Last Modified: January 9, 2024
- Types of Information We Collect and How We Collect It
The categories of personal information that we might obtain from you through your interaction with us may include: Identifiers such as your name, address, email, phone number, username, or other similar fields of information; Internet or Network Activity Information related to your interaction with our websites or Services, or Audio, Electronic, Visual, or similar information where the Services or your interactions with us include audible communication or your presence on visual media (e.g., as part of our dashcam services). There may also be times where we obtain geolocation, telemetry, or movement data sufficient to draw an inference about your driving activity from your interaction with us if that interaction involves you being an End-User or the passenger of an End-User (see “Customer Data” below).
We use this information to operate, maintain, and provide to you the features and functionality of our websites, Platform, and Services, as well as to work with third parties who might market relevant services to you, communicate directly with you, such as to respond to your inquiries, to send you newsletters or email messages about products and services that may be of interest to you, or to otherwise generate revenue in connection with our Services. We may also send you company-related emails or messages (e.g., account verification, billing confirmation, changes or updates to features of the Services, technical and security notices). For more information about your communication preferences, see “Control Over Your Information” below.
Like most websites and online services, we and certain of our third-party providers may collect certain types of usage information automatically when you visit our websites, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, Flash cookies (locally stored objects), embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). These tracking technologies collect information about how you use our websites (e.g., the pages you view, the links you click, and other actions you take on our websites), information about your browser and online usage patterns (e.g., IP address, browser type, browser language, referring / exit pages and URLs, pages viewed, whether you opened an email , links clicked), and information about the device(s) you use to access our websites (e.g., mobile device identifier, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, and depending on your mobile device settings, your geographical location data (which could include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device), or we may be able to approximate a device’s location by analyzing other information, like an IP address). We, or our third party providers, may link your various devices so that content you see on one device can result in relevant content displayed on another device (which may include marketing information related to products or services that may be of interest to you), and so that we may recognize and contact you on the various devices you may use. We may also collect analytics data, or use third party analytics tools, to help us measure traffic and usage of the website or Services. Although we do our best to honor the privacy preferences of our visitors, the Services are not configured to respond to Do Not Track signals from your browser.
We may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites; (b) provide custom, personalized content and information, including content (which may include marketing information related to products or services that may be of interest to you)*; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our websites and Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our websites; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our websites and Services.
If you would prefer not to accept cookies, please click here and adjust your preferences accordingly. Please note this opt-out tool is device and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that disabling cookies may negatively impact your experience using our websites, as some features on our websites may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects – including how to manage privacy and storage settings for Flash cookies – on Adobe’s website. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.
*For more information about our use of tracking technologies to display marketing information to you, please see “Third Party Tracking and Online Advertising” below.
We use certain types of cookies which are “Strictly Necessary”, “Functional”, “Performance” or “Targeting and Advertising” cookies. Please note that if you elect not to receive cookies, certain features or functionality of the Services which depend on Strictly Necessary Cookies or Functional Cookies may not function properly.
Strictly Necessary cookies are cookies that are indispensable due to the fact that the functionality of the Services is contingent on their existence. The Strictly Necessary cookies do not conserve information once you leave the site. They permit us, for example, to identify the terminals to dispatch the communication, to assign numbers to the data “packets” in order to dispatch them in the requested order, and to detect transmission errors or data loss.
Functional cookies are used exclusively for providing an electronic communication service at the request of the internet user. The information is conserved beyond your browsing session on the internet website, and can be transmitted to partners, uniquely for means of changing the way the services behave or look. These can be, for example, cookies that save the preferences of the user such as language preference of the user, cookies that save a “user session”, or cookies that provide a “virtual shopping basket”.
Performance cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Services. They help us to know which components of our Services are the most and least popular and see how visitors move around our Services. These cookies assist us in improving our websites, online services, and marketing communications.
Targeting and Advertising cookies may be set through our Services by our third-party partners and providers. They may be used by those companies for analytics and to build a profile of your interests and show you relevant advertisements on other websites. These cookies record interactions with our websites, online services, and marketing advertisements. They may also record the location from which you are accessing our content.
*For more information about our use of tracking technologies to display marketing information to you, please see “Third Party Tracking and Online Advertising” below.
- When We Disclose Personal Information
We may share your personal information in the instances described below, in each case subject to any relevant restrictions of applicable law (which may include providing you with the opportunity to opt out of or object to such sharing where such a right is provided under applicable law). For further information on your choices regarding your information, see “Control Over Your Information.”
We may share your personal information with third party providers or business partners who help us deliver or improve our websites and Services or who perform services on our behalf. These services may include identifying and serving advertisements that may be of interest to you, processing payments, sending postal mail, providing back-office services, or measuring site traffic. These third party providers or business partners are legally obligated to keep the personal information we share with them confidential and secure and to use your personal information on the basis of our instructions only. In compliance with applicable law, we may also disclose your information to third parties who may send you information about products and services you may enjoy.
We may aggregate, or anonymize, and then share that aggregated or anonymized information with third parties, including data brokers and other business partners, for our business purposes. In some cases, we may aggregate and share data that includes geolocation information and therefore may be considered personal information under applicable law or that could be used to identify an individual. Where permitted by law, we might disclose this personal information for monetary consideration in furtherance of our business purposes or the business purposes of third parties with whom we conduct business.
We may share or disclose your personal information if we determine, in our sole discretion, that such action is reasonably necessary to (a) comply with the law, regulatory requirements or the reasonable requests of law enforcement; (b) if we reasonably believe disclosure is necessary to prevent harm or financial loss, or in connection with detecting or preventing fraud, intellectual property infringement, piracy, or other unlawful activity, (c) to exercise or protect the rights, property or personal safety of the company, our employees, customers or others, and/or (d) to enforce our Terms and Conditions.
- Customer Data
Our Customers may provide data to our Services or otherwise provide data which may include personal information or other information about our Customer or our Customers’ End-Users (all of which we call “Customer Data”), but this definition does not include Fleet Data. “Fleet Data” means any information or data generated by NexTraq Equipment, including but not limited to a vehicle mounted wireless tracking device (“Tracking Device”), and the provision of the Services, including geolocation, telemetry and movement data, information that comes from the vehicles, and information that incorporates or is derived from the processing of such information or data, and all other data made available by us through the Platform for the purpose of providing the Services to you. Customer Data is controlled by our Customers, but Customer acknowledges that NexTraq shall have the right to license this data to third parties pursuant to its Customer Agreements.
Customer is solely responsible for the placement of each Tracking Device and the corresponding collection of Fleet Data associated with the vehicle in which the Tracking Device is placed, and for compliance with all laws and best practices associated with the collection of Fleet Data, including providing notice to and obtaining consents from End-Users, if necessary for such collection. We may associate Fleet Data with Customer Data according to the settings and functionality of the Services utilized by the Customer. We collect and process Fleet Data in accordance with our Customer Agreements.
Further, depending on the functionality and Services purchased by a Customer, the Customer may direct End-Users (for example, Customer employees or drivers) to download and utilize our mobile application (“App”). If you download and use the App from a personal device, we may collect certain information about you, your device, your location, and your usage of the App. For example, we collect your user login and any personal information you or our Customer associate with the account, a mobile device identifier and other information associated with the mobile device, such as the make and model of the device and operating system and device phone number, and we may associate this information with Customer Data and Fleet Data. We consider information we collect from your use of the App to be Customer Data, which we collect and process in accordance with our agreements with our Customers.
If you are an End-User, please address all questions relating to the collection and use of Customer Data and/or Fleet Data to the Customer responsible for the account.
- Control Over Your Information
Email Communications. From time to time, we may send you emails regarding updates to our websites, products or services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “Unsubscribe” link provided at the bottom of the email communication. Note that you cannot unsubscribe from certain company-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
Modifying Account Information. If you have an online account with us, you have the ability to modify certain information in your account (e.g., your contact information) through “profile,” “account,” “settings,” or “preferences” options provided on the Services. Please note that NexTraq does not own or control the Customer Data submitted to or collected by our Services by or on behalf of our Customers, and NexTraq cannot modify or delete Customer Data except at the request of our Customer, or as permitted by our Customer Agreements. We aim to maintain our Services in a manner that protects information from accidental or malicious destruction. Because of this, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.
- Third Party Tracking and Online Advertising
We may from time to time participate in interest-based advertising and use third party advertising companies to serve you marketing content based on use of the Services. We may permit third party online advertising networks, social media companies and other third party services, to collect information about your use of our websites over time so that they may play or display ads on our websites, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited a website and other information. We may also share a common account identifier (such as an email address or user ID) to help us identify you across devices. We and our third party providers use this information to make the advertisements you see online more relevant to your interests.
As noted above, if you would prefer not to accept cookies, please click here and adjust your preferences accordingly. Please note this opt-out tool is device and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” / “ask app not to track” (iOS) or “opt-out of interest based ads” (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices and/or the Digital Advertising Alliance’s resources at www.aboutads.info/choices. Some of these opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers or delete the opt-out cookie, you may need to perform the opt-out task again.
- Data Protection and Security
Data Retention: We maintain standard data retention policies in the ordinary course of our business based on the type and nature of data collected and the purposes for which it is collected and/or used. We will retain all categories of your personal information referenced above in Section 1 for so long as you are a customer and/or are otherwise using the Services, and afterwards in accordance with our ordinary data retention policies then in effect, excluding Fleet data, which may not be subject to deletion. Following termination or deactivation of your account, we may also retain information for a commercially reasonable time for recordkeeping, audit or other purposes, as permitted by applicable law. Any Customer Data that we have access to shall be retained, stored, or deleted according to our Customer Agreements. Notwithstanding the other provisions of this section, we may retain information where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
Keeping information safe: We use commercially reasonable physical, technical and organizational measures designed to preserve the integrity and security of all information we collect. However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. The safety and security of your information also depends on you. Where you have chosen a password to access the Services, you are responsible for keeping this password confidential. We ask that you not share this password with anyone. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted via our Services. Any transmission of personal information is done at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. The safety and security of your information also depends on you. Where you have chosen a password to access the Services, you are responsible for keeping this password confidential. We ask that you not share this password with anyone.
- Links to Third Party Websites and Services
The Services may contain links to webpages operated by parties other than NexTraq. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to you to take precautions to ensure that whatever links you select or software you download (whether by using the Services to access websites or otherwise) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. Other websites and services may have their own privacy policies, which you will be subject to upon linking to the other third party’s website. NexTraq strongly recommends that you review the other third party’s terms and policies.
- Children’s Privacy
Our Services are not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on our Services or on or through any of its features/register on the Services, use any of the interactive or public comment features of this Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 years of age without verification of parental consent, we will delete the information. If you believe we might have any information from or about a child under age 16, please contact us at as set forth in the contact section below.
- Data Subject Rights Related to Personal Information
Right to Know or Access (applicable for California, Canada, Australia and New Zealand residents)
Subject to applicable law, you have the right to know and request a copy of the personal information we collect, use, disclose or sell. The specific information you are entitled to may vary depending on your country or, for U.S. residents, your state.
For California residents you can request a listing of the categories of personal information we have collected, the sources of that information, the purposes for which that information was collected, the categories of personal information disclosed to third parties (if any), and the categories of recipients to whom this personal information were disclosed, the categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold, the categories of personal information shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for these purposes, and the specific pieces of personal information that we maintain about you.
For Canadian residents you may request information about the information we maintain, as well as the use and disclosure of your personal information. We will contact you to obtain informed consent prior to selling any of your personal information, as contemplated by applicable Canadian law.
For Australian and New Zealand residents, you may request confirmation of whether we have any personal information about you and obtain a copy of that information.
When the collection or disclosure of your Personal Information is necessary for the fulfillment of our Services, any such disclosure shall be deemed a condition of service. In those situations, while we do not discriminate against individuals for exercising their privacy rights, the consequences of asking us not to process any of your personal information would be an inability to provide you with access to our Platform or our Services.
Right to Correct or Amend (applicable for Canada, Australia, New Zealand and California residents)
Subject to applicable law, you have the right to request that personal information we maintain about you be amended or corrected. Canadian residents also have the right to challenge the accuracy of completeness of data.
Right to Delete (applicable for California residents)
Subject to applicable law, you have the right to request that we delete personal information collected or maintained by us. Note that in some cases data may be exempt from deletion or need to be routed to a business responsible for your data who transmitted it to us.
Right to Opt-Out of the Sale of Personal Information (applicable for California and Nevada residents)
Subject to applicable law, you have the right to opt-out of the sale of your personal information.
Right to Opt-Out of the Sharing of Personal Information for Targeted Advertising Purposes (applicable for California residents)
Subject to applicable law, you have the right to opt-out of the sharing of your personal information to third parties for cross-context behavioral / targeted advertising purposes.
Right to Limit the Use of Sensitive Information (applicable for California residents)
Subject to applicable law, you have the right to direct us to limit the use of your sensitive personal information to certain purposes, including limiting the use of your sensitive personal information to perform the services or provide the goods reasonably expected by an average individual who requests those goods or services.
Right to Submit a Complaint (applicable for Australian residents)
You have the right to submit a complaint about a perceived breach of the Australian Privacy Principles, or a registered APP code (if any) that you believe NexTraq must abide by, and to request information about how NexTraq will deal with such a complaint. You may submit a complaint to our Privacy Officer through the webform below and any such complaint will be investigated and addressed by our Privacy Officer and Legal department.
Right to Non-Discrimination (applicable for California residents)
Subject to applicable law, you have the right not to receive retaliatory or discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner. In addition, the exercise of the rights described above may result in a different price, rate, or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
To Exercise Your Privacy Rights
To exercise any of the above rights available to you under applicable law, please submit your request through our webform or by calling 1-888-971-3804.
We may need to verify your identity and confirm you are a resident of a region that offers the requested right(s) before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests to include name, email address, and country / state of residency. Although we try to limit the personal information collected in connection with a request to exercise any of the above rights, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of one of the eligible regions.
Authorized Agents (applicable for California residents)
If you would like, you may designate an authorized agent to make a request under California law on your behalf. We will deny requests from agents that do not submit proof of authorization from you. To verify that an authorized agent has authority to act for you, we may require a valid a power of attorney or require that you provide the authorized agent with written permission containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. In certain circumstances, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
- Additional California Disclosures
In the last 12 months, we have collected the following categories of personal information from individuals from the following sources, used such personal information for the following purposes, and disclosed such personal information to the following categories of third parties:
|Type of Information
|Categories of Sources
|Business or commercial purposes
|Third parties with whom disclosed or to whom sold
|Identifiers such as a real name, postal address, unique personal identifier, email address, telephone number, account name, driver’s license number, passport number, or other similar identifiers.
|Provided directly by customers
|To provide services, facilitate advertising / sales, complete or perform under contracts, and for specified uses requested by an individual
|Third party advertisers and marketing vendors
|Online identifiers, Internet Protocol address, Internet or other electronic network activity information, e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
|As described above
Third party advertisers and marketing vendors
|Commercial information, including records of personal property, products or services purchased, obtained, or considered, payment information, content provided in connection with our Services, or other purchasing or consuming histories or tendencies.
|Website, tracking devices and customer agreements
|To provide services, facilitate advertising / sales, and conduct internal operations
Third party advertisers and marketing vendors
|Geolocation data, including related driving behavior data, such as telemetry or movement data.
|To provide services and sales to third parties
Third party analytics companies
|Audio, electronic, visual, thermal, olfactory, or similar information.
|To provide services
|Professional or employment-related information.
|Provided by individual
|To facilitate employment-related activities and our relationship with the business you represent
|Customers (where you represent the Customer)
|Inferences drawn from any of the above information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|Inferred from other personal information
|To provide services and facilitate advertising / sales
Third party advertisers and marketers
Sensitive Personal Information
The following personal information elements we collect may be classified as “sensitive” under California law (“sensitive personal information”):
- Account name and password;
- Driver’s license number or passport number;
- Credit/debit card number plus expiration data and security code (CVV);
- Precise geolocation data.
We use account name and password, as well as payment card information and driver’s license number / passport number to provide certain of our Services. We also use precise geolocation data to provide our Services with geolocation capabilities.
We may at times receive, or process personal information to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.
- Compliance and Cooperation with Regulatory Authorities
- International Transfers
Your personal information may be transferred to countries outside of the country in which we collect it. If we transfer your information to a country outside of the country in which we collect it, we will comply with applicable law, including any requirements related to ensuring that data is transferred with appropriate safeguards, or to a destination that provides a comparable level of safeguards to the country from which it originated.
While this list is not inclusive of all potential destinations, the countries that we reasonably anticipate we may end up transferring data to are the United States of America, Brazil, Canada, Australia, New Zealand, France, and India.
- Contact Us
ATTN: Corporate Data Privacy Officer
1200 Lake Hearn Drive, Suite 500
Atlanta, GA 30319