1. Scope of the Policy
This Policy describes how we collect, use and disclose personal data when you use the following:
- Any website that FleetCarma operates and which displays or links to this Policy (“website(s)”), www.fleetcarma.com.
- SmartCharge Rewards, a web based utility load management program for EV owners.
- FleetCarma Portal, a web based fleet management solution for fleet managers and EV researchers.
For the purposes of this Policy, personal data means information or data relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly, or indirectly, by reference to an identification number or to one or more factors that indicate their identity.
Individuals who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this document.
Our website may contain links to other websites that are operated by third parties. This Policy does not apply to those websites. We strongly suggest that you carefully review the privacy policies and statements of any third-party websites to properly understand their information practices.
2. Information Provided to FleetCarma
The FleetCarma website may also use web beacons, tags, and scripts or use them in email or other electronic communications we send to you. These assist us in sending cookies and counting visits to our website while helping us understand usage and the effectiveness of various campaigns and promotions. Furthermore, we may receive and develop reports based on the use of these technologies by our third party service providers on an individual and aggregated basis.
Information in SmartCharge Rewards is either entered by you when setting up your account, is collected if you contact our customer support team, or is collected via devices you authorize to send us data about your electric vehicle usage, including but not limited to telematics devices connected to the OBD2 port of your vehicle, networked vehicle charging equipment, or the vehicle’s internal telematics system.
To use SmartCharge Rewards, you must set up a SmartCharge Rewards account and provide us with certain information such as name, address, phone number, email address.
We also collect information about user activities in SmartCharge Rewards. SmartCharge Rewards provides Customers with the ability to obtain, among other types of data, charging and driving details for their vehicle and can facilitate payments to the user, however we will not retain banking or financial information for the user.
We may also ask for and collect personal data from individuals who register for or attend events sponsored by FleetCarma or its affiliates. Such data may include your name, address, phone number, and email.
Social Media Widgets
The FleetCarma website includes social media features such as the Facebook “Like” and “Share” buttons as well as mini-programs that run on our website. These features may collect your internet protocol address (IP address), which webpage you are visiting, and may set a cookie to enable the feature to function properly. The use of such features is governed by the privacy policies of the feature owner.
3. Use of Information
Device and Vehicle Data
If you drive a vehicle connected to the FleetCarma products listed above, we receive personal data about you to the extent you provide such personal data to us. We process such personal data in accordance with our Customer’s written instructions or as required by applicable law. To the extent that personal data about you may be inferred from technical vehicle information collected from the device, we process such personal data in accordance with this Policy.
If you created a SmartCharge Rewards account, we use your personal data to provide, maintain, improve, and promote the SmartCharge Rewards Solution. We may also use personal data to send Customers transactional messages in order to respond to comments, questions, and requests or to distribute important Customer information.
FleetCarma’s Website, Communications and Support
We also use your personal data to provide customer service and support. Such support may include technical notices, updates, security alerts, and administrative messages. Where permitted by applicable law, we may also send you promotional communications from time to time to inform you of products, services, features, surveys, newsletters, offers, promotions, contests, and events. Information and news about our partners may also be communicated from time to time.
You can opt out of marketing communications at any time by contacting us at email@example.com or following the unsubscribe or opt-out instructions included in our marketing communications.
If you applied for a job position through our website, we may provide your data to a third party service provider to assist us in managing your application. The job application data you provided to us may also be used or accessed from any of FleetCarma’s locations depending on the nature of the position.
Additionally, we use the information to monitor and analyze trends, usage, and activities in connection with our website and Customer accounts in order to investigate and prevent fraudulent transactions, unauthorized access to FleetCarma products, and other illegal activities. We may also use personal data for any other purpose for which we have obtained your consent or where permitted or required by applicable law.
Data Science and Analytics
We extract vehicle data using either the FleetCarma C2 device, GO device, or 3rd party device that you connect with our platform and may aggregate it through Google’s BigQuery enterprise data warehouse or Azure. Aggregated data sets do not contain personal data and cannot reasonably be used to identify an individual. If Information processed using BigQuery is carried out on servers located in the United States and information processed through Azure remains within the United States unless otherwise specified in our contract with the Customer.
4. Sharing of Information
FleetCarma may share information, including personal data, with our third party service providers that we engage for providing hosting, for maintenance of our websites, applications, backup, storage, payment processing, customer support, analytics, and other services. We do not allow our service providers with whom we share personal data to use that information for marketing or any other purpose other than in connection with the services they provide to us. See Exhibit “A” below for more information.
Complying with the Law and Law Enforcement Requests
In some circumstances, we may receive a request from public authorities to disclose personal data in response to a legally binding request to meet national security or law enforcement requirements. As applicable, we may disclose personal data to comply with subpoenas, court orders, or legal process, or to enforce our legal rights and defend against legal claims. In some cases, we may also share personal data if we believe that illegal or fraudulent activity is or has taken place so that we can investigate, prevent, and take appropriate action regarding such activities that may pose a potential threat to the physical safety of any person, violations of our Customer agreements, or to comply with the law. If your personal data becomes subject to a legal disclosure requirement and we are permitted to do so, we will attempt to notify you of said disclosure, if we have current contact information on file.
FleetCarma Internal Sharing
We may share information, including your personal data, within the Geotab group of companies.
From time to time, we may post success stories on our website or in other publicly distributed material that contains personal data. In such cases, we obtain your written consent before posting your name or other personal data with the success story. If you wish to delete or remove your success story, you can contact us at firstname.lastname@example.org.
Sharing with Consent
We may also share information with third parties when you have provided us with your consent to do so.
5. International Transfers of Data
FleetCarma stores data about website visitors, Customers, and resellers on cloud servers located in North America. We may also store data on cloud servers located in other countries from time to time. FleetCarma operates on a global scale and we may transfer and access such personal data from various parts of the world, including from other countries where we have Customers and operations. FleetCarma stores North American Customer data on servers within North America. However, data (including personal data) may be transferred across national boundaries for load balancing, availability, or other reasons.
6. Communication Preferences
You can choose how we use your personal data to communicate with you through our website, SmartCharge Rewards Solution, or email. You can manage your receipt of marketing and non-transactional communications by clicking an unsubscribe link in emails received from us or you may send a request to email@example.com.
7. Correcting, Updating, and Removing Your Information
Customers may change or update the information associated with their SmartCharge Rewards accounts by logging into these services and editing their profile. You may request to have personal data that we maintain returned or removed by contacting our Customer support department or firstname.lastname@example.org. FleetCarma reserves the right to validate requests to ensure legitimacy. Valid requests will typically be handled within 30 days.
We retain personal data that we store and process on behalf of Customers, resellers, and website visitors for as long as necessary to provide products and services to the Customer. Information (including personal data) will be retained and used as necessary to enable us to comply with our legal obligations, resolve disputes, support our Customers and resellers, and to comply with and enforce our agreements.
We take the security of your personal data very seriously and follow generally accepted technological and organizational measures to safeguard such information. We do this when the information is in transit, in use, and at rest.
We will retain your personal data for as long as needed to fulfill the purposes for which the data was provided. We will delete or anonymize your personal data when we no longer have a legitimate business need for it. If it is no longer possible to delete it because, for example, it has been backed up in archives, then we will securely store the personal data and isolate it from further processing until deletion is possible.
For personal data that we process on behalf of resellers and customers users, we will retain such personal data in accordance with the terms of our agreement with them, subject to applicable laws.
Additional Rights for California and Certain Other Jurisdictions
If you reside in certain other jurisdictions, you have the right to exercise additional rights available to you under the local law that applies to you:
- Right of erasure: you may have a broader right to have personal data that we hold about you erased or deleted.
- Right to object to processing: you may have the right to request that we stop processing your personal data.
- Right to restrict processing: you may have the right to request that we limit the processing of your personal data in some circumstances (e.g. where you believe that the personal data we hold about you is inaccurate or was obtained unlawfully).
- Right to data portability: in some limited circumstances, you may have the right to receive a copy of your data in machine readable, commonly used format and to request that we transfer personal data to another controller.
In the event you would like to inquire about exercising these rights, you may contact our privacy officer by emailing us at email@example.com. In order to protect your privacy and that of others, we may take steps to verify your identity and the validity of your request before we comply.
You also have the right to communicate with a data protection authority about our collection and processing of your personal data. You may contact your local data protection authority for more information.
8. Children’s Personal Data
We do not knowingly or intentionally collect or process any personal data from children under the age of 13. If you are under the age of 13, do not submit any personal data through our website or the SmartCharge Rewards Solution. Parents and legal guardians are encouraged to monitor their children’s internet use and assist in helping us enforce this Policy by teaching their children never to provide personal data through our website or the SmartCharge Rewards Solution. If you have reason to believe that we may have been sent personal data of a child under the age of 13, contact us at firstname.lastname@example.org and we will use reasonable efforts to delete such information.
9. Assignment or Transfer
If FleetCarma was to sell or divest all or substantially all of our business, stock, or assets with another entity, we may assign or transfer this Policy as well as your account and related data (including personal data) in accordance with applicable law.
10. Changes to This Policy
If we make any changes to this Policy, we will post an updated policy on our website. You should periodically review this page for the latest information on our privacy practices. The updated Policy will become effective as of the date stated in the Policy and following any additional steps we may be required to take under applicable law.
11. Supplemental Terms and Conditions for Certain Regions
FleetCarma complies with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canadian Anti-Spam Legislation (CASL), and other applicable provincial and federal laws regarding the data we process, collect, store and use to provide the SmartCharge Solution. Canada’s data protection standards have been deemed adequate by the EU.
California Consumer Privacy Act (CCPA)
For the purposes of the CCPA, FleetCarma neither “buys” personal data from you, nor does FleetCarma “sell” personal data to other companies. To the extent that we receive personal data from you this data is received and used for the purpose of providing a service to you. To the extent that FleetCarma uses other companies to assist with processing activities (“sub-processors”) and provides them with personal data for this purpose, these companies are in turn considered “service providers” to FleetCarma. Accordingly, FleetCarma relies on the provisions in the CCPA that specifically allow for the “provision of a service” as distinct from “selling data.”
12. How to Contact Us
If you have questions about this Policy or about our privacy practices, you can contact us by email at email@example.com or at:
FleetCarma., Division of Geotab
Attn: Dirk Schlimm, Chief Privacy Officer
137 Glasgow Street, Unit 340
N2G 4X8, Canada
13. English Version Controls
Non-English translations of the Policy, if any, are provided for convenience only. If any ambiguity or conflict exists between such other translations, this English version will be held as the authoritative version.
Exhibit “A” – Sub-Processors
|Sub-Processors Used by FleetCarma to Support SmartCharge Rewards, Recruitment activities, and Website||Operation/Purpose|
|Google Cloud Platform|
|G-Suite||Various Program specific docs, email|
|Salesforce.com||Participant and Customer data (includes participant PII), support cases|
|MailChimp||Transactional and marketing emails|
|RingCentral||Voicemail messages and they translate to text.|
|Mixpanel||For product usage analytics|
|Formstack||Program applicant information|
|Auth0||Authentication for SmartCharge Rewards portal login|
|PowerBI Pro – Cloud and Desktop||For internal dashboards
For external report generation
|Microsoft Azure||Cloud services|
|Microsoft Dynamics 365||Names, addresses, emails, phone numbers|
|Google Analytics||For website analytics and tracking|
|Unleashed||Order fulfillment, shipping addresses, names|
|Pardot||Transactional and marketing emails|
|Google BigQuery||Raw device data|
|Tango Card||Name and email address – provided directly by the user|
|USPS||Address validation for shipping and order fulfillment
Also names, addresses, emails, and phone numbers for delivering our shipments.
|NHTSA VIN Decoder||Full Vehicle Identification Number|
|Atlassian JIRA||Tickets sometimes have user information if they are related to support cases or data quality issues|
|Ship Central Fulfillment
(using Veracore system)
|Names, addresses, emails, phone numbers.|
|Simtech Supply Chain Management
(using System Logic system, CLOUDconnect Portal, and Simtech’s FTP)
|Names, addresses, emails, phone numbers.|
|UPS||Names, addresses, emails, and phone numbers for delivering our shipments.|
|Orbital Installation Technologies||Names, addresses, emails and/or phone numbers for installation services|