NOTICE LAST UPDATED: DECEMBER 20, 2019
THIS PRIVACY NOTICE APPLIES TO TELETRAC NAVMAN US LTD’S COLLECTION AND USE OF [CALIFORNIA RESIDENTS’ OR UNITED STATES RESIDENTS’] PERSONAL INFORMATION, PARTICULARLY WHERE SUCH USE OR COLLECTION IS GOVERNED BY THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND RELATES TO CONSUMER TRANSACTIONS. ALTHOUGH THE CCPA APPLIES TO PERSONAL INFORMATION OF INDIVIDUALS THAT ARE RESIDENTS OF CALIFORNIA, TELETRAC NAVMAN US LTD MAY AS A COURTESY EXTEND SOME OF THE CCPA’S REQUIREMENTS TO THE PERSONAL INFORMATION OF RESIDENTS OF THE UNITED STATE OF AMERICA MORE BROADLY.
PLEASE READ THIS PRIVACY NOTICE CAREFULLY BECAUSE IT PROVIDES IMPORTANT INFORMATION AND EXPLAINS YOUR RIGHTS. PLEASE VISIT THIS WEBSITE FROM TIME TO TIME, AS WE MAY UPDATE OUR NOTICE FOR CHANGES IN THE LAW OR OUR DATA PRACTICES. IF YOU HAVE ANY QUESTIONS OR CONCERNS, OR WISH TO EXERCISE YOUR PRIVACY RIGHTS, WE INVITE YOU TO CONTACT US BY ANY OF THE METHODS LISTED AT THE BOTTOM OF THIS PRIVACY NOTICE.
We are Teletrac Navman US Ltd of 7391 Lincoln Way, Garden Grove, CA 92841; USPrivacy@teletracnavman.com; +1 (844) 981-1525 (“we”, “us”, “our”).
We provide location based telematics technology and services for managing mobile assets to customers. This Privacy Notice explains how we use the Personal Information we hold on prospective, current, or former customers, and the rights you may have in relation to that Personal Information.
We may use your information jointly with our affiliated operating companies worldwide and Fortive Corporation, our parent company, located at 6920 Seaway Boulevard; Everett, Washington, 98203; USA.
We take your privacy seriously. This notice:
It is routine for us to collect, process and store Personal Information about you over the course of your relationship with us.
Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include deidentified or aggregate information, or public information lawfully available from governmental records.
The following chart describes the categories of Personal Information we may have collected about you in the past 12 months and, for each category, where and why we collected it, and the categories of entities with which we shared or sold the Personal Information, if any.
| Category of Personal Information (PI) | Sources from which PI was collected | Purpose of collection | Categories of entities with whom PI was shared | Categories of entities to whom PI was sold |
| Address and other identifiers – such as name, postal address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers |
Directly from you From your employer From an agent/third party acting on your behalf, such as a distributor, one of our affiliated operating companies, a lead referral service, or a data provider who collected information from you directly or indirectly Through publicly available sources From the use of our CCTV cameras. Where we have cameras on our premises, your image and movements may be recorded. |
To contact you to discuss the services or products you receive from us To respond to any questions or concerns you have raised; To deal with administrative matters such as invoicing, renewal or to audit customer transactions To perform services on our behalf, such as customer service, processing or fulfilling orders, and processing payments To otherwise carry out our obligations arising under our contract with you and to enforce the same; To carry out anti-money laundering and other compliance checks and controls; and To verify your identity or for other fraud and/or crime prevention To debug errors in our systems; For marketing and advertising purposes For internal research, analytics and development |
Professional advisers, including accountancy and legal firms, in order to provide us with advice Service providers, including to provide and support our data management, analytics, security, and storage systems Group companies, for business and operational purposes |
In the past 12 months, we have not sold your Personal Information to any other entity; and we do not and will not sell Personal Information to third parties |
| Unique and online identifiers – such as IP address, device IDs, or other similar identifiers |
Cookies placed on your computer or mobile device when you visit our website |
For marketing and advertising purposes; and For internal research, analytics and development |
|
In the past 12 months, we have not sold your Personal Information to any other entity; and we do not and will not sell Personal Information to third parties |
| Financial information |
Directly from you Through publicly available sources From an agent/third party acting on your behalf, such as a distributor, one of our affiliated operating companies, a lead referral service, or a data provider who collected information from you directly or indirectly; |
To deal with administrative matters such as invoicing, renewal or to audit customer transactions To carry out anti-money laundering and other compliance checks and controls |
Professional advisers, including accountancy and legal firms, in order to provide us with advice |
In the past 12 months, we have not sold your Personal Information to any other entity; and we do not and will not sell Personal Information to third parties |
| Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
Directly from you From your employer From an agent/third party acting on your behalf, such as a distributor, one of our affiliated operating companies, a lead referral service, or a data provider who collected information from you directly or indirectly |
To contact you to discuss the services or products you receive from us To respond to any questions or concerns you have raised For marketing and advertising purposes To deal with administrative matters such as invoicing, renewal or to audit customer transactions For internal research, analytics and development |
Professional advisers, including accountancy and legal firms, in order to provide us with advice Service providers, including to provide and support our data management, analytics, security, and storage systems Group companies, for business and operational purposes |
In the past 12 months, we have not sold your Personal Information to any other entity; and we do not and will not sell Personal Information to third parties |
| Audio or video footage collected using CCTV cameras (only if you visit one of our premises that uses this technology) |
From the use of our CCTV cameras. Where we have cameras on our premises, your image and movements may be recorded. |
To verify your identity or for other fraud and/or crime prevention |
Service providers, including to provide and support our data management, analytics, security, and storage systems |
In the past 12 months, we have not sold your Personal Information to any other entity; and we do not and will not sell Personal Information to third parties |
| Geolocation Information |
From the product deployed by your employer. |
To otherwise carry out our obligations arising under our contract with you and to enforce the same To perform services on our behalf, such as customer service, processing or fulfilling orders, and processing payments To debug errors in our systems |
Service providers, including to provide and support our data management, analytics, security, and storage systems |
In the past 12 months, we have not sold your Personal Information to any other entity; and we do not and will not sell Personal Information to third parties |
| Inferences drawn from CCPA PI – such as individual profiles, preferences, characteristics, behaviors |
From the product deployed by your employer. |
For marketing and advertising purposes For internal research, analytics and development |
Professional advisers, including accountancy and legal firms, in order to provide us with advice |
In the past 12 months, we have not sold your Personal Information to any other entity; and we do not and will not sell Personal Information to third parties |
We will continue to collect the same categories of Personal Information listed in the chart above, for the same purposes. If this should change, we will issue an updated Privacy Notice.
The third parties with whom we share your Personal Information are bound to comply with similar and equally stringent undertakings of privacy and confidentiality.
We also share your Personal Information with third parties to comply with legal obligations; when we believe in good faith that an applicable law requires it; at the request of governmental authorities or other third parties conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our websites, our businesses, or the public.
We do not grant access to your Personal Information to any other third parties unless we say so in this Privacy Notice or unless the law requires it.
Our products and services are not directed to minors under the age of 18 and we do not knowingly collect or sell the Personal Information of minors.
We aim to protect Personal Information by using reasonable organizational, technological and physical safeguards appropriate to the sensitivity of the Personal Information we hold. We take measures, which are at least as strict as the law requires, to safeguard your Personal Information, but we cannot guarantee its absolute security.
We endeavor in good faith to adhere to self-regulatory advertising principles, such as the Digital Advertising Alliance’s Principles. If you are interested in learning more about and/or opting out of online behavioral advertising, sometimes called interest-based advertising, we encourage you to visit one of the advertising industry-developed opt-out pages, such as www.youradchoices.com or aboutads.info. Please note that while we provide these links for your convenience, we do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.
No, we do not respond to browser or do not track signals.
If you are the account owner or have permission to access the account, you can log in and manage requests for access or deletion that you receive. You can also submit access and deletion requests by using the contact details set out at the end of this Privacy Notice.
We do not and will not sell Personal Information to third parties.
WE ARE COMMITTED TO HONORING YOUR RIGHTS
We are committed to providing Consumers control over their Personal Information. If you exercise any of the rights explained in this Privacy Notice, we will continue to treat you fairly. In particular, this means that Consumers who exercise their rights under this Notice will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than other Consumers.
CALIFORNIA SHINE THE LIGHT
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents to annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year.
To exercise any of the rights above, or to ask a question, contact us at +1 (844) 981-1525, click here or use the contact details set out at the end of this Privacy Notice.
For requests for access or deletion, we will first acknowledge receipt of your request within 10 days of receipt of your request. We provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we’ll let you know.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.
In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavour to provide you with an explanation as to why.
IF YOU MAINTAIN A PASSWORD-PROTECTED ACCOUNT WITH US
We will verify your identity using a two-step process. We will first ask you to log into your account, and we will then ask you to separately authenticate your identity by asking you a series of questions.
If we are unable to verify your identity through your password-protected account with a reasonable degree of certainty appropriate to the nature of your request, for security reasons, we may ask you to verify your identity in accordance with the additional requirements described below.
REQUESTS FOR SPECIFIC PIECES OF PERSONAL INFORMATION
We will ask you for at least three pieces of Personal Information and endeavour to match those to information we maintain about you. Additionally, we require that you provide a declaration attesting to your identity, signed under penalty of perjury.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial. Additionally, we will treat the request as one seeking disclosure of the categories of Personal Information we have collected about you and endeavour to verify your identity using the less-stringent standards applicable to such requests.
REQUESTS FOR CATEGORIES OF PERSONAL INFORMATION COLLECTED ABOUT YOU
We will ask you for at least two pieces of Personal Information and endeavour to match those to information we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of our denial.
REQUESTS FOR DELETION OF PERSONAL INFORMATION WE HAVE COLLECTED FROM YOU
We will ask you for at least two pieces of Personal Information and endeavour to match those to information we maintain about you.
If we are unable to verify your identity with the degree of certainty required before providing you with the information requested, we will notify you to explain the basis of our denial.
AUTHORIZED AGENTS – ADDITIONAL VERIFICATION REQUIRED
You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process. You will be required to verify your identity by providing us with certain Personal Information as described above, depending on whether you hold an account with us or not and the nature of the information your require, which we will endeavour to match the information submitted to information we maintain about you. Additionally, we will require that you provide us with written confirmation that you have authorized the agent to act on your behalf, and the scope of that authorization. The agent will be required to provide us with proof of the agency relationship, which may be a declaration attesting to the agent’s identity and authorization by you to act on their behalf, signed under penalty of perjury. If the agent is a business entity, it will also need to submit evidence that it is registered and in good standing with the California Secretary of State. Information to identify and verify your agent can be submitted through the same mechanism and at the same time that you submit information to verify your identity.
If you have questions on the processing of your Personal Information, would like to exercise any of your rights, or are unhappy with how we’ve handled your information, please contact us here: Teletrac Navman US Ltd of 7391 Lincoln Way, Garden Grove, CA 92841, or through our website form.
If you would like to assert your privacy rights, you may also call us toll free at +1 (844) 981-1525 or submit a request online here.
We will review and update this Notice periodically in light of changing business practices, technology, and legal requirements. If we make a significant or material change in the way we use or share your Personal Information, you will be notified via email or a notice on our website.