Telematics and Dashcam Privacy Notice | Trakm8

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Telematics and Dashcam Privacy Notice

The Trakm8 Group are committed to respecting and protecting your privacy


This privacy policy tells you what to expect when Trakm8 collects and processes your personal data.


It is very important that you read this in full so that you understand what information we collect from you and from the Telematics device fitted to your vehicle(s) and how we then process this information as part of the Service we provide.


This notice should be read in conjunction with the Privacy Notice provided by the Contracting Entity.

Phrases which start with capital letters (such as “Privacy Notice”) are defined in the Definitions section at the end of this notice.

Note that, Drivers must ensure that any Nominated Driver and/ or Associated Person (e.g. car mechanic) is informed that a Telematics device is fitted to the vehicle and advise them of this policy.

Note also that, Drivers must make a copy of this policy available to a Nominated Driver or Associated Person on request.

Where you have any concerns about the information collected or how your information may be used, you should discuss in the first instance with the relevant individual within your organisation.

Revisions to this Privacy Policy


As the needs of the business develop, there may need to be revisions to this Privacy Policy.

Controller / Processor status


Under Data Protection legislation, Trakm8 Ltd operates as both a Data Processor and a Data Controller of your personal information in conjunction with the Contracting Entity (normally your employer, the vehicle owner or your insurer).

The Contracting Entity will also be a Data Controller under Data Protection legislation.

The Contracting Entity are responsible for defining the Purpose for processing your personal information and for ensuring a Lawful Basis for that processing. Trakm8 are responsible for determining what information to collect from the telematics or dashcam device in order to fulfil the stated purpose.

Typically, retention periods for data are defined by the Contracting Entity as part of the contractual agreement, to reflect the Contracting Entity’s legal and organisational requirements.

Enquiries relating to the Retention of data should be directed to the relevant person at the Contracting Entity in the first instance.

Trakm8 may retain data for a longer period where we deem it necessary to reflect our own legal and organisational requirements.

Lawful Basis


Trakm8 and our partners will collect, process and will pass this information to the Contracting Entity under our Legitimate Interests in order to provide the Service.

The Contracting Entity will have their own, separate Lawful Basis for their initial collection and processing of personal data and the subsequent processing of the information provided by Trakm8.

Enquiries relating to the Contracting Entity’s Lawful Purpose should be directed at the relevant individual within your organisation

What data do we collect when you register for our Services?


When registering for our Service, we will typically collect such information as may be required to set up and deliver the Service. This information may include such items as:

• Contact Name
• Company Name
• Vehicle Registration(s)
• Billing Information such as bank account and sort code
• Billing Address
• Work Address
• Driver Names

Note that this information may be collected directly from the Data Subjects or may be provided to Trakm8 Group by the Contracting Entity.

What data do we collect from the telematics/dashcam device?


Once the telematics device has been installed and activated, it will record and analyse data relating to the vehicle to which it has been fitted.

Depending on the specific unit fitted and the instructions from the Contracting Entity, the telematics device will collect driver behaviour related information such as:

• Vehicle Data: Registration, VIN, make, model etc.
• Journey Data: GPS location, time and date, direction, speed, acceleration/deceleration rates etc.

Note: This includes Private Journey data which may be available as standard to the Contracting Entity; which may be made available under specific, agreed circumstances; or which may only be made available with the consent of the Data Subject. Please refer to the Contracting Entity to establish which is the correct scenario for your device

• Dashcam Data: images captured by the dashcam device(s)
• Diagnostic Data: vehicle fault codes, battery health status etc.

Use of Telematics and Dashcam data


Trakm8 maintains a database of all telematics and dashcam data and will keep this information in accordance with the retention periods agreed between Trakm8 and the Contracting Entity.

We use this data to provide the Service. We also use this data to maintain and improve the Service and to carry out research and development for new products and services.

Note, that Trakm8 may aggregate and anonymise location and/or driving behaviour for statistical or business purposes. All aggregated and anonymised data is the property of the Trakm8 Group.

Profiling – Driver Behaviour Scores


Trakm8 systems allow Driver Behaviour Scores to be calculated based on recorded telematics data and other publicly available data such as speed limits. The calculation of Driver Behaviour Scores is a form of profiling under Data Protection Legislation.

Driver Behaviour Scores are calculated using a combination of recorded telematics data, speed limit or similar data and System Thresholds that may be defined within our systems by the Contracting Entity. These thresholds typically relate to legal speed limits (speeding events), acceleration rates (harsh acceleration events), deceleration rates (harsh breaking events) or other driving behaviours (such as harsh cornering).

Trakm8 does NOT itself use the Driver Behaviour Score profiling for any form of automated decision making.

Calculated Driver Behaviour Scores are passed directly from Trakm8 to the Contracting Entity for their subsequent processing and use.

Trakm8 do not control the use of Driver Behaviour Score data by the Contracting Entity and you should contact the Contracting Entity directly for further information on their use of this data.

Enquiries relating to Driver Scoring and how it is used should be directed to the Contracting Entity in the first instance.

Third Parties


We use your information only as set out in this Policy and will not sell, rent or pass your information on to others for marketing or other purposes without your express consent.

Trakm8 may however provide aggregate statistics about our customers, sales traffic patterns and related site information to reputable third-party vendors and relevant affiliate partners, but these statistics will include no personally identifying information.

Trakm8 will provide certain telematics and dashcam data to the Contracting Entity in order to provide the Services, as agreed in our contract with the Contracting Entity.

We may also release account, telematics and/or dashcam data where we believe in good faith that this release is reasonably necessary to comply with the law.

Security


We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Your Rights - Controlling your personal information


Under data protection legislation, you have the right to:

• Request access to the personal data we hold about you and details of any other party we share that data with;
• Request a copy of the personal data that we hold about you;
• Request that we correct your personal data when it is incorrect, out of date or incomplete;
• Request that we stop using your personal data for direct marketing communications;
• Request that we stop any consent-based processing of your personal data after you withdraw that consent.

You have the right to request a copy of any information about you that Trakm8 holds at any time, and also to have that information corrected if it is inaccurate.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. We will then cease processing your data for that purpose.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

If we decide not to action your request we will explain to you the reasons for our refusal.

You may also request that some or all of your data is deleted; however, the Right to Erasure is not absolute and we may decide to retain the data if we have an overriding reason for doing so.

If we decide not to action your request we will explain to you the reasons for our refusal.

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

Making and Dealing with Requests


Any requests relating to this Service and the Personal data being processed will be handled jointly between Trakm8 and the Contracting Entity.


Requests relating to your personal data should be made to the Contracting Entity in the first instance – details of how to do that will be included in the relevant Privacy Notice provided by the Contracting Entity.


However, if you so wish, you are also able to make such as request directly to Trakm8 via email at privacy@trakm8.com or by writing to:


Data Protection Officer
Trakm8
Roman Park
Roman Way
Coleshill
West Midlands
B46 1HG

Contacting the Regulator


If you feel that your data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.


The Information Commissioner’s Office can be contacted via telephone on 0303 123 1113 or online at www.ico.org.uk/concerns

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.


Additional Questions?


We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.


If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:


Email us at: privacy@trakm8.com or write to us at:

Data Protection Officer
Trakm8
Roman Park
Roman Way
Coleshill
West Midlands
B46 1HG

Definitions


Associated Person - any other person who has been authorised to work on the vehicle (such as mechanics), to drive the vehicle, who use or are provided with or transported in a vehicle fitted with Telematics device for any period of time and for any purpose. It is the Driver’s responsibility to make a copy of this policy available to any Nominated Drivers.

Contracting Entity – the entity entering into the contract with Trakm8 and on whose instructions the Service is provided. This is often your employer, your insurer or the vehicle owner (in the case of hire or lease cars).

Customer Personal Data - personal data contained in the Data or otherwise collected from the Customer, and which is processed by the Supplier in the course of performing its obligations and for the other purposes set out herein.

DashCam - dashboard and/or in vehicle or asset camera(s);

DashCam Data - data produced by a Camera;

Data - Telematics Data, Driver Profile Data, Diagnostic Data, On Board Diagnostic Data, FNOL, Battery Status Data and Camera Data;

Data Protection Legislation - General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK, and any successor legislation to the foregoing;

Diagnostic Data - all raw, unprocessed data specified under the European On-Board Diagnostic standards available at a Vehicle or plant’s J1962 diagnostic socket;

Drivers – the main Driver and/or owner of the vehicle fitted with a Telematics device for the purposes of carrying out their duties or for any other purpose.

Nominated Drivers - any other person who has been authorised to drive the vehicle, who use or are provided with or transported in a vehicle fitted with Telematics device for any period of time and for any purpose. It is the Driver’s responsibility to make a copy of this policy available to any Nominated Drivers.

Personal data, process, data controller, data processor and data subject - have the meanings given in the Data Protection Legislation

Service – the full range of tracking and fleet management services provided by the Trakm8 Group and its subsidiary companies.

Telematics Device (Plug-in) – the unit which is fitted into the OBD port of your vehicle that collects and transmits data to us.

Telematics Device (Fitted to Vehicle) – the unit which has been fitted to your vehicle by an installation engineer (as opposed to the Plug-in) and that collects and transmits data to us.

Tracking Information – any information collected by the device fitted to the vehicle

VIN– Vehicle Identification Number