FleetSharp's Privacy Policy

Effective Date: October 15, 2024

This Privacy Policy explains how FleetSharp collects, uses, discloses, maintains and otherwise processes the personal information described in this Policy, as well as the rights and choices individuals have regarding such personal information. By using our Services, you consent to the collection and use of your personal information by FleetSharp.

Our Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use it; (4) how we may share it; (5) the choices we offer, including how to access and update it; (6) and the measures we take to keep your information safe. Specifically, our Privacy Policy covers the following topics:

• Scope and Background

• Personal Information Collected and Processed

• Disclosures of Personal Information

• Aggregate and De-identified Data

• Cookies, Analytics, and Advertising

• Your Rights and Choices; Governing Law, Venue and Binding Arbitration

• Third-Party Services

• Children’s Privacy

• Data Security

• Data Retention

• Data Transfers

• Changes and Updates to this Policy

• How to Contact Us

• Additional Privacy Information for Certain Jurisdictions
  

SCOPE AND BACKGROUND

This Policy applies to the personal information that FleetSharp obtains related to:

• Our website www.fleetsharp.com, affiliated websites and the services available through our websites, as well as any related products, websites, downloadable software, applications, and other services provided by us that display or include a link to this Policy (collectively, together with the websites, our “Services”)

• Our current, former and prospective customers

• Individuals who request or register to receive news, information and marketing communications from us

• Individuals who participate in surveys or research conducted by us.

Other Notices and Terms. This Policy is incorporated into and is subject to the FleetSharp Terms of Service (available at https://www.fleetsharp.com/terms). Capitalized terms used but not defined in this Policy have the meaning given to them in the FleetSharp Terms of Service. In some cases, additional or supplemental privacy notices may be provided and will apply to certain personal information collected and processed by FleetSharp. For example, we may provide an additional notice to provide more specific information about how we use and disclose personal information if you choose to take advantage of a particular partner promotion. The additional notice will control in the event of a conflict with this Policy, with respect to processing of personal information that is subject to that additional notice.

PERSONAL INFORMATION COLLECTED AND PROCESSED

We obtain personal information about you from various sources as described below. In some cases we may not be able to provide our Services to you without this information.

Personal Information Collected Directly

• Account registration. If you purchase or use FleetSharp Devices or Services, then you must provide us with your name, email address, and a password to create an account and user profile. We also require a physical address in the event of a purchase.

• Payment and billing information. When you make payments for our Devices and Services, you may need to provide personal information to our third-party service providers, such as your credit card number and billing address.

• Communications. We will collect information you provide us through your communications (e.g., when you communicate with customer support).

Personal Information Collected via Automated Means

In addition to information that you provide directly, we may collect information about you via automated means, such as cookies, web beacons and similar technologies, including:

• Cookies and similar technologies. When you use our Services, we may send cookies (small text files containing alphanumeric characters) to your device. These cookies will be provided to us by your browser on subsequent visits to our Services. We may also use other technologies like clear gifs. For more information on our use of cookies and similar technologies, see the “Cookies, Analytics, and Advertising” section.

• Location information. We collect your location information when you use our Devices and Services. Your location can be determined by: GPS, IP address, and things near the Device, such as Wi-Fi access points and cell towers. We may associate such location data with the Personal Information you provide to us. We use such information to deliver our Service to you. When you use our Mobile Applications, we may display your device’s current location, but this is not stored or transmitted anywhere.

• Dashcam information. We sell connected dashcams which collect video from our customers. We do not sell or distribute these videos anywhere. You may save a copy of the videos to your own computer. We automatically delete stored videos after a maximum of one year.

Personal Information Obtained from Third Parties

In accordance with applicable laws, we may collect personal information about you from third-party sources, such as public databases, joint marketing partners, social media platforms or other third-party platforms. In many cases you can control what personal information you share with us through privacy settings available on such third-party platforms and social media services.

In addition, we may receive leads from third parties about businesses that may be interested in our Services.

Customer Data Processed by FleetSharp

Our customers purchase and use FleetSharp’s Devices and Services to monitor and manage their personal and business vehicles and assets, including to engage with their own current, former and prospective clients and personnel (referred to as “end users” herein). In providing our products and services, FleetSharp may collect and process Customer Data, including personal information about end users, on behalf of that customer. This may include, for example, name, address and contact information, payment and billing details, and other customer information.

USE OF PERSONAL INFORMATION

The purposes for which we may process personal information will vary depending upon the circumstances. In general, we use personal information for the following purposes:

• Providing Services and support. To provide and operate Services, communicate with you about your use of our Services, provide technical support, respond to inquiries, fulfill your orders and requests, process your payments, and for similar service and support purposes.

• Analyzing and improving Services, Websites and our business. To better understand and analyze how users access and use our Services, for research and analytical purposes, to evaluate and improve our Services and business operations and to develop new services and features.

• Advertising and marketing: In accordance with applicable laws, to promote our products and services, including on third-party websites, as well as for direct marketing purposes, including to send you newsletters, client alerts and information we think may interest you.

• Protecting our business and preventing misuse. To protect our Services and our business operations; to prevent and detect fraud, illegal or unauthorized activities and access, and other misuse; to investigate potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Service or this Policy.

• Complying with legal obligations. To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.

• Related to our general business operations. To consider and implement mergers, acquisitions, reorganizations, and other business transactions, and where necessary to the administration of our general business, accounting, recordkeeping and legal functions.

• FleetSharp affiliates and subsidiaries. We may disclose personal information about you with our affiliates and subsidiaries.

• Service providers. We work with third party service providers to provide website or application development, IT, system administration and hosting, maintenance, credit card processing, research and analytics, marketing, customer support and data enrichment and other services. These third parties may have access to or process your personal information as part of providing those services for us. We limit the information provided to these service providers to that which is necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

• To protect and enforce our rights. We also reserve the right to disclose your information in order to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Services and any facilities or equipment used to make the Services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

• In case of merger, sale, or other asset transfer. Information about our users, our customers and their end-users and end-customers, including personal information, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any potential or actual merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

• With your consent. We also may disclose your personal information as described in an additional notice, at the time the information is collected, or in any other manner to which you consent, or as otherwise required or permitted by law.

AGGREGATE AND DE-IDENTIFIED DATA

We may use and disclose aggregate, anonymous and other non-identifiable information that is not linked to a particular person, which may include deidentified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device), to analyze, improve and develop our business, products and Services, and for research and analytics purposes. Where we use, disclose or process deidentified data we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws.

COOKIES, ANALYTICS AND ADVERTISING

We and our third-party service providers use cookies, pixels, javascript, log files, and other mechanisms to automatically collect information on our Services. The automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use our Services, the pages or other content you view or otherwise interact with on our Services, and the dates and times that you visit, access, or use our Services. We use this information to assess how many users access or use our Services, how they interact with our Services, which content, products, and features of our Services most interest or are of most value to our users, what types of offers and incentives our customers and their end-customers respond to, and how our Services perform from a technical point of view. We and the third parties we work with may also use cookies and similar mechanisms to improve our ad campaigns and reach people with more relevant ads and content.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process or to allow us to track your activities while using our Services. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. Please review your web browser “Help” file to learn the proper way to modify your settings regarding such automated data collection. Please note that if you delete, or choose not to accept, such technologies from our Services, you may not be able to utilize the features of our Services to their fullest potential.

Clear GIFs, Pixel Tags. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs in connection with our Services to, among other things, track activities of users of our Services, help us manage content, and compile statistics about usage of our Services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Log Files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.

Advertising. We work with third-party ad networks, analytics companies, measurement services and others (“third party ad companies”) to manage our advertising on third-party sites, mobile apps and online services. We and these third-party ad companies may use cookies, pixel tags, and other tools to collect activity information on our Services (as well as on third-party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers. This information is used to provide you with more relevant ads and content and to evaluate the success of such ads and content.

Do Not Track. Some web browsers incorporate a “Do Not Track” feature. Because there is not yet an accepted standard for how to respond to Do Not Track signals, our Services do not currently respond to such signals.

YOUR RIGHTS AND CHOICES; GOVERNING LAW, VENUE AND BINDING ARBITRATION

You may have rights under the applicable privacy laws of your state, including (subject to limitations); the right to access and review your personal information held by us, to request the amendment of incomplete or inaccurate information, to request deletion of certain personal information, and to lodge a complaint regarding our privacy practices. You may submit a request to us to exercise your privacy rights, as applicable, by contacting us at privacy@fleetsharp.com. We will respond to your request as required under applicable privacy laws and we will request that you provide certain information to enable us to verify you and your request. In any event, you may ask us to delete your personal information, and we will make our best, commercially reasonable effort to comply with your request.

In addition, you may have other rights and choices regarding your personal information as described in this section. Your rights and choices shall be governed by and construed and enforced in accordance with the laws of the State of Missouri, except to the extent preempted by U.S. federal law, without regard to conflict of law rules or principles (whether of Missouri or any other jurisdiction) that would cause the application of the laws of any other jurisdiction. Any dispute between the parties shall be subject to binding arbitration in St. Louis County, Missouri. For additional information see the FleetSharp Terms of Service (available at https://www.fleetsharp.com/terms).

Account Information. You may decline to share certain personal information with us, in which case we may not be able to provide you some or all the features and functionality of our Services. You may update, correct, or delete your profile information and preferences at any time by accessing your account settings page on the Services. If you are not a registered user of our Services, if you wish to access or amend any other personal information we hold about you, or if you would like to request that we delete any information about you that we have obtained, you may contact us at privacy@fleetsharp.com. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, to the extent permitted under applicable law.

Opt-Out. If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other communications that we may send to you from time to time, by emailing your request to privacy@fleetsharp.com.

Please be aware that if you opt-out of receiving commercial email from us, it may take up to ten business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive transactional and administrative messages from us regarding our Services.

Integration. We may allow you to enable certain third-party integrations, to integrate your FleetSharp account or certain data with third party services and platforms. However, please keep in mind that we cannot control the actions of others with whom you may choose to integrate or share your information. Further, even after information posted on our Services is removed, caching and archiving services may have saved that information, and others, including third parties, may have copied or stored that information.

THIRD PARTY SERVICES

This Policy applies only to the processing of your personal information by FleetSharp. The Services may contain features or links to websites and services provided by third parties. The policies and procedures described in this Privacy Policy do not apply to third-party sites. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through our Services. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

CHILDREN’S PRIVACY

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under the age of 18 other than location or dashcam information with the permission of a parent. If you are a parent or guardian and discover that your child under 18 years of age has obtained an account on our Services, then you may alert us at privacy@fleetsharp.com and request that we delete that child’s personal information from our systems.

DATA SECURITY

We take commercially reasonable steps to protect the personal information that we collect. Regardless of the precautions taken by us, we cannot ensure or warrant the security of any information you transmit to us and there is no guarantee that there will be no unauthorized access, use, disclosure or processing of personal information or that there will not be any breach of our physical, technical, or managerial safeguards.

DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. After expiration of the applicable retention periods, your personal information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data. In some cases, we may choose to retain certain information (e.g., insights about use of Services) in a depersonalized or aggregated form.

DATA TRANSFERS

Our Services are intended for customers located within the United States and Canada. If you choose to use our Services from other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services. You acknowledge that the governments, courts or law enforcement or regulatory agencies in the U.S. or those jurisdictions may be able to obtain disclosure of the personal information through the laws of the applicable jurisdiction. By providing any information, including personal information, on or to our Services, you consent to such transfer, storage, and processing.

CHANGES AND UPDATES TO THIS POLICY

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through our Services. If the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, include messages in your invoice, or generate a notification when you access our Services for the first time after such material changes are made. Your continued use of our Services after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.

CONTACT US

If you have any questions or comments about this Policy, your personal information, our use and disclosure practices, or your consent choices, please contact us at privacy@fleetsharp.com.

ADDITIONAL INFORMATION FOR RESIDENTS OF JURISDICTIONS WITH ADDITIONAL PRIVACY REQUIREMENTS

This section supplements the information and disclosures contained in our Policy and only applies to individuals residing in California and certain other states with state privacy laws from whom we may collect personal information.

During the last twelve (12) months, we have collected the following categories of personal information from consumers.

Please contact us at privacy@fleetsharp.com if you have any questions or concerns about any privacy matters or opt-out rights under your applicable state laws.

Apollo ELD Privacy Policy

Client Information
To have access to our web-based applications, a user is required to create an account. Information gathered at the time of account creation is used for internal use only. We will never sell, distribute, or share your information to any third party for any reason.
You may also have to enter personal or company information. You will be able to change your information at any time using the links in the online applications.

Use of Background Location
The APOLLO ELD apps collects coarse location, while in background, to detect when a vehicle crosses a United States’ state border. Current user location is not shared and coarse location is only used to calculated miles traveled on each state which is used on IFTA reports.

Log Files and Storage of System Information
The application will gather certain information automatically and store it in log files. This information may include IP addresses, browser type, referring/exit pages, operating system, as well as date/time stamp data. We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number) and will use this information in our development efforts to provide our customers with the best experience possible when using our applications, analyze trends, track how visitors interact with our site and applications and for internal administrative purposes.

Legal Access to Your Information
We may share access to your personal and company information, when necessary, under the following conditions to:

• adhere to a request made by a governmental, official or other departmental agency
• enforce violations to our privacy policy or terms of use
• prevent, detect or otherwise enforce anti-fraud laws and statutes
• protect our company and it’s partners from any acts of copyright infringement as permitted by law.

Personal Information Protection
The application provides many layers of security to preserve the confidentiality of our customers information. Data security includes physical, electronic, administrative and managerial procedures. Although transmission of data over the internet or other public network can be guaranteed to be 100 percent secure, we make reasonable efforts to secure your personal information once we receive it, but we cannot guarantee the security of information you send to us.
The application does not store credit card numbers on our servers. Any credit card information submitted, utilize a credit card authorization service for security purposes that in turn provides ATS with credit card validation information only and we do not have access to your personal financial data. Any personally identifiable information entered into our web applications is encrypted and stored as tokenized values. Information that is uploaded using our web applications are encrypted as well.
Our server environment uses advanced firewall and other security technologies. Our website and applications use strong encryption techniques that provide safeguards to help ensure that our clients information is safe.

Some of the information security safeguards that the application has put in place include:

• Advanced access security measures have been taken to help guard against unauthorized access.
• SSL encryption is utilized throughout our applications which help ensure data transmissions are kept confidential.
• Unique system user name’s and passwords also help guard against unauthorized access. It is our customers responsibility to guard against user name and password leak.
• Access security is provided by segregated network architecture, hardened server configurations, and redundant firewalls. Internet-based attacks are stopped through the use of redundant state-of-the-art firewall technology and hardened server configurations.
  

The internet is a constant source of external threat. We have taken great measures to ensure all of our customer information is kept safe by the above-mentioned means.

Steps we have taken to safeguard your online account and data:

• State of the Art encryption methodologies including SSL has been put into place ensuring not only account access is kept secure but is also used in data transmissions throughout our systems.
• Detailed logs are kept with regard to system access as well as system usage to help maintain the highest level of security.
• Along with advanced encryption technologies, our systems utilize the latest in firewall and intrusion detection technologies to guard against external attacks on our systems and our customers data information.

California Privacy Policy Act
The application fully comply with the California Online Privacy Protection Act. We will not distribute your personal information to outside parties without your consent.
Further, all users of our website and applications may make any changes to their personal information at any time by following the links provided.

Information Obtained From Third Parties
The application and our organization do not trade, share, sell or otherwise distribute any customer information to third parties. Occasionally we may utilize lists acquired from third parties for sending brochures, and other information relevant to our products and services. These correspondence are not meant to be intrusive and the data obtained from these marketing measures will strictly be used internally.