Privacy Policy

Introduction:

For a better understanding of the Privacy Policy, we made this table with terms and definitions, in the case there are questions related to them: 

TERM	DEFINITION
Anonymization	Process by which data loses the possibility of direct or indirect association with an individual, considering the reasonable and available technical means at the time of processing.
B2B	B2B businesses target other businesses as consumers. B2B stands for "business-to-business" and refers to commercial transactions between two businesses or companies. In a B2B transaction, the products, services, or information are exchanged between two businesses, rather than between a business and a consumer.
B2C	B2C businesses target individual consumers. It is a type of commerce where businesses sell their products or services directly to individual consumers, rather than to other businesses. In B2C transactions, the buyer is typically an individual who is purchasing for personal use, rather than for resale or use in another business.
Consent	Freely given, specific, informed, and unambiguous indication of an individual's agreement to the processing of Personal Data
Content	Any information or data that you upload, submit, post, create, transmit, store, or display in Transpoco Services.
Data Controller	The Data Controller will make decisions about processing activities. It  exercises overall control of the Personal Data being processed and is ultimately in charge of and responsible for the processing.A controller can be a company or other legal entity (such as an incorporated partnership, incorporated association or public authority), or an individual (such as a sole trader, partner in an unincorporated partnership, or self-employed professional, eg a barrister).
Data Processor	The Data Processor acts on behalf of the relevant controller and under their authority. In doing so, they serve the controller’s interests rather than their own.A processor can be a company or other legal entity (such as an incorporated partnership, incorporated association or public authority), or an individual, for example a consultant.
Device	Any computer used to access the Transpoco Services, including without limitation a desktop, laptop, mobile phone, or tablet.
GDPR	The General Data Protection Regulation (GDPR), which came  into effect May 25, 2018. It is the most significant change 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.
Marketplace	An online marketplace is a type of e-commerce website where product or service information is provided by multiple third parties.
Personal Data	Any information that relates to an identified or identifiable individual, directly or indirectly. This may include name, address, email address, social security number, or any other identifier that is unique to the individual, as well as any other information that can be used to identify the individual indirectly (such as location data, IP address, or online identifiers). Personal Data does not include information that has been anonymized.
Transpoco Services	Transpoco’s products and/or services provided.

• About This Policy

Transpoco offers services to two different markets: Business to Business (B2B) and Business to Customer (B2C).

Our B2B (clients that buy our products for business use) customers in the role of Data Controllers have a Data Processing Agreement in place with Transpoco and we, as Data Processors, will only process the Personal Data handled by them and on their behalf. For more information about how the Personal Data is handled, please check:

https://www.transpoco.com/knowledge/data-processing-terms

This Privacy Policy states our commitment to your privacy, as a B2C (clients that buy our products for personal use) customer and to visitors on our website.

This Privacy Policy is designed to demonstrate our firm commitment to privacy and to inform you about what Personal Data we process, why we process it and how you can manage and delete the information you trusted us with. 

Failure to provide correctly certain Personal Data may make it impossible for Transpoco to provide its services.

If you do not agree with this Privacy Policy, you should not use our product and services. 

This Privacy Policy is not the same as Transpoco's terms and conditions, which is a separate document. The Terms and Conditions outline the contract between you and Transpoco in respect of the services.

• Why we collect Personal Data:

We collect Personal Data to provide better services and supply the best experience for our customers.

• Types of Personal Data we collected and how we collect them:

If you choose a Marketplace to purchase our product, the Personal Data is collected and processed only by this party. If you have any doubts or issues regarding it, please contact or check the Marketplace's privacy settings.

We start processing your Personal Data when you activate the product: 

For the purpose of activating our trackers and creating an account and profile information in our system and when you use Transpoco Services (including but not limited to when you upload, download, collaborate on, or share content) we will collect and process:

• Contact information such as name, email address, mailing address, IMEI number or Vehicle registration and phone number;
• If you subscribe to use our product, any financial data is handled by a 3rd party provider who has been audited by a PCI-certified auditor and is certified to PCI Service Provider Level 1 standard. Last card details will be kept to help in future purchases, but you do have the right to request the use of a different card in your purchases.
• Location data via satellite tracking for the purpose of identification of where vehicles are;

If you choose to purchase directly from one of our websites, such as https://www.cartrackerprice.co.uk/ we will be collecting:

• Contact information such as name, email address and mailing address;
• If you subscribe to use our product, any financial data is handled by a 3rd party provider who has been audited by a PCI-certified auditor and is certified to PCI Service Provider Level 1 standard. Last card details will be kept to help in future purchases. But you do have the right to request the use of a different card in your purchases.

When you access our website:

When you access our website, Transpoco, for operation and maintenance purposes, services may collect files that record interaction with this Application (System Logs) or use for this purpose other Personal Data (such as IP Address).

Personal Data may be freely provided by the user e.g. filling a form, or collected automatically when using our website.

Managing contacts and sending messages

If you request a quote or add your information to any form on our website, we will process the data on a database of email contacts, phone contacts or any other contact information to communicate with you. These services may also collect data concerning the date and time when the message was viewed by the user, as well as when the user interacted with it, such as by clicking on links included in the message:

System use: HubSpot Email (HubSpot, Inc.)

HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.

Personal Data collected: email address and phone number or other information the user might give us on the form.

Cookies

Cookies are small text files which are downloaded and stored on a user's computer or mobile device when you visit a website. They allow the website to recognise the user's device and remember their preferences, for the sole purpose of providing the service required by the user.

When you visit Transpoco's website you can manage by accepting all cookies, rejecting all cookies or editing them, as it is a granular banner, compliant to GDPR. We will only collect non mandatory cookies if the consent is given by the user.

For more information, please check our Cookie Policy.

Content: We collect and store content that you create, input, submit, post, upload, transmit, store, or display in the process of using our products. Such content includes any Personal Data that you choose to include.

General Uses: We use the Information we collect about you (including Personal Data to the extent applicable) for a variety of purposes, including:

• To provide, operate, maintain, improve, and promote Transpoco Services;
• To enable you to access and use Transpoco Services, including uploading, downloading, collaborating on, and sharing Content;
• For administrative purposes such as to process and complete transactions, and send you related information, including purchase confirmations and invoices;
• To send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; and sending you technical notices, updates, security alerts, and support and administrative messages;
• To use analytics information (including log and configuration data) to understand how our products are being configured and used, how they can be improved for the benefit of all of our users, and to develop new products and services. As such we generate data from the analytics logs described above, including the content elements captured in such logs, as well as from the content stored in the Products.

You can find the complete list of our processing activities and the lawful basis we rely on when processing your Personal Data here.

• Third parties and international transfers

The main storage location for your Personal Data is in Ireland or the EU. However, some of the third parties described in this policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. 

When we engage in such transfers, we audit these third parties and use a variety of legal mechanisms to help ensure your rights and protections travel with your data. Recognised data protection safeguards are in place to ensure the security of your personal data where it is transferred outside of the EEA. Some of our pages utilise white-labelling techniques to serve content from our service providers while providing the experience of our site. 

Service Providers, Business Partners, and Others: We work with third-party service providers to provide website, application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services for us. These service providers may have access to or process your Information (including Personal Data) where we have a lawful legitimate interest to share your data for the purpose of third parties providing those services for us. 

Please be aware that you are providing your Information to these third parties acting on behalf of Transpoco.

• Information sharing and disclosure:

Aggregated or Anonymized Data: Transpoco may use vehicle data to create an anonymised traffic data product. This product is used to display real-time and historic traffic movement. Speed and location data is gathered from individual vehicles, the data is anonymised so the vehicle, company, and driver cannot be recognised. This anonymised product may be sold to third parties. No individual vehicle or driver data is visible to the third party.

Transpoco does not sell your Personal Data. 

• Retention period:

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 to suspend or remove the data.

Any data on backup will be deleted within 30 days.

You may be able to deactivate your Transpoco Services account, in your account settings. 

Upon deactivation of an account, Transpoco shall, if required, return the Personal Data and copies thereof to be securely destroyed, except if applicable law provides otherwise. In that case, we shall no longer Process the Personal Data, except in the case of applicable law. 

By default, we will retain your account information for as long as your account is active, or as reasonably useful for commercial purposes or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Otherwise, your account and data will be deleted 30 days after account cancellation. 

• How we secure your Personal Data

Transpoco hosts data with an ISO27001 compliant hosting company based in the EU region. The servers on which Personal Data is stored are kept in a controlled environment. 

Where data is transferred over the Internet as part of our Products, the data is encrypted using industry standard SSL (HTTPS). We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with Data Protection Legislation and proper security measures.

While we take reasonable efforts to guard your Personal Data, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. 

Transpoco ensures the staff who access and process Transpoco customer Personal Data have been trained in handling that data and are bound to maintain the confidentiality and security of that data.

We have a specific page regarding the GDPR measures that are taken by Transpoco, please check it for more information:

GDPR | Transpoco Telematics Solutions

For this reason, we encourage you to take appropriate measures to protect yourself, such as keeping all usernames and passwords confidential while handling them yourself, as this type of information is personal, non-transferable, and solely your responsibility.

• Our policy towards children

Transpoco services are not directed to individuals under 13. We do not knowingly collect Personal Data from children under 13. If you become aware that a child under 13 has provided us with Personal Data, please contact our Support Team and we will take steps to delete such information.

• Changes in this policy

This Privacy Policy will be reviewed from time to time to take into account changes in the law.

We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice to our newsletters by email. We encourage you to review this Privacy Policy to stay informed about our information practices and the ways you can help protect your privacy.

• Your Rights

If you no longer would like us to process your information, please contact us directly following the instructions at the end of this policy. You can also request access and removal of your Personal Data at any time.

Under GDPR, you have rights including:

Right of access - You have the right to ask us for copies of your Personal Data. 

Right to rectification - You have the right to ask us to rectify Personal Data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

Right to erasure - You have the right to ask us to erase your Personal Data in certain circumstances. 

Right to restriction of processing - You have the right to ask us to restrict the processing of your Personal Data in certain circumstances. 

Right to object to processing - You have the right to object to the processing of your Personal Data in certain circumstances.

Right to Data Portability- You have the right, in certain circumstances, to transfer your Personal Data to another organisation.

Right to review Automated Decisions- You have the right to object to automated decision making and/or profiling.

Right to file a Complaint- You have the right to complain to the Data Protection Commissioner. You also have the ability to complain to us by sending an email as set out at Paragraph 12 below.

Please be aware that if you do not allow us to collect Personal Data from you, we may not be able to provide our services.

Personal Data might not have to be erased if any of the following applies:

• The "right of freedom of expression";
• For supporting legal claims;

• How to contact us:

Transpoco - E-pire limited, trading as Transpoco, Dublin City University Alpha Innovation Campus, Old Finglas Road, Glasnevin, Dublin 11, Ireland. 

If you wish to complain about how we have handled your Personal Data and any supporting documentation by sending an email to the address below or opening a Support Ticket/chat through your Move product:

Data Protection Officer: Barry Cronin, contact: support@transpoco.com

After full details are provided, our Data Protection Officer (DPO) will endeavour to provide an initial response to your query or complaint within 10 business days, and investigate and attempt to resolve your query or complaint within 30 business days or such longer period as is necessary and notified to you by our Data Protection Officer.