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   * TRANSPORTATION INTELLIGENCE
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   * SMARTDRIVE PROTECT
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PRIVACY POLICY

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 * PRIVACY POLICY




 * PRIVACY POLICY & NOTICE: INTRODUCTION
 * IMPORTANT INFORMATION & WHO WE ARE
 * THE DATA WE COLLECT
 * HOW WE USE YOUR DATA
 * DISCLOSURES OF YOUR PERSONAL DATA
 * SECURITY
 * NOTICE REGARDING INTERNATIONAL TRANSFERS
 * DATA RETENTION
 * YOUR PRIVACY CHOICES
 * JURISDICTION SPECIFIC INFORMATION
 * EUROPEAN UNION, THE UNITED KINGDOM, & SWITZERLAND
 * UNITED STATES
 * BRAZIL
 * OTHER JURISDICTIONS
 * RIGHTS REQUESTS
 * OUR ACTIONS OVER THE PAST TWELVE MONTHS
 * NOTICE ABOUT PROCESSING OF DATA ON THIS SITE
 * DOCUMENT CHANGE HISTORY

PRIVACY POLICY & NOTICE: INTRODUCTION
 * PRIVACY POLICY & NOTICE: INTRODUCTION
 * IMPORTANT INFORMATION & WHO WE ARE
 * THE DATA WE COLLECT
 * HOW WE USE YOUR DATA
 * DISCLOSURES OF YOUR PERSONAL DATA
 * SECURITY
 * NOTICE REGARDING INTERNATIONAL TRANSFERS
 * DATA RETENTION
 * YOUR PRIVACY CHOICES
 * JURISDICTION SPECIFIC INFORMATION
 * EUROPEAN UNION, THE UNITED KINGDOM, & SWITZERLAND
 * UNITED STATES
 * BRAZIL
 * OTHER JURISDICTIONS
 * RIGHTS REQUESTS
 * OUR ACTIONS OVER THE PAST TWELVE MONTHS
 * NOTICE ABOUT PROCESSING OF DATA ON THIS SITE
 * DOCUMENT CHANGE HISTORY


PRIVACY POLICY & NOTICE: INTRODUCTION

SMARTDRIVE SYSTEMS, INC (collectively referred to as "ENTITY" "we," or "us") is
part of the Solera group of companies. This Privacy Policy and Notice explains
our policy concerning the collection and processing of personal data and
describes privacy rights and how the law protects data subjects. We respect
privacy and are committed to protecting your personal data.  Our websites and
services are not intended for use by minors under the age of 16 and we do not
knowingly collect data relating to children. It is important that you read this
privacy policy together with other notices we may provide on specific occasions
when we are collecting or processing personal data so that you are fully aware
of how and why we are using your data. For example, there are separate privacy
notices for employees and job candidates. Those privacy notices supplement this
policy. You can review specific sections of our policy by selecting a heading
using the sidebar to the left or scroll through our entire policy. 


IMPORTANT INFORMATION & WHO WE ARE

CONTACT DETAILS

SMARTDRIVE SYSTEMS, INC

1500 Solana Blvd, Bldg. 6, Suite 6300, Westlake, TX 76262  Email address:
privacy@solera.com Toll-free phone: +1 (855) 839-8020

Our representative for the countries in EEA, EU and Switzerland: Marco Iriarte,
who can be reached at privacy@solera.com.

CHANGES. This privacy policy may be updated from time to time. We will provide
the updated policy on our website and a summary of material changes. Please keep
us informed if your personal data changes during your relationship with us. We
realize that it is important that the personal data we hold about you is
accurate and current.

THIRD-PARTY LINKS. Some of our websites and services may include links to
third-party websites, plug-ins, and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible
for how they process personal data. We encourage you to read the privacy notice
of every website you visit.


THE DATA WE COLLECT

The types of personal data we obtain about you depends on how you interact with
us and our products and services. 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, such as anonymous
data. We follow the law in each applicable jurisdiction in determining what
constitutes personal data. The following are the categories and specific types
of personal data that you provide to us directly or that we collect
automatically. 

When you use our public websites such as the website where you accessed this
policy: We may collect Internet or other technical and usage data including but
not limited to IP address, browsing history, and referring websites. Some
collection is through cookies. You may also choose to provide your contact
information for us to communicate with you about our products and services. 

When you use our products or services including websites that require a log-in:

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

 * Identification Data such as a name, alias, phone number, address, unique
   identifiers, account name, social security number, driver’s license number,
   passport number, or other similar identifiers.
 * Financial Data such as bank account, credit card and debit card numbers, and
   other financial information.
 * Commercial Transaction Information such as records of personal property,
   products or services purchased, obtained, or considered, or other purchasing
   or consuming histories or tendencies.
 * Technical and Usage Data such as internet protocol address, login data,
   browser type and version, data on devices used to access a website, service
   or application, browsing history, and search history. how you use our website
   or service. 
 * Geolocation Data such as latitude and longitude of your location.
 * Sensing Information such as audio, electronic, visual, thermal, olfactory, or
   similar info.
 * Employment Information such as work experience or profession
 * Education Data such as information about schooling, training and professional
   certifications 
 * Inference Data such as information drawn from other information reflecting
   preferences, characteristics, psychological trends, predispositions,
   behaviour, attitudes, intelligence, abilities, and aptitudes.
 * Medical Data such as information on health conditions and treatment.
 * Marketing and Communications Data such as your preferences in receiving
   marketing from us and  third parties and your communication preferences.
 * Vehicle Data such as vehicle registration and licensure, vehicle
   identification number, vehicle pictures, damage info and repair and
   maintenance records.

We also collect, use, and share Aggregated Data that is derived from personal
data but does not identify a person. For example, we may aggregate Technical and
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 a person, we treat the
combined data as personal data which will be used in accordance with this
privacy policy.

We collect Special Categories of Personal Data, such as race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, criminal convictions and offenses. It is
collected only where required to provide services or comply with a legal
obligation.  

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 you and you do not provide
that data, we may not be able to enter into or perform a contract with you. In
this case, we may have to cancel a product or service you have with us, but we
will notify you if this is the case at the time.


HOW WE USE YOUR DATA

Personal Information collected through our public websites such as the website
where you accessed this policy: We will use the personal data we collect to
administer our websites, for internal operations, data analysis and to improve
our websites. We may also use personal information for direct marketing or other
specific purposes made clear to you at the time you submit your personal
information on our website. Our use of your Personal Information may be based on
our legitimate interests to ensure network, information security, and business
performance improvement. Our direct marketing purposes are based on your
consent. We may also rely on our legitimate interests to improve business and
marketing practices or contact you to offer similar Services or products that
you may have bought from us, requested a demo, or negotiated with us.

Personal Information collected by our Products and Services including websites
that require log-in: We will only use your personal data as permitted by law.
Most commonly, we will use your personal data in the following circumstances:

 * Where we need to perform the contract we are about to enter into or have
   entered into with you.
 * Where it is necessary for a legitimate interest and your interests and
   fundamental rights do not override those interests.
 * Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your
personal data other than in relation to marketing communications.. You have the
right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA: We may provide additional
notices to you of the purpose of and basis for collecting the data. In general,
we collect information for purposes and on the bases shown below:

Purpose of Collection

Lawful basis for processing

To provide services to you or your employer

Performance of a contract

Our legitimate business interests (to contact you in relation to a contract with
your employer)

To manage payments and recover money owed to us

Performance of a contract

Our legitimate business interests (to recover claims) 

To display interactive content

Performance of a contract

To provide customer service

Performance of a contract

Our legitimate business interests (to record service provided

Comply with legal obligations

For marketing activity and to enable you to participate in competitions 

Performance of a contract

Our legitimate business interests (to improve our services and analytics)

Comply with legal obligations

Consent

Administer and protect our business

Our legitimate business interests (to conduct and manage our business in a
secure way and to give you the best services and the best and most secure
experience)

Comply with legal obligations

Data analytics

Our legitimate business interests (to improve our products and services)

To make recommendations to you about goods and services that may be of interest

Our legitimate business interests (to develop our products and services and grow
our business)

To provide promotional offers

In order to take steps at your request prior to entering into a contract 

Consent

 * Legitimate business interest means the interest of our business that does not
   override your interests or fundamental rights and freedoms. We make sure to
   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. 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 or your employer are a party or to
   take steps at your request before entering into such a contract.
 * Comply with a legal obligation means processing your data where it is
   necessary for compliance with a legal or regulatory obligation that we are
   subject to.

MARKETING COMMUNICATIONS: You will receive marketing communications from us if
you have requested information from us or purchased goods or services from us or
if you provided us with your details when you entered a competition or
registered for a promotion and, in each case, you have not opted out of
receiving that marketing. We will get your express opt-in consent where required
by law. 

CHANGE OF PURPOSE. We will only use your personal data for the purposes for
which we collected it, unless we reasonably consider that we need to use it for
another purpose that is compatible with the original purpose. For an
explanation, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify
you and we will explain the legal basis which allows us to do so. We may process
your personal data without your knowledge or consent as permitted by law.


DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with:

 * Other companies in the Solera group of companies who are involved in
   providing the service or product or provide IT and system administration
   services and information reporting.
 * Our customers who are providing services to you.
 * Our service providers who provide IT and system administration services or
   product support.
 * Our professional advisers such as lawyers, bankers, auditors, and insurers.
 * Government agencies, when required by law
 * Third parties to whom we sell, transfer, or merge parts of our business or
   our assets or where seek to acquire other businesses or merge with them. If a
   change happens to our business, the new owners may use your personal data in
   the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and
to treat it in accordance with the law. We do not allow our third-party service
providers to use your personal data for their own purposes and only permit them
to process your personal data for specified purposes and in accordance with our
instructions.


SECURITY

We have put in place appropriate security measures to prevent your personal data
from being accidentally lost, used or accessed in an unauthorized way, altered,
or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors, and other third parties who have a business
need-to-know. They will only process your personal data on our instructions, and
they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach
and will notify you and any applicable regulator of a breach where we are
legally required to do so.


NOTICE REGARDING INTERNATIONAL TRANSFERS

Personal data may be transferred from the country where it was collected to
other countries where Solera’s group of companies operate. This means, for
instance, that personal data may be transferred from the EEA, UK, Switzerland,
and Brazil to the United States, Mexico, and India for processing.  Any
transfers will be in compliance with applicable law. We will be liable for
onward transfers to third parties. 

If the processing of your personal data is subject to data protection
regulations concerning international transfers, we will ensure that any
international or onward transfer is consistent with applicable law such as
standard contractual clauses approved by an appropriate regulatory authority. We
may also rely on an adequacy decision of the regulatory authority such as the
European Commission confirming an adequate level of data protection in the
jurisdiction of the party receiving the information.

We comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK
Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We have
certified to the U.S. Department of Commerce that we adhere to the Data Privacy
Framework Principles with regard to the processing of personal data received
from the European Union, the UK (and Gibraltar) and Switzerland. If there is any
conflict between the terms in this privacy policy and the relevant Data Privacy
Framework Principles, the Principles shall govern. To learn more about the Data
Privacy Framework program, and to view our certification, visit the U.S.
Department of Commerce's Data Privacy Framework website. The U.S. affiliates of
Solera, namely Audatex North America, LLC, Claims Services Group, LLC,
DealerSocket, LLC, Distribution Service Technologies, LLC, DMEautomotive LLC,
eDriving Fleet LLC, eDriving LLC, eDriving Telematics LLC, Enservio, LLC,
Explore Information Services, LLC, GTS Services, LLC, Hollander, LLC,
HyperQuest, LLC, Identifix, LLC, LYNX Services, LLC, Mobile Productivity, LLC,
Omnitracs, LLC, RedCap Technologies, LLC, Roadnet Technologies, Inc., SmartDrive
Systems, Inc., Spireon, Inc., Title Technologies, LLC, Transportation
Performance, LLC, XRS Corporation, also adhere to the EU-U.S. Data Privacy
Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S.
Data Privacy Framework.

We commit to resolve DPF Principles-related complaints about our collection and
use of your personal data.   EU and UK individuals and Swiss individuals with
inquiries or complaints regarding our handling of personal data received in
reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the
Swiss-U.S. DPF should first contact us via our web form. You have an option to
invoke binding arbitration by delivering notice to us and following the
procedures and subject to conditions set forth in Annex I of the Data Privacy
Framework Principles. 

We commit to cooperate and comply respectively with the advice of the panel
established by the EU Data Protection Authorities and the UK Information
Commissioner's Office and the Swiss Federal Data Protection and Information
Commissioner with regard to unresolved complaints concerning our handling of
personal data received in reliance on the EU-U.S. DPF and the UK Extension to
the EU-U.S. DPF and the Swiss-U.S. DPF.

We are subject to the investigatory and enforcement powers of the Federal Trade
Commission (FTC).  


DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements. To determine the appropriate
retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorized
use or disclosure of your personal data, the purposes for which we process your
personal data and whether we can achieve those purposes through other means, and
the applicable legal requirements.


YOUR PRIVACY CHOICES

You may opt not to disclose information to us. Some of your information,
however, may be required in order to use our products or services. Additional
information regarding your privacy rights can be found below in the
“Jurisdiction Specific Information” section.

MARKETING COMMUNICATIONS. You can ask us to stop sending you marketing messages
at any time. Opting out of marketing messages will not affect our processing of
your personal data for non-marketing purposes, such as providing a product or
service to you, warranty registration, the product or service experience, or
other transactions.

COOKIES. You can make choices about what cookies collect information on our
websites. You may be able to set your browser to refuse all or some browser
cookies. If you disable or refuse certain cookies, some parts of the website may
become inaccessible or not function properly.


JURISDICTION SPECIFIC INFORMATION

You may have certain rights available to you when it comes to your personal
information. Below is a summary of those rights.


EUROPEAN UNION, THE UNITED KINGDOM, & SWITZERLAND

Data Subjects may, depending on applicable law, have some or all of the
following rights: 

 * Right of access-  You have the right to obtain confirmation as to whether or
   not personal data concerning you is being processed, and, where that is the
   case, access to the personal data and to know what data is being processed,
   the purpose of the processing, as well as the origin of such data and the
   communications made or planned for such data. 
 * Right to rectification- You have the right to obtain without undue delay the
   rectification of inaccurate personal data concerning you. Taking into account
   the purposes of the processing, you shall have the right to have incomplete
   personal data completed, including by means of providing a supplementary
   statement.
 * Right to erasure (‘right to be forgotten’)-  You have the right to obtain the
   erasure of personal data concerning you without undue delay and the
   controller shall have the obligation to erase personal data without undue
   delay where one of the following grounds applies.
 * Right to restriction of processing- You have the right to obtain restriction
   of processing.
 * Right to data portability- You have the right to receive the personal data
   concerning you, which you have provided to a controller, in a structured,
   commonly used and machine-readable format and have the right to transmit
   those data to another controller without hindrance from the controller to
   which the personal data have been provided.
 * Right to object or to withdraw consent- You have the right to object, on
   grounds relating to your particular situation, at any time to processing of
   personal data concerning you.
 * Automated individual decision-making, including profiling- You have the right
   not to be subject to a decision based solely on automated processing,
   including profiling, which produces legal effects concerning you or similarly
   significantly affects.

To exercise your rights please apply directly through  the link below in the
"Rights Requests" section. If you believe that we have not processed your
personal data in accordance with regulations, you can contact our Privacy
Department at privacy@solera.com. You are entitled to submit a complaint to the
Data Protection Agency in your country, you can find a list of EU contacts here:
https://edpb.europa.eu/about-edpb/about-edpb/members_en. 


UNITED STATES

In some States, you may have certain rights when it comes to your personal data
including: 

• The right to access the personal data we have collected about you over the
last 12 months and the way we use and disclose your information and confirm our
processing of your information

• The right to request a copy of the personal data we have collected about you

• The right to delete data we have collected about you

• The right to correct the personal data we have collected about you

• The right to port or transfer a copy of the personal data we have collected
about you in a structured, commonly used and machine-readable format

• The right to opt-out of automated decision-making which significantly impact
your rights where a decision is made using an electronic system without human
involvement. No decision will be made by us about you solely on the basis of
automated decision making which has a significant impact on you

• The right to be free from discrimination for exercising your
rights (non-discrimination)

• The right to appeal our decision related to your rights request by sending us
an email marked “Appeal”     

We do not currently respond to “Do Not Track” signals. 

Under certain circumstances, California residents may also have right to use an
authorized agent to make a request under CPRA on your behalf. You must provide
us with written documentation that the agent is authorized to act on your behalf
or a power of attorney. We may also contact you directly to verify your
identity.

NOTICE REGARDING SALE & SHARING OF PERSONAL DATA FOR TARGETED ADVERTISING

In some states, residents have the right to opt-out of having their personal
data sold or shared for targeted advertising purposes.  We do not sell or share
personal information as defined under applicable data protection laws and have
not done so within the last 12 months.


BRAZIL

Whenever the processing operation is carried out in Brazil, the purpose of the
processing activity is to offer or provide goods or services or the processing
of data of individuals located in Brazil; or the personal data being processed
were collected in Brazil according to Section 3 of LGPD (“LGPD Data”), this
Policy shall governed according to: (i) the General Data Protection Law, no.
13,709/2018 (hereinafter the "LGPD"), (ii) the Constitution of the Brazilian
Federative Republic, article 5, item LXXII; (iii) the Habeas Data Law
(hereinafter "Habeas Data"), no. 9,507/1997; and, finally, the (iv) Internet
Civil Rights , Law No. 12,965/2014.

When processing LGPD Data, the following principles shall apply:

 * Purpose: Personal Data collected must be used for a lawful, legitimate,
   specific and explicit purpose, which must be informed in advance, in a clear
   and sufficient manner; 
 * Adequacy: Processing of Personal Data compatible with the informed purpose;
 * Need: Limitation of the processing to the minimum necessary for the
   accomplishment of its purposes, with the scope of the relevant, proportional
   and non-excessive data in relation to the purposes of the processing of data;
 * Free Access: facilitated and free of charge consultation about the form and
   duration of the processing, as well as about the integrity of their personal
   data;
 * Quality: accuracy, clarity, relevance and updating of the data, according to
   the need and for the fulfillment of the purpose of its processing;
 * Transparency: clear, accurate and easily accessible information about the
   carrying out of the processing and the respective processing agents, subject
   to commercial and industrial secrecy;
 * Security: use of technical and administrative measures to protect Personal
   Data from unauthorized access and accidental or unlawful situations of
   destruction, loss, alteration, communication or disclosure;
 * Prevention: Adoption of measures to prevent the occurrence of damage due to
   the Processing of Personal Data;
 * Non-discrimination : Impossibility of processing for unlawful or abusive
   discriminatory purposes;
 * Accountability: adoption of effective measures capable of proving compliance
   with the rules of protection of Personal Data and the effectiveness of these
   measures;

When we process your LGPD Data, you are entitled to:

 * Obtain confirmation of the existence of processing.
 * Free access to your Personal Data that has been processed, as provided in
   Section 9 and 18 of the LGPD.
 * Correction of incomplete, inaccurate or outdated Personal Data.
 * Anonymization, blocking or deletion of unnecessary, excessive or processed
   data in non-compliance with the provisions of the LGPD.
 * Portability of Personal Data to another service provider or product, upon
   express request, in accordance with the regulations of the ANPD, in
   compliance with trade and industrial secrets.
 * Deletion of Personal Data processed with your consent, except in the cases
   provided for in Art. 16 of the LGPD;
 * Information of public and private entities with which we have shared your
   Personal Data;
 * Information on the possibility of not providing consent and on the
   consequences of such a denial;
 * Withdrawal of consent, pursuant to § 5 of Section 8 of the LGPD;
 * Submit to the ANPD complaints for violations of the provisions of the
   Applicable Regulations and the other rules that modify, add or supplement it,
   on the basis of § 1 of Section 18 of the LGPD.

DATA RETENTION: How Long Will You Use My Personal Data?

We will only retain your personal data for as long as necessary to fulfill the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements. To determine the appropriate
retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorized
use or disclosure of your personal data, the purposes for which we process your
personal data and whether we can achieve those purposes through other means, and
the applicable legal requirements.

Details of retention periods for different aspects of your personal data are
available in our retention policy which you can request from us by contacting
us. More specifically, and without limiting the generality of the foregoing, by
law we have to keep basic information about our customers for at least 5 years
after they cease being customers for tax, financial auditing, and record keeping
purposes.


OTHER JURISDICTIONS

You may have rights under data protection laws in relation to your personal
data. Contact us for more information.


RIGHTS REQUESTS

If you wish to exercise any of the rights set out above, please fill out the
webform here: EXERCISE YOUR RIGHTS. California residents may also contact us
using the contact information above. See Privacy Requests Statistics for how we
handle California privacy requests. 

When you make a Rights Request, 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. If your request provides an email address, or our records
contain your email address, we may ask you to verify your identity through such
address. Where additional information is required, we try to ask only
information that can be corroborated through our records. We may also ask you
for further information in relation to your request to speed up our response.

We will keep a record of rights requests and responses for at least twenty-four
months in a log that will not be used for any purpose other than for
record-keeping and analytics.


OUR ACTIONS OVER THE PAST TWELVE MONTHS

The following table provides additional information on the personal information
collected in the last twelve months:

Categories of Personal Information collected

Categories of Sources of such Personal Information

Purpose for which the Personal Information was collected

Categories of third parties with whom the Personal Information is shared

Identification Data

 * Direct interaction with you
 * Customers for whom we provide services, and their agents
 * Vendors who provide us services
 * Other companies in the ENTITY group

 * Provide you or our customers with services
 * Comply with legal obligations

 * Customers for whom we are a service provider
 * Vendors who provided us services
 * Vendors who provided an element of our services
 * Other companies in the ENTITY group
 * Industry organizations who required it to provide information used in our
   services

Financial Data

 * Direct Interaction
 * Use of our service
 * Customers who use our services
 * Vendors such as background check companies

 * Provide services to our customers
 * Comply with legal obligations
 * For internal business purposes such as fraud detection

 * Vendors who provided us professional assistance such as lawyers and
   accountants
 * Government and regulatory agencies

Commercial Transaction Data

 * Direct Interaction
 * Customers who use our services

 * Provide our services
 * Comply with legal obligations

 * Vendors who provided us services
 * Vendors who provided an element of our services

Vehicle Data

 * Direct Interaction
 * Customers who used our services
 * Other companies in the Omnitracs group
 * Vendors who provide us services

 * Provide services to our customers
 * Comply with legal obligations
 * Analytics

 * Customers for whom we are a service provider
 * Vendors who provided us services
 * Vendors who provided an element of our services
 * Other companies in the ENTITY group
 * Government agencies who provide information required for our services or for
   legal compliance

Technical Data

 * Interaction with devices that accessed our services
 * Other companies in the ENTITY group
 * Vendors who provide analytics and other services

 * Security and troubleshooting
 * To perform services
 * To improve our products and services

 * Vendors who provide us services
 * Customers of our services
 * Other companies in the ENTITY group

Usage Data

 * Interaction with our services
 * Vendors who provide analytics and other services

 * Security and troubleshooting
 * To improve our products and services

 * Other companies in the ENTITY  group
 * Vendors who provide us services including analytics

Geolocation Data

 * Direct Interaction through our services
 * Through content uploaded in our services
 * From devices used by our employees and dedicated contractors

 * Security and fraud detection
 * To provide services
 * To improve our products and services
 * To provide analytics

 * Vendors who provide an element of our services
 * Vendors who provide professional services such as security and fraud
   detection
 * Other companies in the Omnitracs group

Sensing Data

 * Direct interaction through our contact centers
 * Through devices used by our workforce and at our offices

 * To provide services
 * Security and fraud detection

 * Vendors who provide us services
 * Other companies in the Omnitracs group

Employment Data

 * Direct interaction with our services
 * Direct interaction with you
 * Vendors who provide us services

 * To provide services
 * Security and fraud detection
 * To comply with legal obligations
 * For human resources

 * Vendors who provide us professional services
 * Customers of our services
 * Other companies in the ENTITY  group
 * Government and regulatory agencies

Education Data

 * Direct interaction with you
 * Vendors who provide us services

 * Security and fraud detection
 * To comply with legal obligations
 * For human resources

 * Vendors who provide us professional services
 * Other companies in the ENTITY group
 * Government and regulatory agencies

Inference Data

 * Through our services
 * Direct interaction with you

 * To provide analytics
 * To improve our products and services

 * Customers of our services
 * Vendors who provide us professional services
 * Other companies in the ENTITY group

Medical Data

 * Direct interaction
 * Employees
 * Vendors providing services relating to employment benefits and obligations

 

 * Provide employee benefits and process claims
 * Legal and regulatory obligations

 * Vendors providing employment and benefits services
 * Professional advisors such as insurers and lawyers

Marketing and Communications Data

 * Direct interaction with you
 * Customers for whom we provide services, and their agents
 * Other companies in the ENTITY Group

 * Provide you or our customers with services or information requested
 * Comply with legal obligations

 * Vendors who provided us services
 * Other companies in the ENTITY  group


NOTICE ABOUT PROCESSING OF DATA ON THIS SITE

This notice explains how we collect and process personal data through your use
of this website. This notice should be read in conjunction with our Privacy
Statement above and may be updated by us from time to time.  This site may
collect personal data through cookies or other technology.  You can make choices
about what cookies are allowed to collect and process information by clicking on
the "Cookie Preferences" button at the bottom of the website.  This website may
also offer you the opportunity to learn more about products by providing your
contact information through a webform.  Any contact information you enter may be
used to contact you about our products and services.  More information about
processing personal data may be provided on certain website pages.


DOCUMENT CHANGE HISTORY

December 2023: Added a notice concerning processing of data on this website,
updated "The Data We Collect" and "Our Actions Over the Past Twelve Months"
sections, updated "Notice Regarding International Transfers" and "Disclosures Of
Your Personal Data" sections to conform to the DPF Principles, and added a link
to California disclosures. 










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SmartDrive Systems gives fleets and drivers unprecedented driving performance
insight and analysis, helping save fuel, expenses and lives. Its video safety,
predictive analytics, telematics, compliance and personalized performance
program help fleets improve driving skills, lower operating costs and deliver
significant ROI.

© 2024 SmartDrive Systems, Inc. All rights reserved. SmartDrive, the SmartDrive
logo and SmartDrive SmartIQ® are registered trademarks of SmartDrive Systems,
Inc. SmartRecorder, SmartChoiceTM, SmartAlliance and SR4 are trademarks of
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owners.

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