Cambridge Mobile Telematics, Inc. (CMT) takes your privacy seriously. This policy explains how we collect, use, and process your Personal Data as a data controller when you use our DriveWell Go Europe App.
This Policy Only Applies to the Processing or Collection of Personal Data
Personal Data means any information about an individual from which that individual can be identified.
Role as Controller
For the purposes of EU and UK data protection laws and any applicable national implementing laws, regulations and secondary legislation relating to the processing of personal data (together “Data Protection Law”), the controller is Cambridge Mobile Telematics, Inc. of 314 Main Street, Suite 1200, Cambridge, MA 02142.
Role as Processor
If you are enrolled in a telematics program with one of our customers (insurance company, etc.), you must contact them (and not CMT) regarding privacy issues and to exercise any of your privacy rights.
2. Legal Basis for the Processing
We will only use your Personal Data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
To fulfill our contractual obligations to you.
Where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests.
To comply with a legal obligation.
To the extent we process your Personal Data for any other purposes, we ask for your consent in advance or require that our partners obtain such consent.
3. Data Collection
A. Personal Data We Collect Directly from You
The Personal Data we collect directly from you may include:
Identity Data: which includes first name, maiden name, last name, user name or similar identifier, marital status, title, date of birth and gender;
Contact Data: which includes billing address, delivery address, email address and telephone numbers, business name;
Transaction Data: which includes details about payments to and from you and other details of products and services you have purchased from us;
Technical Data: which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the DriveWell Go Europe App;
Profile Data: which includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
Usage Data: which includes information about how you use our DriveWell Go Europe App, including the full Uniform Resource Locators (URL) clickstream to, through and from our services (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
Marketing and Communication Data: which includes your preferences in receiving marketing from us and our third parties and your communication preferences;
Location Data: we also use GPS technology to determine your current location. We require this Personal Data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings;
Direct Interactions. You may give us your Identity, Contact and Financial Data when you fill in forms or correspond with us by phone, email or otherwise. This includes Personal Data you provide when you register to use our DriveWell Go Europe App or to receive our newsletter, subscribe to use our services, create an account to use our services, request marketing to be sent to you, search for a product or place an order online, participate in discussion boards or other social media functions in our DriveWell Go Europe App, enter a competition, promotion or survey, attend a conference or webinar, give us feedback or contact us and when you report a problem with the DriveWell Go Europe App .
Purchases: If you make purchases via our DriveWell Go Europe App, or register for an event or webinar, we may require you to provide your Identity, Contact, Financial and Transaction Data.
Community: If you register for an online community that we provide, we may ask you to provide us with Identity, Contact, Profile and Technical Data.
B. Personal Data We Collect Directly from Other Sources
We also collect information from other sources including third parties (from whom we may purchase Personal Data and from publicly available information). We may combine this information with Personal Data provided by you.
C. Use of Tracking Technologies and Cookies
We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you use the DriveWell Go Europe App, our services, or interact with emails we have sent to you. This helps us to provide you with a good experience when you use the DriveWell Go Europe App, allows us to improve the DriveWell Go Europe App, analyze overall trends, offer a tailored experience for users, and secure and maintain the DriveWell Go Europe App and our services.
When you use the DriveWell Go Europe App, we, or an authorized third party, may place a cookie or a similar tracking technology on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer browsing preferences, and improve and customize your browsing experience.
You may opt-out of the collection of non-essential device data on your web browser by managing your cookies at the browser or device level.
Do Not Track
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform. Therefore, we do not currently commit to responding to browsers’ DNT signals.
4. Use made of Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosure and Sharing with third parties
CMT does not sell your Personal Data.
We may share your Personal Data with third parties for the purposes set out in the table above. Below is a summary of the types of third parties used:
A. Service Providers
Our contracted service providers, who provide services such as IT and system administration, help desk, CRM, marketing automation, cloud-hosting, and deploying emergency medical services and tow services for our crash-detection offerings.
B. Customers of CMT.
If you are invited to use the DriveWell Go Europe App by a CMT customer (for example, auto insurance company), we may share your Personal Data with such customer to the extent this is necessary for verifying accounts and activity, performing under a contract, investigating suspicious activity, or enforcing our terms and policies.
C. Our Affiliates
With affiliates within our corporate group, to the extent such sharing of data is necessary to fulfill a request you have submitted online or for customer support, marketing, technical operations, and account management purposes of fulfilling our contractual obligations to you.
D. Event Sponsors
If you attend a physical or online event or contest organized by us, or download or access content, we may share your Personal Data with sponsors of the event. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy policies.
E. Third-party Networks and Websites
With market our services to you on third-party social media networks, advertising networks, websites, and third-party platforms (e.g., Google, Twitter, LinkedIn, and Facebook), and assess the performance of our marketing efforts.
F. Professional Advisers
In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers – including lawyers, bankers, auditors, and insurers based in countries in which we operate, and to the extent, we are legally obliged to share or have a legitimate business interest in sharing your Personal Data.
G. Change in Ownership
To a successor, if we engage in a merger, reorganization, or other corporate change, or sell a business unit, or a significant portion of our business. By applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.
H. Anonymous and Aggregated
We use driving data to look at driving trends, such as how often people drive distracted, which cities/states have the highest prevalence of speeding, or how the average length or distance of trips changes around holidays, etc. CMT de-identifies your Personal Data to the extent that it cannot be reasonably re-associated with you. Where possible, data is not only anonymized but data such as name, address, age, gender, etc., is made inaccessible. We may also share anonymous and aggregated usage data in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our services. In cases where the results of these processing activities are shared with third parties, such anonymous and aggregated data does not contain any of your Personal Data.
I. Legal Requirements
We may be required by law or legal process to disclose your Personal Data, to enforce our legal agreements, or to protect our rights, property, safety, our customers, or others, and we will try to take steps to limit any such disclosure. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may retain your Personal Data for as long as reasonably necessary to fulfill the purposes for which it was provided or collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements or if required to fulfill our legal obligations. We determine the appropriate retention period for Personal Data based on the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, the need to maintain and improve our technology, whether we can achieve the purposes of the processing through other means and based on applicable legal requirements (such as applicable statutes of limitation).
After the expiry of the applicable retention periods, your Personal Data 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.
We may retain your Personal Data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect of our relationship with you, to comply with law enforcement requests, maintain security, prevent fraud and abuse, resolve disputes, enforce our legal agreements, or fulfill your request to “unsubscribe” from further messages from us.
We will retain some anonymised information after your account has been closed and we may use this for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Please note: After you have closed your account or deleted information from your account, any information you have shared with others will remain visible. We do not control data that other users may have copied from the DriveWell Go Europe App. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.
7. Your Rights Relating to Your Personal Data
A. Your Rights
You have the right under Data Protection Law, free of charge to request:
- Access your Personal Data held by us;
- Rectification or deletion of your Personal Data;
- A restriction on our processing of your Personal Data;
- A transfer of your Personal Data (data portability) in a structured, machine-readable and commonly used format;
- Object to the processing of your Personal Data;
- Withdraw your consent to us processing your Personal Data, at any time.
To exercise any of the above rights, please contact us by email at email@example.com, or by phone at 800-941-7177. We will respond to such queries within 30 days and deal with requests we receive from you, in accordance with the provisions of Data Protection Law. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights), for example your email address and telephone number used to register with us. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
B. Marketing Communications
Marketing: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
Promotional Offers from us: We will send you marketing emails if you “opt in” to receive marketing emails when registering with the DriveWell Go Europe App, or if you have enquired about, or purchased any of our goods or services from us and you have not opted out of receiving such marketing.
Third Party Marketing: We will obtain your express opt-in consent before we share your Personal Data with any third party for marketing purposes.
Opt-Out: Please note that, if you change your mind about being sent marketing emails you can “opt-out” at any time by clicking the “unsubscribe” link at the bottom of any marketing email. Once you “opt out”, you will no longer receive any marketing emails from us. We will continue to communicate with you regarding your service billing and support via email and where we send push notifications from time to time to update you about any service updates, events, and promotions we may be running. If you no longer wish to receive these communications, please disable these in the settings on your device.
C. Your Rights Relating to Customer Data
8. International Transfers
Our services are global, and your Personal Data may be stored and processed in any country where we engage service providers, for example who we use for the fulfilment of your order, the processing of your payment details or the provision of support services. This will involve a transfer of your Personal Data to countries outside of your country of residence, where data protection rules are different from those of your country of residence.
Processing of your Personal Data will therefore involve a transfer of data to countries outside the European Economic Area (“EEA“), Switzerland or the UK.
The DriveWell Go Europe App is accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the DriveWell Go Europe App from outside the EEA, Switzerland, or the UK. This means that where you chose to post your Personal Data via the DriveWell Go Europe App or within our services, it could be accessed from anywhere around the world and therefore a transfer of your Personal Data outside of the EEA, Switzerland or the UK may be deemed to have occurred.
B. Data Security
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. Where we have given you (or where you have chosen) a password which enables you to access the DriveWell Go Europe App, you are responsible for keeping this password confidential. We ask you not to share any password with anyone. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data Protection Officer
CMT has a data protection officer (“DPO”) who can be contacted as follows: firstname.lastname@example.org.
Our intention is to meet the highest standards when collecting and using Personal Data. For this reason, we take complaints we receive very seriously. We encourage users to notify us if they think that our collection or use of Personal Data is unfair, misleading, or inappropriate. If you have any complaints about our use of your Personal Data, please contact our DPO or contact your local data protection supervisory authority.
For EU individuals, our lead supervisory authority is the Hungarian Data Protection Authority.
For UK individuals:
The Information Commissioner’s Office at,
Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF, England
Our representative in the UK and Switzerland is:
Data Protection Representative (UK), Ltd (DataRep UK)
85 Great Portland Street,
London, W1W 7LT, England
Registered in the UK (number 12953008)
11. Other Terms
A. Automated Decision Making
To conduct business and provide services to our customers with the CMT-branded DriveWell Go Europe App, CMT may utilize algorithms defined as automated decision-making under Article 22 of the General Data Protection Regulation (GDPR).
This processing is considered:
- Necessary for the performance of a contract between the controller and the individual;
- Where the controller has obtained the individual’s explicit consent; or
- CMT has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. These measures also include controls to provide all individuals using the CMT-branded DriveWell Go Europe App with the following rights:
- To access your Personal Data;
- To rectify or delete your Personal Data;
- To restrict the processing of your Personal Data;
- To object to the processing of your Personal Data;
- To transfer your Personal Data (data portability)
- To obtain human intervention by CMT;
- To express your view on the automated decision; and
- To contest the automated decision.
B. Industry Standard Security
While we use industry-standard security measures to protect against the loss, misuse, and alteration of the Personal Data under our control, there is no guarantee that it cannot be compromised. We have aligned our Information Security Management System with ISO 27001 standards and are audited against the framework on an annual basis.
C. For CMT-Branded Mobile Applications.
Mobile Application Privacy Details
The following information applies only to CMT-branded mobile applications (including without limitation, the DriveWell Go app and OpenRoad app (and not to mobile applications with customer branding)).
- As of December 8, 2020, CMT is required to provide information about our mobile application’s privacy practices as part of the Apple App Store.
- This is intended to assist users in understanding an app’s privacy practices before they download the mobile application on any Apple platform.
- The data below may be collected and linked to your identity. This information is not used for tracking* purposes:
- Contact Info – Email
- Health & Fitness – Fitness (Motion)
- Location – Precise
- User Content – Photos or Videos
- Identifiers – User ID and Device ID
- Usage Data – Interaction
- Diagnostics – Crash Data
- Other Data
*Apple defines tracking as: linking data collected about a user or device with third-party data for advertising, advertising measurement purposes, or sharing data about a user or device with a data broker.
Google Permissions Declarations
We do not intentionally gather Personal Data about visitors who are under the age of 16.
E. No Contractual Rights
F. Links to Third Party Sites
Our services and website may contain links to other sites and services owned and controlled by others. These third-party websites have privacy policies, and you should review those policies
G. Contact Us
For specific information, or to ask questions of our privacy team, please contact us at email@example.com.
Revisions to this Policy