Privacy Policy

Effective Date: March 17, 2019

Fleetonomy (“Fleetonomy”, “we“, “our” or “us“) develops and provides artificial intelligence-based solutions, an online platform (“Platform“) and mobile applications (“App“), which enable fleet owners, auto manufacturers and mobility service providers to maximize potential from their fleet.

Our Platform, our website available at www.fleetonomy.io (the “Site“) and the App (together with the Site and Platform – the “Services“) allow fleet owners, auto manufacturers and mobility service providers (each, our “Client”; “you”) to create new revenue streams by enhancing efficiency and generating more insights from their available data.

This Privacy Policy describes how we collect, store, use and disclose personal data regarding individuals who visit our Site (“Visitors“), or use our Services (you and your customers, the “End-Users”), and our role as “Data Processor” of our Clients’ End-Users data. It applies whenever you or the End Users visit our Services, interact with us or otherwise access or use any of our Services.

Specifically, this Privacy Policy describes our practices regarding –

  1. ‎Data Collection
  2. Data Uses
  3. Data Location and Retention
  4. Data Sharing
  5. Cookies and Tracking Technologies
  6. Communications
  7. Data Security
  8. Data Subject Rights
  9. Children’s Privacy
  10. Data Controller/Processor
  11. Additional Notices

Please read this Privacy Policy carefully and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services. You are not legally required to provide us with any Personal Data (defined below), but without it we will not be able to provide you with the full range of Services or with the best user experience when using our Services.

  1. Data Collection

We collect Personal Data regarding our Clients and their End-Users, as well as data regarding Visitors to our Site. Such data is typically collected and generated through the Visitor’s, Client’s or End-User’s interaction with our Services, through automatic means directly by such Visitor, Client or End-User; from our Clients; or other third parties.

Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data“):

  1. Data automatically collected or generated: When you visit, interact with or use our Services, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of third party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).

Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser version, locale and language settings used, the cookies and pixels installed on such device and the activity (clicks and other interactions) of Visitors, Clients and End-Users in connection with our Services. Such data does not enable us to learn a person’s true identity or contact details. We mainly use this data to gain a better understanding on how Visitors, Clients and End-Users typically use and interact with our Services; how we could improve their user experience; to optimize our marketing campaigns and ad management; and to optimize the overall performance of our Services.

  1. Data received from our Clients: You may provide us with Personal Data such as your name, workplace and position, contact details (such as e-mail, phone and address), account login details (such as usernames and hashed passwords), as well as any other data you choose to provide when you use our Services, create a Client account or contact us. Clients may also provide us with data concerning their colleagues, customers, or other individuals, in order to enroll them as End-Users to our Services. Such data usually refers to such End-Users’ names and work e-mails, however additional data may be provided at the Client’s discretion.
  1. Data received from our Clients’ End-Users: End-Users may provide us additional data when accessing our Services, such as their billing details, GPS locations, mileages and status of membership (loyalty clubs), flight details, business needs, ride preferences, trip history (pickup and drop-off locations, times, routes, price, review given, etc.), and profile picture. To the extent that such data concerns a non-human entity (e.g. the bank account of a company or business), we will not regard it as “Personal Data” and this Privacy Policy shall not apply to it.
  2. Data received from third parties: We may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or services provides, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn and Twitter.
  3. Data Uses

We use Personal Data as necessary for the performance of our Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing and advertising services, optimizing our Clients’ services and support operations, and protecting and securing our End-Users, Clients, ourselves and our Services.

Specifically, we use Personal Data for the following purposes:

  1. To facilitate, operate, and provide our Services;
  2. To authenticate the identity of our End-Users, and to allow them access to our Services;
  3. To provide our Visitors, End-Users and Clients with assistance and support;
  4. To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
  5. To contact our Visitors, End-Users and Clients with general or personalized service-related messages (such as password-retrieval or billing) and promotional messages (such as newsletters, webinars, new features, etc.), and to facilitate, sponsor and offer certain events and promotions;
  6. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
  7. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
  8. To comply with any applicable laws and regulations.
  9. Data Location & Retention

Data Location: Your Personal Data may be maintained, processed and stored by us and our authorized affiliates and Service Providers (defined below) in the USA, Europe and Israel, as necessary for the proper delivery of our Services, or as may be required by law.

Fleetonomy is headquartered in Israel, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents. While privacy laws may vary between jurisdictions, Fleetonomy and its affiliates and Service Providers are each committed to protect Personal Data in accordance with this Privacy Policy and customary industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

Data Retention: We retain End-Users’ Personal Data in accordance with the instructions of our Client, or for as long as our Client’s account is active, and we have not been notified otherwise, or as long as we consider necessary for the purposes described herein.

We keep Visitors’ Personal Data for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services.

We will also retain Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.

Please note that except as required by applicable law or our contractual obligations, we will not be obligated to retain any Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at privacy@fleetonomy.io.

  1. Data Sharing

Legal Compliance: We may disclose or allow government and law enforcement officials access to Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing and advertising services, data and cyber security services, payment processing services, End-User engagement services, e-mail distribution and monitoring services, phone and text messaging services, and our business, legal and financial advisors) (collectively, “Service Providers”). These Service Providers may have access to your our your End-Users’ Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.

Sharing Personal Data with our Clients: We may share the Personal Data of End-Users with the Client for whom we process such data. In such cases, sharing such data means that other individuals will be able to monitor, process and analyze it. Please note that Fleetonomy is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of our Client, that itself acts as the “Data Controller” of such data (as further described in Section 10 below).

Protecting Rights and Safety: We may share Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Fleetonomy, any of our End-Users or Clients, or any members of the general public.

Fleetonomy Subsidiaries and Affiliated Companies: We may share Personal Data internally within our group of companies for the purposes described in this Privacy Policy. In addition, should Fleetonomy or any of its subsidiaries or affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your and your End-Users’ Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, Fleetonomy may share your Personal Data and that of your End-Users in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.

  1. Cookies and Tracking Technologies

Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide, secure and improve our Services, personalize your and your End-Users’ experience and monitor the performance of our activities and campaigns.

A “cookie” is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the Client or End-User.

While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser and recommend the use of cookies for an optimal user experience of our Services, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

  1. Communications

Service Communications: We may contact our Clients and Visitors with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, password-retrieval notices, etc. We, or our Clients, may also send End-User notifications, messages and other updates. Typically, you and your End-Users will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.

Notifications and Promotional Communications: We may send our Clients and Visitors notifications, messages and other updates about new features, offerings, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify Fleetonomy at any time by sending an e-mail to privacy@fleetonomy.io, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

  1. Data Security

In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.

  1. Data Subject Rights

If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR), to request access to, and rectification or erasure of your Personal Data held with Fleetonomy, or to restrict or object to such Personal Data’s processing, or to port such Personal Data – please contact us by e-mail at privacy@fleetonomy.io.

Please note that once you contact us by e-mail, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.

  1. Children’s Privacy

Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at privacy@fleetonomy.io.

  1. Data Controller/Processor

Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller”, who determines the purposes and means of processing; and the “Data Processor”, who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Fleetonomy is the “Data Controller” of its Visitors and Clients’ Personal Data, and with respect to which, assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy.

If a Client submits any Personal Data concerning any of its End-Users, or otherwise has any of its End-Users submit or upload Personal Data in connection with our Services, such Client shall be deemed the “Data Controller” of its End-Users’ data, and Fleetonomy will process such data on this Client’s behalf, as its “Data Processor”. This means that in such cases, we will process such End-Users’ data on behalf of our Client, in accordance with its reasonable instructions and our commercial agreements. The Client will be solely responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).

If an End-User would like to make any requests or queries regarding Personal Data we process on our Client’s behalf, please contact such Client directly. For example, if an End-User wishes to access, correct, or delete data processed by Fleetonomy on behalf of a Client, please have such request directed to the relevant Client (who is the “Data Controller” of such data).

  1. Additional Notices

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is so published. We will provide a 10-day prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or application of such third parties and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your Personal Data, please contact us by e-mail at privacy@fleetonomy.io.

If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.