Collection of your Personal Information
Personally identifiable information or “personal information” is data that can be used to identify or contact a single person.You may provide CMT with personally identifiable information that may include, but not be limited to, your e-mail address, name, date of birth, home or work address and telephone number. Additionally, the App collects non-personal information in the form of driving data from your phone such as driving speed, time of day and GPS-based location data.
We will retain your personally identifiable information for the period necessary to fulfill the purposes outlined in this Policy unless otherwise required or permitted by law. The App is intended to collect your driving information, but may inadvertently collect the driving information of third parties with whom you are a passenger. No records will be created that identify any such third parties. As is true of most applications and websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. To collect this information, when you use the App or visit our website, a “cookie” may be set on your device or computer. Cookies contain a small amount of information that allows our web servers to recognize you whenever you visit. We store information that we collect through cookies, log files and/or clear gifs to create a “profile” of your preferences. We do not tie your personal information to information in the profile. We use this information that we collect, which does not identify individual users, to analyze trends, to administer the App, to track users’ movements with respect to the App and/or our website and to gather demographic information about our user base as a whole. We do not provide this information to outside parties other than set forth in this policy. No personal information is stored in cookies and we do not link collected data to personal information.Use of your Personal Information
The App uses your personal information to improve our services to you by improving the App‘s performance. Except as set forth in this Policy, we will not use, disclose, or transfer your personally identifiable information or the personally identifiable information of others you have provided us unless (1) you expressly authorize us to do so; (2) it is necessary to allow our service providers or agents to provide services for us, (3) it is necessary in order to provide our products or services to you (and contacting you when necessary), (4) we are sending you other information that may be useful to you, (5) subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements, (6) it is necessary to protect the confidentiality or security of your records, (7) subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all of the assets of CMT or the merger of CMT into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which CMT is not the survivor, (8) it is necessary in connection with other business purposes including, without limitation, customer care, service quality, business management and operation, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends and dispute resolution, (9) it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity; (10) it is necessary for us to provide it to our attorneys, accountants, regulators, auditors or other advisors; or (11) it is otherwise necessary for us to disclose it as required or permitted by law.
CMT may share personally identifiable information with trusted partners to help us perform statistical analysis. All such third parties are contractually prohibited from using personally identifiable information provided by the App except to provide these services to the App, and they are required to maintain the confidentiality of your information with equal or greater protections than those provided by the App. CMT will disclose your personally identifiable information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on CMT; (b) protect and defend the rights or property of CMT; and, (c) act under exigent circumstances to protect the personal safety of users of CMT or the public. CMT may also disclose personal information about you if CMT determines that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.Third Party Sites and Services
The App may contain links to third-party websites, products, and services. Information collected by third parties, which may include such things as location data or contact details, is governed by such third-party privacy practices. We encourage you to learn about the privacy practices of those third parties.Security of your Personally Identifiable Information
To make sure your personal information is secure, we communicate our privacy and security guidelines to CMT employees and strictly enforce privacy safeguards within the company. The App secures your personally identifiable information, and the personally identifiable information of others on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. However, no data transmission over the Internet can be guaranteed as 100% secure. As a result, while we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us or receive from us.Access to Personal Information
You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account. For other personal information we hold, we will provide you with access for any purpose including to request that we correct the data if it is inaccurate or delete the data if CMT is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made per the Privacy Questions section below.Collection and Use of Non-Personal Information
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where the App is used so that we can better understand customer behavior and improve our products and services.
We may collect details of how you use the App. This information may be used to improve the relevancy of results provided by the App. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.
We may collect information regarding your utilization of other applications while utilizing the App. This information may be used to improve the functionality of the App and we will not be able to identify what you are doing on any such other applications.
If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.Communications With CMT
We appreciate your questions and comments about the App and CMT and welcome your messages to recipients listed on the App including messages or emails provided to our customer support. We will share your communications with those within our organization who are most capable of addressing the issues contained in your message. We may archive your message for a certain period of time or discard it, but your e-mail address and e-mail will only be used in accordance with this Policy.Using the App From Outside the United States
If you are using the App from outside of the United States, please be aware that your information, including any personally identifiable information to which we may be given access, may be transferred to, stored, or processed in the United States. The data protection and other laws of the United States and other countries may not be as comprehensive as those in your country, but we will take strong measures to protect your personally identifiable information. By using the App, you understand that your personally identifiable information may be transferred to our facilities and to those third parties with whom we share such information as specified in this Policy. If you are in the European Union, CMT, as the data processor working in conjunction with our customers as data controllers, is committed to the delivery of solutions and services that comply with GDPR. Learn more about our GDPR policies here
.No Information Collected from Children
We understand the importance of taking extra precautions to protect the privacy and safety of children. Accordingly, we do not knowingly collect, use or disclose personal information from children under 13, or equivalent minimum age in the relevant jurisdiction, without verifiable parental consent. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, without first receiving verifiable parental consent we will take steps to delete the information as soon as possible.Changes to this Policy
We may change this Policy at any time and from time to time. The most recent version of the Policy is reflected by the version date located at the bottom of this Policy. If we make any material changes to our Policy, those changes will apply to the personally identifiable information collected after the effective date listed on the Policy, and we will notify you by placing a notice on the App‘s download page prior to the change becoming effective. We encourage all users to periodically review this Policy for the latest information on our privacy practices.California Privacy Rights and Do Not Track Disclosures
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personally identifiable information, such as name, e-mail, and mailing address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties' direct marketing purposes and (b) the name and address of all such third parties. To request the above information, please email us at firstname.lastname@example.org with a reference to California Disclosure Information.We will respond to such requests to information access within 30 days following receipt at the e-mail stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.
We treat the data of everyone who uses the App in accordance with this Policy, whatever their Do-Not-Track setting or use of any other mechanism that provides them with the ability to exercise choice about the collection of their personally identifiable information.Privacy Questions
Cambridge Mobile Telematics, 314 Main Street, Suite 1200, Cambridge, MA 02142
This Policy was last updated on March 22, 2022.
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