Last updated May 12, 2021
Thank you for choosing to be part of our community at GuardTrax LLC ("Company", "we", "us", "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
When you use our mobile application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include the App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.
This privacy notice applies to all information collected through our Services (which, as described above, includes our App), as well as, any related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
In Short: We collect information regarding your geolocation, mobile device, push notifications, when you use our App.
If you use our App, we also collect the following information:
Geolocation Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's calendar, bluetooth, camera, contacts, sensors, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our App you accessed.
Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.
2. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in. If you are accessing our App from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see "WILL YOUR INFORMATION BE SHARED WITH ANYONE?" above), in and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 2 years.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the App, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the App. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at email@example.com.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short:You may review, change, or terminate your account at any time.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the App, you have the right to request removal of unwanted data that you publicly post on the App. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the App, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at firstname.lastname@example.org or by post to:
General Privacy and Security
You should understand that privacy cannot be guaranteed on wireless telephone systems, satellite transmissions or computer systems and you should take necessary efforts and precautions to protect personal information when communicating in such environments. With respect to other voice communications, GuardTrax, in conjunction with employee training, quality control, and the general provision of its products and services ("Products"), may monitor and/or electronically record any conversations with call center representatives.
GuardTrax maintains a variety of physical, electronic, and procedural safeguards to protect information about you that you have provided. For example, we take a variety of steps to protect against unauthorized access to our systems that store and process information; such as policies limiting access to those systems to authorized personnel only.
When you are accessing our services through the GuardTrax LLC’s web site, we employ the Secure Sockets Layer (SSL) protocol for the transmission of the information you send to us. We also use encryption technologies to protect your account information. You should keep your user names, passwords, and other access information safe and confidential to protect against unauthorized access to your account information and services. You must also choose passwords that others will not guess easily. You may want to change your password from time to time to increase your privacy protection.
Personal, Non-Public and Private Information
Personal information for the purposes of this Policy means information that can be used to personally identify you or is associated with any such information. In the context of this Policy:
Personal Information is information that is directly associated with a person such as their name, address, telephone number, e-mail address, activities and preferences.
Non-public Information is a subset of personal information, which is sensitive and not publicly available, such as a credit card number, social security number, or bank account information.
Private Information is a subset of non-public information and is the contents of data transmitted through GuardTrax's Telematics Gateway including, but not limited to, a user's location data.
Use of Personal and Non-Public Information
Except as part of the sale of all or substantially all of the assets of GuardTrax, GuardTrax will not sell, trade, license or otherwise disseminate your personal information to any third party without your consent.
Your Personal and Non-Public Information will only be used internal by GuardTrax LLC, its subsidiaries and affiliates to: (i) deliver the products and services as purchased or subscribed to; (ii) understand and meet your needs and preferences; (iii) develop new and enhance existing product and service offerings; (iv) manage and develop our business and operations; and (v) meet any legal and/or regulatory requirements. GuardTrax may use, disclose, sell, trade, license or otherwise disseminate aggregated data provided that the data is not linked to any specific individual's Personal or Non-Public Information.
Use of Private Information
Except as part of the sale of all or substantially all of the assets of GuardTrax, GuardTrax will not sell, trade, license or otherwise disseminate your Private Information. GuardTrax shall use commercially reasonable efforts, including, but not limited to, utilizing its proprietary data compression technology to safely transmit and receive your location data through GuardTrax's Products.
We may also log IP addresses for the purposes of systems administration or to report information in aggregate form to advertisers (e.g., how many visitors logged on to our web site). An IP address is a number that is assigned to your computer automatically when you user the internet. When you visit a particular web page in the GuardTrax web site, our servers log your IP address. We do not link your IP address to personally identifiable information.
GuardTrax reserves the right to update and/or modify this Policy at any time, should either our practices change or if the law requires changes to it. If at any point GuardTrax decides to use personally identifiable information in a manner that is materially different than what was stated at the time it was collected, we will notify you via posting on this page for thirty (30) days before the material change is made to give you an opportunity to opt out of the proposed use at any time.
If you have any questions or comments concerning this Policy as it applies to your Product, please contact our legal department or you may also write to us at GuardTrax LLC, Attn: Legal Department, 11 Commerce Drive, Lobby Floor, Cranford, New Jersey 07016.
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