Trakm8 Website and General Privacy Notice (version 1.14)

This Privacy Notice covers the processing of Personal Information collected and processed when you our website and the processing of Personal Information required for normal business purposes.

For details of how we process Personal Information to deliver our Telematics Services, please refer to our Driver Privacy Notice (Driver Privacy Notice).

Revisions to this Privacy Policy

From time to time, there may need to be revisions to this Privacy Notice so you should revisit this page from time to time.

Why do we collect your Personal Information?

We may need to process your Personal Information for a variety of business reasons including:

• When you visit this or any other Trakm8 website
• When you subscribe to Regulatory News Alerts
• When you subscribe to our Server Status Updates
• When you subscribe to our Driver Privacy Notice updates
• When you place an online order
• When you visit Trakm8’s social media pages
• When you contact Trakm8 via telephone or email
• When you contact Trakm8 Technical Support via telephone or email
• When we contact you via telephone for marketing purpose or when we send you email marketing
• When you take part in a webinar, online demonstration, online meeting or similar
• If you apply for a job with us
• If you visit our offices

There may also be other circumstances where we need to process your Personal Information such as for legal, taxation or fraud prevention reasons, .

What Personal Information do we collect and when do we collect it?

As you might imagine, there are lots of different reasons why we need to collect and process your Personal Information.  The sections below attempt to set out the data that we collect for different reasons, what we do with that data and our lawful basis for that processing.

When you visit our website(s)

The information that we collect will depend on how you use our website as set out in the sections below.

When you use our website Chat function

If you use the Chat service on our website, we will place cookies onto your device to allow the Chat  service to function correctly.

We will process any Personal Information that you enter into the Chat Session such as the details of your enquiry, the name of your company or organisation you represent, fleet size, email address, job title, telephone number etc.

We will use your Personal Information to respond to directly to your chat and to follow up on enquiries.

Your Personal Information will be processed on the basis of our Legitimate Interests (to grow our business, respond to enquiries etc.).

Details of the cookies set by the chat function are detailed within our Cookie Policy

The Chat functionality is provided by Crisp and allows us to quickly connect website visitors to our agents and to respond to their enquiries during and outside of office hours.

Further information on Crisp can be found here: https://crisp.chat/fr/privacy/

When you complete one of our online enquiry forms

If you fill in forms on our website such as enquiry forms, we will collect your contact details and any other Personal Information you provide such as your name, the name of your company or organisation (if any), email address, job title, telephone number, fleet size etc.

We will use your Personal Information to respond to directly to your enquiries made via our websites or social media.

Your Personal Information will be processed on the basis of our Legitimate Interests (to grow our business, respond to enquiries etc.).

If you consent to be added to our marketing database when completing the enquiry form, we will collect your name and contact details, the name of your company/organisation (if any), your email address, job title, telephone number(s), fleet size  and your preferences as to the types of marketing information you would like to receive from us.

When you register online and take part in webinars, online demonstrations or similar ‘events’.

When you register and/or attend an online webinar, online demonstration or similar, we will process your Personal Information such as name, email or company name.  We will use this data to send you connection details and to host and administer the webinar, demonstration or event. 

Note that any questions, comments or other input that you provide during such a webinar, demonstration or similar may be collected and may be made available to other participants.

If we record the online event, this will be clearly indicated to participants at the start of the event.

Your Personal Information will be processed on the basis of our Legitimate Interests (to grow our business, develop our products/services, to study how customers use our products/services and to keep our marketing strategy current).

If you consent to be added to our marketing database during the registration process, we will collect your name contact details the name of your company/organisation (if any), email address, job title, telephone number(s), fleet size  and your preferences as to the types of marketing information you would like to receive from us.

We currently use a number of different providers (Zoom, Cisco Webex, MS Teams, eWebinar) to deliver our webinars and we may share limited information with these providers for delivery of the service.

For more information, please refer to:

• https://zoom.us/privacy/
• https://www.cisco.com/c/en_uk/about/legal/privacy-full.html
• Microsoft Teams Privacy – Microsoft Teams | Microsoft Docs
• https://ewebinar.com/terms/#PrivacyPolicy

Where use of the above providers requires any transfer of Personal Information outside of the UK / EEA, we will utilise the UK International Data Transfer Addendum or EU Standard Contractual Clauses for such transfer.

When you use our online Calculators and other Interactive Content

When you use one of the interactive tools on our website such as ROI or Savings Calculators, we may share some basic elements of your data with Outgrow such as your email address.

Your Personal Information will be processed on the basis of our Legitimate Interests (to grow our business, develop our products/services, to study how customers use our products/services and to keep our marketing strategy current).

If you consent to be added to our marketing database, we will collect your name contact details the name of your company/organisation (if any), email address, job title, telephone number(s), fleet size  and your preferences as to the types of marketing information you would like to receive from us.

For more information please refer to: https://outgrow.co/privacy-policy/

When you enter a competition online

If you enter one of our online competitions, we will use collect and use your Personal Information to administer that competition.

Your Personal Information will be processed on the basis of your Consent as you have chosen to enter the competition.

If you consent to be added to our marketing database whilst entering the competition, we will collect your name contact details the name of your company/organisation (if any), email address, job title, telephone number(s), fleet size  and your preferences as to the types of marketing information you would like to receive from us.

When you subscribe to Regulatory News Alerts

The Regulatory News Alerts on the Trakm8 website are provided by EQS on our behalf. 

If you register for these alerts, we will collect your email address and will share this information with EQS in order that they can send you updates as they happen. 

Your Personal Information will be processed on the basis of your Consent as you have registered for the alerts.

It is possible to unsubscribe from these updates at any point using the Unsubscribe feature on our website or by contacting EQS directly.

Full details of how EQS use this data can be found on their website: https://www.eqs.com/en-GB/footer/legals/data-protection/

When you subscribe to our Server Status Updates

The Server Status updates are provided by Statuspage, an Atlassian owned company. 

If you register for updates, we will collect your email address and share with Atlassian so they can send you updates as they happen.

Full details of how Atlassian use this data can be found on their website: https://www.atlassian.com/legal/privacy-policy.

Your Personal Information will be processed on the basis of your Consent as you have registered for the alerts.

You may unsubscribe from this service at any time by emailing Privacy@trakm8.com or in writing to the postal address below.

When you subscribe to our Driver Privacy Notice updates

When you subscribe to Driver Privacy Policy updates, we will collect your email address which we will then use to notify you of updates as they happen.

Your Personal Information will be processed on the basis of your Consent as you have registered for the alerts.

You may unsubscribe from this service at any time by emailing Privacy@trakm8.com or in writing to the postal address below.

When you place an Online Order

When you place an order on our website, we will collect your Personal Information in order to take payment and fulfil that order.

As part of the payment process, we will share your payment information with Stripe, a 3rd party payment processor. 

Where the contract is with you directly, your Personal Information will be processed as is necessary to fulfil your order (necessary for contract).

Where the contract is with your employer, , your Personal Information will be processed under our Legitimate Interests.

Your payment will then be processed by Stripe, who collect, use and process your information, including payment information, in accordance with their privacy policies.

You can access their privacy policy via the following link: https://stripe.com/gb/privacy

Stripe’s services in Europe are provided by a Stripe affiliate -Stripe Payments Europe Limited (“Stripe Payments Europe”) – an entity located in Ireland. In providing Stripe Services, Stripe Payments Europe may transfer Personal Information to Stripe, Inc. in the US.

Where a transfer of Personal Information to a country outside of the UK / EEA takes place, we will utilise the UK International Data Transfer Addendum or EU Standard Contractual Clauses for such transfer.

Website Analytics / Targeted Advertising

When you visit one of our websites and provide your consent via our Cookie banner, we may use the following 3rd party analytics services to track and analyse both individualized usage and volume statistical information and details of visitor behaviour patterns.

• Google Analytics
• Lucky Orange
• Pardot
• Bing
• Facebook
• LinkedIn

We also partner with one or more 3rd parties (such as advertisers and ad networks) to serve advertising on other sites.

These 3rd parties use cookies, web beacons, pixel tags and similar tracking technologies to collect and use certain information about your online activities, either on our Websites and/or other sites or mobile apps, to infer your interests and deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests (“Interest Based Advertising”). For more information about this practice, click here: http://www.aboutads.info/choices/

Our 3rd party service providers may also use cookies or web beacons to collect information about your visits to other sites to measure and track the effectiveness of advertisements and our online marketing activities (for example, by collecting data on how many times you click on one of our ads).

Details of the cookies set by our analytics providers are detailed within our Cookie Policy

Google Analytics

Where we have your consent, we make use of Google Analytics, a web analytics service provided by Google, Inc (“Google”).

Google Analytics uses “cookies”, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will generally be transmitted to and stored by Google on servers in the United States.  Your IP address will not be associated with other Google data.

You may refuse the use of cookies by selecting the relevant setting on our Cookie Banner or by using the settings on your browser.

In addition, you can prevent Google’s collection and use of the data (cookies and IP address), as well as the processing of this data by Google, by downloading and installing the browser plug-in available from the following link:

https://tools.google.com/dlpage/gaoptout?hl=en-GB

Please note that on this website, Google Analytics code is supplemented by “anonymizeIp” to ensure an anonymized collection of IP addresses (so called IP-masking). Further information concerning the terms and conditions of use and data privacy can be found at

http://www.google.com/analytics/terms/gb.html or at https://policies.google.com/?hl=gb&gl=de

Pardot

Where we have your consent, we use Pardot to track visitor and prospect activities on our website and landing pages by setting cookies on users’ web browsers. Cookies are configured to remember preferences, such as form fields, when a visitor returns to our site.

Pardot also sets a cookie for logged-in users to maintain the session and to remember table filters.

Pardot sets first-party cookies for tracking purposes and sets third-party cookies for redundancy. Using first-party and third-party cookies together is standard in the marketing automation industry.

Pardot cookies do not store personally identifying information, but rather a unique identifier only.

For more information, please refer to:

https://help.salesforce.com/articleView?id=pardot_basics_cookies.htm&type=5

Lucky Orange

Where we have your consent, we use Lucky Orange to help identify problems customers are having on our site and improve your experience. We go to great lengths to provide tools that help limit sensitive data about you from being transmitted and stored on our servers.

https://help.luckyorange.com/article/173-what-cookies-does-lucky-orange-set

Tracking via Lucky Orange can be disabled via their website:

https://www.luckyorange.com/privacy.php

Note that this will disable Lucky Orange tracking across ALL websites which means that for some sites, functions such as chat may stop functioning

Microsoft / Bing

Where we have your consent, we will use Microsoft Bing to record your web usage and save information about your “session,” i.e. your time on our website.

You may refuse the use of cookies by selecting the relevant setting on our Cookie Banner or by using the settings on your browser.

You can also control your Personal Information that Microsoft has obtained, and exercise your data protection rights, by contacting Microsoft or using various tools they provide. In some cases, your ability to access or control your Personal Information will be limited, as required or permitted by applicable law. How you can access or control your Personal Information will also depend on what you want to do. For example, you can:

• Control the use of your data for interest-based advertising from Microsoft by visiting their opt-out page.
• Access and clear some of your data through the Microsoft privacy dashboard.

You contact Microsoft at the address in the  How to contact us section or by using their web form.

Facebook

Where we have your consent, we use Facebook Page Insights to monitor our Facebook Pages and to unlock additional insights about Facebook members who visit or interact with our Page.

We may use the Facebook pixel on our website to track conversions, retarget website visitors, and unlock additional insights about Facebook members interacting with our website, Facebook Page and advertisements.

We also use the Facebook pixel to ensure our Facebook ads are displayed to Facebook users who have shown an interest in our website or who have interests that indicate our products and services will be of potential interest to them.  By taking this approach, we aim to ensure that ads are only displayed to users who are interested in our information and services.

Using the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion tracking”).

By using the Facebook pixel on our website, Facebook is informed of your visit to our website when you log in or visit Facebook itself.

Standard Contractual Clauses will apply to Personal Information that is transferred via the Services from the UK to Facebook.

The data collected about you is anonymous and Trakm8 are not provided with the identity of the users at any stage. However, the data is stored and processed by Facebook so that it can be linked to the respective user profile and used by Facebook for its own market research and advertising purposes.

Facebook’s processing of the data is governed by Facebooks Data Usage Policy. Accordingly, general instructions on how to display Facebook ads, in the Facebook Data Usage Policy: https://www.facebook.com/policy.php

For specific information and details about the Facebook pixel and how it works, please visit the Facebook Help Centre: https://www.facebook.com/business/help/651294705016616

You may object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set what kind of ads you see on Facebook, you can go to the page set up by Facebook and follow the instructions on how to set up use-based advertising: https://www.facebook.com/settings?tab=ads

The settings are platform-independent and are applied to all devices, such as desktop computers or mobile devices.

You may also object to the use of cookies for measuring range and advertising purposes via the Network Advertising Initiative’s deactivation page ( https://optout.networkadvertising.org/ ) and additionally via the US website ( https://www.aboutads.info/choices ) or the European website ( https://www.youronlinechoices.com/uk/your-ad-choices/ ).

LinkedIn Insight Tag

Where we have your consent, we use the LinkedIn tag on our website to track conversions, retarget website visitors, and unlock additional insights about members of LinkedIn who interact with our advertisements.

The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views. All data is encrypted. The LinkedIn browser cookie is stored in a visitor’s browser until they delete the cookie or the cookie expires.

Each time you access one of our pages that use LinkedIn’s features; a connection is established to a LinkedIn server. LinkedIn is informed that you have visited our website with your IP address. With the help of the LinkedIn Insight Tag we are able to analyse the success of our campaigns within the LinkedIn platform or determine target groups for them based on the interaction of the users with our website.

Standard Contractual Clauses will apply to Personal Information that is transferred via the Services from the UK to LinkedIn.

If you are registered with LinkedIn, it is possible for LinkedIn to associate your interaction with our online services with your user account.

You can permanently opt out via this link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

For more information on the LinkedIn Privacy Policy, go to https://www.linkedin.com/legal/privacy-policy

When you visit Trakm8’s social media pages

If you contact us through Social Media, we may keep a record of that contact and the information you provide us with at that time.

Where an individual submits an enquiry, we collect and store some or all of the following information:

• Name
• Email address
• Telephone number(s)
• Job Title
• Company/organisation name
• Fleet Size

Your Personal Information will be processed on the basis of your Consent as you have submitted the enquiry to which we are responding.

If you consent to be added to our marketing database, we will collect your name, the name of your company/organisation (if any), email address, job title, telephone number(s), fleet size and your preferences as to the types of marketing information you would like to receive from us.

Where you are a member of a social media platform such as Facebook, LinkedIn, Twitter etc., the platform is generally able to analyse your online behaviour when you visit Trakm8’s social media content and when you interact with any website that includes a social media plugin.

Under certain circumstances, your Personal Information may also be recorded if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.

Facebook

We operate a Facebook Page. The provider is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.

We have signed a joint processing agreement (Controller Addendum) with Facebook. This agreement specifies which data processing operations we or Facebook are responsible for when you visit our Facebook page. You can view this agreement at the following link: https://www.facebook.com/legal/terms/page_controller_addendum

You can customise your advertising settings independently in your user account. Click on the following link and log in: https://www.facebook.com/settings?tab=ads

Details can be found in the Facebook privacy policy: https://www.facebook.com/about/privacy/

LinkedIn

We have a company profile on LinkedIn. The provider is the LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

If you want to disable LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

For details on how they handle your Personal Information, please refer to LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.

X (Twitter)

We have a company account on Twitter. The provider is Twitter International Company, 1 Cumberland Place, Fenian Street Dublin 2, D02 AX07 Ireland.

You can customize your Twitter privacy settings in your user account. Click on the following link and log in: https://twitter.com/personalization

For details, see the Twitter Privacy Policy: https://twitter.com/privacy

When you contact Trakm8 via telephone or email

If you contact us in writing, via email or telephone, we may keep a record of that contact and the information you provide us with at that time. 

Where you contact Trakm8 via telephone, we may also keep a call recording of that call for the following purposes:

• training and quality control;
• as evidence of conversations; and/or
• for the prevention or detection of crime.

Where an individual submits an enquiry, creates an account or places an order, we collect and store some or all of the following information:

• Name
• Email address
• Telephone number(s)
• Job Title
• Company/organisation name
• Fleet Size
• Banking Information
• Enquiry, Account or Order Details

Where you may an enquiry, we will process your Personal Information on the basis of your Consent (as you have submitted the enquiry to which we are responding).

Where you have placed an order, we will process your Personal Information on the basis of our Legitimate Interest or as is needed to fulfil your order (Necessary for Contract)

If you consent to be added to our marketing database, we will collect your name, the name of your company/organisation (if any), email address, job title, telephone number(s), fleet size and your preferences as to the types of marketing information you would like to receive from us.

When you contact Trakm8 Technical Support via telephone or email

When you contact our Technical Support function via email or telephone, we will collect your Personal Information such as name and contact details, along with any details relevant to the Support Case.

Your Personal Information will be processed on the basis of our Legitimate Interests as we are responding to your enquiry; are providing guidance in response to a request; or are attempting to resolve an issue which you have reported.

If you contact our Support Line, we will use Salesforce to record and manage your reported issues.

If  you contact our Support Line outside of core business hours, we may share your data with our Out of Hours service provider.

Where you contact Trakm8 via telephone, we may also keep a call recording of that call for the following purposes:

• training and quality control;
• as evidence of conversations; and/or
• for the prevention or detection of crime.

When you meet us at Trade Shows / Exhibitions / Events or similar

If we meet you at a networking event, exhibition or trade show, we may collect your contact details and any other information you provide to us at these events.

Your Personal Information will be processed on the basis of your Consent as you have provided that information directly to us.

If you consent to be added to our marketing database, we will collect your name, the name of your company/organisation (if any), email address, job title, telephone number(s), fleet size and your preferences as to the types of marketing information you would like to receive from us.

When you apply for a job with us

If you submit a job application to us or if we receive your job application via a recruitment company, we will collect your contact details and any other information you provide in the application.

This may include information such as CVs, your full name, address, date of birth, proof of residency and/or copies of your passport or driving licence. If you provide a copy of your passport, the data will also include your place of birth, gender and nationality.

We may also collect documents required to prove your identity, Right to Work status or for Information Security screening.

Your Personal Information will be processed on the basis of your Consent as you have applied for the job vacancy.

If you visit our offices

If you visit our offices we will ask you to sign in/out at reception and may also record your vehicle registration details.

We use CCTV both inside and outside of our building for security purposes and therefore may capture CCTV images of you and your vehicle.

Your Personal Information will be processed on the basis of our Legitimate Interests (i.e. for security purposes).

When we contact you via telephone or email for marketing purposes

From time to time, we may contact you for marketing purposes.  We will do this either on the basis of your Consent (i.e. you have stated that you want to receive marketing material from us) or on the basis of our Legitimate Interests (where you have not objected to our marketing in the past).

Your Personal Information will be processed on the basis of your Consent where you have requested such calls or on the basis of our Legitimate Interests to promote our business.

How can you stop the use of your personal data for direct marketing?

You have the right to request that we stop contacting you via telephone for marketing purposes and / or that we stop sending you email marketing at any time.

There are several ways you can stop direct marketing communications from us:

• Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further marketing emails.
• Inform us via telephone, email or social media.
• Contact our Data Protection Officer via email at Privacy@trakm8.com.or in writing using the address shown below.

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

Telephone Marketing

Where we contact you via telephone for marketing purposes, we may also keep a call recording of that call for the following purposes:

• training and quality control;
• as evidence of conversations; and/or
• for the prevention or detection of crime.

Email Marketing

When we send you any email marketing messages, we will always provide you with an easy method to withdraw your consent though an unsubscribe link in the email itself.

We may use a number of processors to assist with sending these email messages including Pardot, SendGrid or Survey Monkey.

Where use of the above providers requires any transfer of Personal Information outside of the UK / EEA, we will utilise the UK International Data Transfer Addendum or EU Standard Contractual Clauses for such transfer.

Email marketing messages, surveys or similar that we send you may also contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages.

Where used, such tracking technology may record a range of data such as: times, dates, I.P addresses, email-opens, email-clicks, email-forwards, geographic and demographic data. Such data, within its limitations, will show the activity each subscriber made for that email campaign.

Where used alongside cookies, such tracking may also record activity on our websites such as pages visited, number of visits etc. For more details on our use of cookies, including how to disable cookies, please refer to our Cookie Policy.

Indirect Sources of Personal Information     

In certain, limited circumstances, we may collect Personal Information that has been made publicly available (such as via Companies House, Electoral Roll or the Land Registry etc.). We may also obtain your Personal Information from event organisers (such as Trade Shows or Exhibitions) and from commercial data suppliers.  We seek to ensure that the supplier of such Personal Information complies with all relevant privacy laws.

Where we obtain Personal Information  indirectly, we will, to the extent required by law, provide you with relevant privacy information within 1 month of obtaining your data or when we first contact you.

Explaining the legal bases for processing Personal Information

The law on data protection sets out a number of different reasons for which a company may collect and process your Personal Information, including:

Consent

In specific situations, we can collect and process your data with your consent.

For example, when you enter your personal details on an enquiry form we will use your data to respond to the enquiry; when you tick a box to receive email newsletters we will use your data to send you those newsletters; or when you enter a competition we will use your data to tell you if you have won.

When collecting your Personal Information, we’ll always make clear to you which data is necessary in connection with a particular service and which is optional.

Necessary for Contract

In certain circumstances, we need your Personal Information to comply with our contractual obligations and to fulfil any contract that we have with you.

For example, if you order an item from us for home delivery, we’ll collect your address details and pass them to our courier in order for them to deliver your purchase.

Legal Compliance

If the law requires us to, we may need to collect and process your Personal Information.  

For example, we can pass on details where required to do so under HMRC rules or where required by a court order.

Legitimate Interests

In specific situations, we require your Personal Information to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we may send you direct marketing information informing you about products and services that we think might interest you (as long as we comply with other legal requirements in doing so).

Who do we share your Personal Information with?

We may disclose some or all of your personal information to 3rd party service providers in the course of their service provision to Trakm8 Group companies. 

We will only provide these companies with the information they need to deliver the service we have engaged them for and they are prohibited from using that information for any other purpose.

Whenever we share personal information with our service providers, we will put in place contracts which require the service provider to protect the information and keep it secure.

We may also 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.

We may also release information where we believe in good faith that this release is reasonably necessary to comply with the law, to enforce or apply our contractual rights, or to otherwise protect and defend our rights, property or the safety of our customers and other users of the website, and/or where there is an applicable legal exemption in force. 

Salesforce

We use a CRM system provided by Salesforce for managing business and marketing contacts and for processing installation and support related information. 

These services are hosted from within the UK / EEA.

Any data transfer from the UK to SendGrid in the US via the Services takes place under the UK Extension to the EU-US Data Privacy Framework.

For more information please refer to: https://www.salesforce.com/company/privacy/

Pardot

We may use Pardot for sending service related emails necessary for the set-up and operation of our services.  We may also use SendGrid for sending marketing related emails.

We provide your name, email address and the email content and Pardot sends the email to you on our behalf.

The information may be stored on Salesforce/Pardot servers based in the US.

Any data transfer from the UK to Salesforce in the US via the Services takes place under the UK Extension to the EU-US Data Privacy Framework.

For more information please refer to: https://www.salesforce.com/company/privacy/

Amazon Web Services (AWS)

Trakm8’s operational telematics systems and internal IT networks are hosted on AWS infrastructure within the UK / EEA. 

For more information please refer to: https://aws.amazon.com/privacy/

Daisy

Trakm8’s operational telematics systems and internal IT networks are also hosted on Daisy infrastructure within the UK. 

For more information please refer to: https://daisyuk.tech/privacy/   

SendGrid (Twilio)

We use SendGrid for sending service related emails necessary for the set-up and operation of our services.  We may also use SendGrid for sending marketing related emails.

We provide your name, email address and the email content and SendGrid sends the email to you on our behalf.

The information is stored on SendGrid servers based in the US.

In addition to simply sending e-mail, SendGrid provides different analysis options to inform us of whether, when and where the distributed emails are opened, used or rejected. To achieve this, SendGrid uses cookies and similar technologies.

Data transfer from the UK to SendGrid in the US via the Services takes place under the UK Extension to the EU-US Data Privacy Framework.

For more information, please refer to: https://www.twilio.com/legal/privacy

Installation Partners

We may also share your Personal Information with our installation partners in order to deliver and support our goods and services.

A full list of current installation partners can be found here: Trakm8 Installation Partners

Out of Hours Support Provider

Where you contact us for support outside of core hours, we will share your personal data with our Out of Hours service provider.

Stripe

When you place an order we may use Stripe who act as a third party payment provider. In this case, your payment will be processed by Stripe, who will collect, use and process your information, including payment information, in accordance with their privacy policies.

Any data transfer from the UK to the US via the Services takes place under the UK Extension to the EU-US Data Privacy Framework.

You can access their privacy policy via the following link: https://stripe.com/gb/privacy

Crisp

Our websites use the Chat functionality provided by Crisp

This allows us to quickly connect customers to our agents and to respond to customers enquiries during and outside of office hours.

Further information can be found at: https://crisp.chat/fr/privacy/

Outgrow

We use features from Outgrow to deliver interactive content such as Savings or ROI Calculators and quizzes.

Outgrow sets a single cookie related to compliance with data protection legislation

For more information please refer to: https://outgrow.co/privacy-policy/

Google ReCAPTCHA

We use reCAPTCHA when you subscribe to our Operational Status or Driver Privacy Policy notifications.  reCAPTCHA is a service from Google that protects websites from spam software and misuse by non-human visitors by use of advanced risk analysis techniques.

For more information, please see: https://policies.google.com/terms and Google’s Privacy Policy: https://policies.google.com/privacy

Webinar or meeting platform providers

We use a number of service providers to deliver webinars, online meetings or similar.  By registering and accepting an invitation to such an ‘online meeting’, you are providing your explicit consent to the collection, processing and sharing of specific personal information in accordance with the details below.  If you do not wish for this information to be processed, you should not accept the invitation.

MS Teams

We may use Microsoft Teams to provide our ‘online meetings’ (webinars, conference calls, online demonstrations etc.)

A Teams account is not required if you are simply joining as a participant.

Where the online meeting is conducted using MS Teams, various types of data are processed depending on the information you provide before or during participation in an “online meeting”.

• Content – meetings, conversations, voicemails, shared files, recordings and transcriptions
• Profile data such as name, email and phone number
• Diagnostic and service data Diagnostic data related to service usage. This personal data allows Microsoft to deliver the service (troubleshoot, secure and update the product and monitor performance) as well as perform some internal business operations, such as:
  • Determine revenue
  • Develop metrics
  • Determine service usage
  • Conduct product and capacity planning

Any data transfer from the UK to the US via the Services takes place under the UK Extension to the EU-US Data Privacy Framework.

For more information, please refer: Microsoft Privacy Statement – Microsoft privacy

Zoom

We may use Zoom to provide our ‘online meetings’ (webinars, conference calls, online demonstrations etc.)

A Zoom account is not required if you are simply joining Zoom Meetings as a participant.

Where the online meeting is conducted using Zoom, various types of data are processed depending on the information you provide before or during participation in an “online meeting”.

• User details: first name, last name, telephone (optional), e-mail address, password (if “Single-Sign-On” is not used), profile picture (optional), Department (optional)
• Meeting metadata: Topic, description (optional), participant IP addresses, device/hardware information
• For recordings (optional): MP4 file of all video, audio and presentation recordings, M4A file of all audio recordings, text file of online meeting chat.

When dialing in by phone: information on incoming and outgoing phone number, country name, start and end time. If necessary, further connection data such as the IP address of the device can be saved.

• Text, audio and video data: You may be able to use the chat, question or survey functions in an “online meeting”. To this extent, the text entries you make are processed in order to display and, if necessary, log them in the “online meeting”. In order to enable the display of video and the playback of audio, the data from the microphone of your terminal device and from any video camera of the terminal device are processed for the duration of the meeting. You can turn off or mute the camera or microphone yourself at any time using the “Zoom” applications.
• In order to participate in an “online meeting” or to enter the “meeting room”, you must at least provide information about your name.

Any data transfer from the UK to the US via the Services takes place under the UK Extension to the EU-US Data Privacy Framework.

For more information, please refer to: https://zoom.us/privacy/  

Cisco Webex

We may use Cisco Webex to provide our ‘online meetings’ (webinars, conference calls, online demonstrations etc.)

Where the online meeting is conducted using Cisco Webex, various types of data are processed depending on the information you provide before or during participation in an “online meeting”.

• Registration Data:
  • Name, email, password, public IP address, browser, phone number (optional), mailing address (optional), Avatar (optional)
• User Generated Data:
  • Meeting and call recordings, uploaded files
• Hosting and Usage data:
  • IP address, user agent ID, hardware type, operating system, client version, IP addresses along network path, MAC address, Service Version, Actions taken, meeting session information (title, date, time, duration, quantity, quality, network activity, network connectivity), number of meetings, number of screen sharing sessions/non screen sharing sessions, number of participants, host name, join method, performance/troubleshooting

Any data transfer from the UK to the US via the Services takes place under the UK Extension to the EU-US Data Privacy Framework.

For more information, please refer to: https://www.cisco.com/c/en_uk/about/legal/privacy-full.html

eWebinar

We may use eWebinar to provide our ‘online meetings’ (webinars, conference calls, online demonstrations etc.)

Where the online meeting is conducted using eWebinar, various types of data are processed depending on the information you provide before or during participation in an “online meeting”

• Demographic information such as gender, age, and location of residence (city/province/state/county/country);
• Contact information such as name, email address, mailing and delivery address, and phone number;
• Unique identifiers such as username, account number, and password;
• Professional information such as name of employer, occupation, and location of occupation

This information is stored on eWebinar servers in Canada and the US.

By accepting the invitation and participating in the ‘online meeting’ you are deemed to have consented to the transfer of data via the services to eWebinar.

For more information, please refer to: https://ewebinar.com/terms/#PrivacyPolicy  

Survey Monkey

We may use Survey Monkey to send you surveys or similar.  We provide your name, email address and the survey content to Survey Monkey and Survey Monkey may contact you on our behalf.

This information and your response are stored on Survey Monkey servers based in the US.

Standard Contractual Clauses will apply to personal data that is transferred via the Services from the UK to Survey Monkey in the US.

For more information, please refer to: https://www.surveymonkey.com/mp/legal/privacy/

Other Parties

We will also share your personal information with third parties in the following circumstances:

• companies assisting us in our support activities;
• companies assisting us in our marketing, advertising and promotional activities;
• third party payment processors in relation to credit/debit card payments;
• fraud prevention agencies if false or inaccurate information is provided to us as part of your use of our services or otherwise, and fraud is identified or suspected;
• credit reference agencies, fraud prevention agencies, payment processors, suppliers of technical and support services, insurers, logistics providers, manufacturers and cloud service providers, debt collectors, our legal and other professional advisors, including auditors;
• if we are under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers; and
• when we restructure or sell our business or its assets or are subject to a merger or re-organisation.

How we protect your Personal Information

We know how much data security and privacy matters to visitors to our website and to our customers, suppliers and partners.  With this in mind, we will treat your Personal Information with the utmost care and take all necessary steps to protect it once we receive it.

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 process.

Unfortunately, the transmission of information via the internet is never completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of information you submit via our website and any transmission is at your own risk.

Where you are using our websites to access an account or any online services, it is your responsibility to keep your passwords confidential and sign out once you have finished browsing.

Where your Personal Information may be processed (International Transfers)

Our primary processing facilities are all based within the UK.

On occasions, we may need to transfer Personal Information that we collect from you to 3rd party processors in countries that are outside the UK and/or EEA.

If we do transfer your information outside the UK / EEA, we will take appropriate steps to protect that information, which include:

• transferring your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the UK and/or European Commission
• entering into an agreement with the recipient, which includes the UK International Data Transfer Addemdum or a version of the EU’s standard contractual clauses that the UK Information Commissioners Office has determined offers adequate protection for your information
• entering into an agreement with the recipient who have Binding Corporate Rules (BCR) in place that have been approved by the UK and/or an EU competent Supervisory authority
• obtaining your consent for any transfer of Personal Information

For example, our contracts with 3rd parties stipulate the standards they must follow at all times. If you wish for more information please contact our Data Protection Officer.

How long will we keep your Personal Information?

Whenever we collect or process your Personal Information, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

For example, we will keep Personal Information about you and any related financial transactions for a period of 7 years (by reference to closure of your account or the last purchase or sale you made) to comply with HMRC requirements to keep accurate records that can be audited.

At the end of that retention period, your Personal Information will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.  There are exceptions, such as where your Personal Information needs to be retained for longer where there are valid legal grounds for us to do so, for example, where required by law, court orders or to defend or pursue legal claims.

Change of Business Ownership

As our business develops, members of the Trakm8 Group may have the majority of its shares bought by another company, may enter into mergers; acquisitions; consolidations; restructuring/reorganisation; or it may sell some or all of its assets or business.  Where such a transaction occurs, we may disclose and/or transfer your Personal Information as part of that transaction.  Any acquirer may continue to use your Personal Information as set out in this Privacy Policy.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over those other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the websites in question.

Special Category Data

Generally speaking, we do not intentionally collect “special category data” (i.e. data relating to racial or ethnic origin, political opinions, religious beliefs, membership of a trade union, physical or mental health and criminal records) about visitors to our website or our customers or suppliers.  

The exceptions are during online meetings or where we identify suspected criminal activity such as fraudulent claims or the use of stolen payment card details.

Where we suspect criminal activity, we will record details of the suspected criminal activity and may take appropriate action, including refusing to accept orders, make payments or give refunds. We may also report the incident to the relevant bank or payment card issuer or to the police or other appropriate authorities.

As online meetings provide a live visual connection, race or religion maybe inferred. We rely on your explicit consent for this; if you do not want to disclose this information, you can turn off or mute the camera and/or microphone yourself at any time.

Children’s Data

This website is not designed for, or intentionally targeted at children. If you are under 16 years’ old, please do not send us your Personal Information (for example, your name, address and email address). We do not intentionally collect or maintain data about anyone under the age of 16, through this website. If we discover that we have unintentionally collected Personal Information from a child below 16, we will remove that child’s Personal Information from our records promptly.

What are your rights over your Personal Information?

Under Data Protection Legislation, you have the right to:

• Request a copy of the Personal Information and Telematics Data that we hold about you;
• Request details of any other party we share that data with;
• Request that we correct your Personal Information when it is incorrect, out of date or incomplete;
• Request that we erase your Personal Information
• Request that we restrict the processing of your Personal Information
• Request a copy of your Personal Information in order to reuse for your own purposes across different services.
• Object to the processing of your Personal Information
• Request that we stop using your Personal Information for direct marketing communications
• Request that we stop any consent-based processing of your Personal Information after you withdraw that consent.

Your Rights in detail

Making and Dealing with Requests

You may submit a request at any time by contacting our Data Protection Officer email at Privacy@trakm8.com ; or by writing to:

Data Protection Officer

Trakm8 Limited

4 Roman Park

Roman Way

Coleshill

West Midlands

B46 1HG

You may also contact us via email, telephone or via our social media channels.

Subject Access Requests – Right to have a copy of your Personal Information.

You have a right to request a copy of the Personal Information that we hold about you as well as other related information such as who we share that data with, where we obtained the data or how long we will keep the data.  Much of that information is contained within this Privacy Notice.

We will consider any Subject Access Request and inform you of the outcome of that assessment, our decision and our reasons for that decision.

Requests for Rectification – Right to have your data corrected.

You may request that we correct, amend or update your information where you believe that it is incorrect.

You should provide details of the inaccuracy or error within your Personal Information so that we can assess your request.

We will consider any request for rectification and inform you of the outcome of that assessment, our decision and our reasons for that decision.

Right to Erasure  – Right to have your data deleted in certain circumstances.

You may request that we delete the Personal Information that we hold about you.

Please note, this right is not absolute and there may be some instances where there is an overriding reason to keep that Personal Information..  For example, some data may need to be retaining to meet our legal obligations or for taxation purposes.

We will consider any request to delete your Personal Information and inform you of the outcome of that assessment, our decision and our reasons for that decision.

Note that any requests for erasure relating to Telematics or other service data should be submitted in accordance with our Driver Privacy Notice.

Right to Restrict Processing – Right to ask us to stop using your Personal Information

You have the right to ask us to stop using your Personal Information in the following circumstances:

• You contest the accuracy of your Personal Information and you are verifying the accuracy of the data;
• You believe that your Personal Information has been unlawfully processed, you don’t want your Personal Information deleted and you request a restriction instead.
• You need us to keep a copy of your Personal Information it in order to establish, exercise or defend a legal claim that you are dealing with.
• You have objected to use of your Personal Information and want processing restricted whilst we deal with that request.

Requests of this type are often submitted alongside other requests (such as requests for rectification.

We will consider any request to restrict processing and inform you of the outcome of that assessment, our decision and our reasons for that decision.

Request for Data Portability – Right to reuse for your own purposes across different services.

You have the right to request a copy of your Personal Information so that you can reuse it for another purpose.

It is unlikely that we will hold any Personal Information about you that you would not already hold.

We will consider any request portability request and inform you of the outcome of that assessment, our decision and our reasons for that decision.

Note that any portability requests relating to Telematics or other service data should be submitted in accordance with our Driver Privacy Notice.

Right to Object to Processing – Right to ask us to stop processing your data in certain circumstances.

You have the right to object to the processing of your Personal Information where we are processing on the basis of our Legitimate Interests.

Please note, this right is not absolute and there may be some instances where we decline your request as there is an overriding reason to do so. 

We will consider any objection to processing and inform you of the outcome of that assessment, our decision and our reasons for that decision.

Note that any requests for erasure relating to Telematics or other service data should be submitted in accordance with our Driver Privacy Notice.

Right to Object to Processing for Direct Marketing – Right to ask us to stop marketing to you.

You have the right to ask us to stop sending you marketing material or to stop contacting you for marketing purposes.

Where you make such a request, we will stop marketing to you by adding your details to our DO NOT MARKET list.

Your right to withdraw Consent.

Where Trakm8 are processing your Personal Information on the basis of your Consent, then  you have the right to change your mind at any time and withdraw that Consent. 

Where this happens, we will stop processing your Personal Information for the relevant purposes.

Checking your identity.

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

Trakm8 will normally accept the following forms of ID as proof of identity: a copy of your driving licence, passport, national ID card or in some instances photographic ID cards issued by your employer.

We may also request that the Trakm8 Customer assists us in verifying your identity.

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.

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 Information, you have the right to lodge a complaint with the Information Commissioner’s Office.

The Information Commissioner’s Office can be contacted at:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545745 (national rate)

Email: casework@ico.org.uk

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.

Contacting us and Further Information

We hope this Privacy Policy has been helpful in setting out the way we handle your Personal Information and your rights to control it.

If you have any questions, 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 Limited

4 Roman Park

Roman Way

Coleshill

West Midlands

B46 1HG

Trakm8 Limited and Route Monkey Limited are wholly owned subsidiaries of Trakm8 (Holdings) PLC.

Trakm8 (Holdings) PLC: Registration: Incorporated and registered in England and Wales; company registration number 05452547.

Registered Office: 4 Roman Park, Roman Way, Coleshill, Birmingham, West Midlands B46 1HG.

Trakm8 Limited: Incorporated and registered in England and Wales; company registration number 04415597.

Route Monkey Limited:  Incorporated and registered in Scotland; company registration number SC353016.