At Track & trace we take your privacy very seriously

WHAT DOES GDPR MEAN?
We’re committed to compliance with the General Data Protection Regulation (GDPR), which went into effect May 25, 2018. The regulation contains the most significant changes to European data privacy legislation in the last 20 years, replacing European Privacy Directive 95/46/EC. It is designed to give EU citizens more control over their data and seeks to unify a number of existing privacy and security laws under one comprehensive law. The GDPR applies not only to EU-based businesses, but also to any business that controls or processes data of EU citizens. Per the GDPR, personal data is any information relating to an identified or identifiable individual; meaning, information that could be used, on its own or in conjunction with other data, to identify an individual. Track & Trace customers can trust that we’ve made GDPR a priority and have devoted significant and strategic resources toward our efforts to comply with GDPR. The contents of these documents are not intended to be legal advice, nor should they be considered a substitute for legal assistance. The final responsibility for understanding and complying with GDPR resides with you, though we will assist you in meeting GDPR requirements where possible.

WHICH ACTIONS HAS TRACK & TRACE COMPLETED REGARDING GDPR?
We appreciate that customers have requirements under GDPR that are directly impacted by their use of our products and services, and we are committed to help them to fulfill their requirements under GDPR and local law.
Below are a few examples of actions Track & Trace has committed to in order to satisfy GDPR requirements that apply to both us and our customers:
◦ Ensuring our products are designed in accordance with ISO 27001 standard (information security management system). This standard mirror many of the security and privacy requirements of GDPR and is helping give our customers a transparent framework to measure our software development and data management practices. You can reach out to our team for the certificate; Completed;
◦ Committing to follow any additional security and privacy measures required under GDPR; Completed;
◦ Assisting with data processing security and privacy requirements, notifying regulators of personal data breaches in the unlikely event that they occur, and promptly communicating any such breaches to our customers and end-users; Completed;
◦ Ensuring our staff that access and process our customer personal data have been trained in handling that data and are bound to maintain the confidentiality and security of that data; Completed;
◦ Holding any vendors that handle personal data to the same data management, security, and privacy practices and standards to which we hold ourselves. Work in progress;
◦ Committing to carrying out data impact assessments and consulting with EU regulators where appropriate; Completed;
◦ We’re strengthening our security controls across the board. All customers personal data has been encrypted. Where data is transferred over the Internet as part of our Products, the data is also encrypted using industry standard SSL (HTTPS). We had improved our systems for authentication and authorisation as well; Completed;
◦ Updating our Products Terms and Conditions with Privacy Policy in order to attend GDPR requirements; Work in progress
◦ Providing customers with additional assurances regarding their ability to fully control their data in a safe, secure, and compliant environment when they use services from Track & Trace; Work in progress;
◦ Improving logs; Completed;
◦ Enabling customers to easily export their data into a machine-readable format; Completed.

WHAT DO TRACK & TRACE CUSTOMERS NEED TO DO?
We strongly advise you to make yourself familiar with our latest privacy policy. If you have drivers that are using their vehicle for both business and private use, those drivers should have an option to activate a privacy mode for private driving.
For many years we have promoted best practices in terms of data protection and data privacy, we have many resources such as sample policies and guidelines on this topic. These resources are all freely available on our website and we encourage you to take a look at them hereor reach out to us if you have any queries related to our solutions.

OUR PRIVACY POLICY

Personal Data collected for the following purposes and using the following services:

Data Controller and Owner:
Intelligent Devices Ltd., trading as Track & Trace.

Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies, Usage data, email address and phone number.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection.
The Personal Data may be freely provided by the User, or collected automatically when using this Application.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User.
Failure to provide certain Personal Data may make it impossible for this Application to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data
Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data
The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Analytics, Managing contacts and sending messages and User database management.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:

– Analytics

– User database management

– Contact management & message sending

– Email

Cookie Policy
This Application uses Cookies. To learn more and for a detailed cookie notice, you may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action
The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System Logs and Maintenance
For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System Logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy. More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Information about this privacy policy
The Data Controller is responsible for this privacy policy, prepared starting from the modules provided by XPRS and hosted on XPRS servers.

Definitions and legal references
Personal Data (or Data)
Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data
Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User
The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject
The legal or natural person to whom the Personal Data refers.

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)
The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application
The hardware or software tool by which the Personal Data of the User is collected.

Cookies
Small piece of data stored in the User’s device.

Legal information
Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.