provide or improve our Services. We take reasonable steps to
ensure that the PII we process is accurate, complete, and current, but we
depend on our users to update or correct their PII whenever necessary. Nothing
in this Privacy Policy is interpreted as an obligation to store information,
and we may, at our own discretion, delete or avoid from recording and storing
any and all information.
9. Your Rights
9.1.
Right of Access and Rectification. You have the right
to know what PII we collect about you and to ensure that such data is accurate
and relevant for the purposes for which we collect it. We allow our users the
option of accessing and
obtaining a copy
of their PII, and to
rectify such PII if it is not accurate, complete, or updated. However, we may
first ask you to provide us certain credentials to permit us to identify your
PII.
9.2. Right to Delete PII or Restrict Processing. You
have the right to delete your PII or restrict its processing. We may postpone
or deny your request if your PII is in current use for the purposes for which
it was collected or for other legitimate purposes such as compliance with legal
obligations.
9.3. Right to Withdraw Consent. You
have the right to withdraw your consent to the processing of your PII. Exercising
this right will not affect the lawfulness of processing your PII based on your
consent before its withdrawal.
9.4. Right of Data Portability. Where
technically feasible, you have the right to ask us
to transfer your PII in accordance with your right to data
portability. You may exercise the above rights by sending a request to dpo@greenroad.com
9.5.
Right to Lodge Complaint. You also have the
right to lodge a complaint with a data protection supervisory authority
regarding the processing of your PII.
10. Enforcement
We regularly review our compliance with this
Privacy Policy. Please feel free to direct any questions or concerns regarding
this Privacy Policy or our treatment of PII by contacting us as provided above.
When we receive formal written complaints, it is our policy
to contact the complaining user regarding his/her
concerns. We will cooperate with the appropriate regulatory authorities,
including local data protection authorities, to resolve any complaints
regarding the transfer of PII that cannot be resolved between the Company and
an individual.
11. Changes to This Privacy Policy
We may update this Privacy
Policy. We will notify you about significant changes in the way we treat PII by
sending a notice to the primary email address specified in your account or by
placing a prominent notice on the Services. We encourage you to periodically
review this Privacy Policy for the latest information about our privacy
practices.
12. Consent to Processing
By providing any PII to us pursuant to this Privacy Policy,
all users fully understand and unambiguously consent to this Privacy Policy and
to the collection and processing of such PII abroad. The server on which the
Services are hosted and/or through which the Services are processed may be located outside of the country from which you
access the Services and/or your
country of residence. Some of the uses and disclosures mentioned in this
Privacy Policy involve the transfer of your PII to various countries around the
world that may have different levels of privacy protection than your country
and will be transferred outside of the European Economic Area. If there is a
transfer of your PII outside the EEA, we
will, in the absence of an EC Adequacy decision relevant to the destination
country or to the transfer, seek to rely on appropriate safeguards such as
entering into appropriate EC approved standard contractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm). By
submitting your PII through our Services, you consent, acknowledge, and agree that we will collect,
use, transfer, and disclose your PII as described in this Privacy Policy.
13. Do Not Track Notices
You are also advised that Company does not respond to
"Do Not Track" signals.
14. Questions
If you have any questions about this Privacy Policy or
concerns about the way we process your PII, please contact us at dpo@greenroad.com.