Privacy Notice

This Privacy Notice explains how Xirgo Holdings, Inc. and its affiliated companies ("Xirgo," "we," "us," "our") collects, uses, and discloses personal data collected or generated by Xirgo's websites, video and vehicle telematics technologies, and associated portal websites (collectively, the "Services").

For the purposes of this Privacy Notice, "you" and "your" means you as the user of the Services, whether you are a driver, customer, or other party whose personal data we have collected pursuant to this Privacy Notice.

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services.

What personal data do we process?

When you use or access the Services, we collect certain categories of data about you from a variety of sources.

Video and vehicle telematics

Our in-vehicle and video telematics technologies generate information, including information that may identify or that could reasonably be linked to an identified or identifiable individual. An example of when this could occur is when we provide vehicle telematics services to commercial fleet managers.

Our in-vehicle and video telematics technologies may collect the following types of information, which in some cases may be linked directly or indirectly to identified or identifiable individuals:

Driver identifiers such as vehicle number plate and driver name
Device information and identifiers, for example, Internet Protocol ("IP") address, cookie identifiers, device type, advertising, and application identifiers
User log-in details, for example, name, email address, contact number, or organization details
Vehicle identification number ("VIN") and vehicle serial or other identification numbers
Technology Information, for example, username, password, browsing activity, advertisements viewed, search terms, content viewed, and logs
Video footage of outside and inside vehicle data
Global Positioning System ("GPS") location data
Vehicle diagnostic data
Telemetry, for example, speed, direction of travel, location or event snapshots, photographs, or images
Driver facial reactions and movements
If any passengers are present, then video or images of those passengers

Website and Portal information

We manage access to and use of Xirgo's websites and the portals associated with our products and services to view data associated with our websites and data generated by our in-vehicle and video telematics technologies. Certain information, such as IP addresses, must be collected as a necessary part of delivering content or services to you over the Internet or other networks. If you use the portal as a registered user, we may collect:

Contact details e.g., name, organization, and email address
Device and usage information, for example, your user ID, IP address, how often you access the portal, and the actions you take in the portal

What do we use personal data for?

When personal data is generated as part of the Services, we generally do not make any decisions about how that personal data is used. Our customers make those decisions and we act under their instructions. If you work for or are a part of an organization that uses our Services and want to know more about any personal data it generates about you, the best place to start is by asking your organization for more information.

We use personal data to help improve our Services. For example, such personal data may be used by our artificial intelligence systems to improve abilities to identify certain types of safety events, or to develop new products and services.

We also use personal data to manage user credentials and access restricted areas of our websites and to the portals, to maintain security logs, to understand how to make our website and portals easier to use and navigate, and to improve our websites and portals.

For EU users

Our lawful basis for using personal data is our legitimate interest in improving and developing our products and services.

How and when we disclose personal information

We may disclose personal data within Xirgo or when:

Xirgo, an affiliate of Xirgo, or a subsidiary of Xirgo is merged into a third party, in which case your personal information may be transferred as part of the merger
Substantially all of the assets of Xirgo, an affiliate of Xirgo, or a subsidiary of Xirgo are acquired by a third party, including in the context of a bankruptcy or other restructuring, in which case your personal information may be transferred as part of the acquisition
We use vendors, service providers, and consultants that need access to personal information in order to perform services for us, for example hosting and IT service providers
We believe that your actions are inconsistent with our agreements or policies, that you have violated the law, or that disclosure is necessary to protect the rights, property, and safety of Xirgo, our customers, users, the public, or others
Obtaining advice from our lawyers and other professional advisors
We believe sharing is necessary to protect and manage our business interests
Sharing is otherwise permitted by applicable law
When we are required by law to do so

Data security and retention

Despite our reasonable efforts to protect your information, no security measures are impenetrable. We cannot guarantee "perfect security." Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use insecure channels to send us sensitive or confidential information.

We retain your information for 12 months, unless a different period is specifically requested by or agreed with your organization.

Data transfers

Personal data may be transferred to and stored by a third party at a destination inside or outside the European Economic Area.

If we transfer personal information to a third party, we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organizational, contractual, or other lawful mechanisms, such as standard contractual clauses. Please contact us if you would like more information about these safeguards.

Your rights and how to exercise them

If you are resident in the European Economic Area ("EEA") or the UK you may have certain rights in respect of your personal data, including:

The right to object to or withdraw consent to the processing of your personal information
The right to object to decision making by a computer, based on your personal information
The right to access and rectify your personal information
The right to erase, restrict, or receive a machine-readable copy of your personal information

You may contact us about your rights at any time and your request will be handled free of charge in a timely manner.

Within the EEA you also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns, we ask that you initially contact us at privacy@xirgo.com so that we can investigate and hopefully resolve your concerns.

For California residents

This section applies to you only if you are a resident of the State of California (a "resident" or "residents"). This section describes the personal information that we process as a "business," as such term is defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the "CCPA").

Processing of personal information

In the preceding 12 months, we collected and (where indicated below) have disclosed the following categories of personal information and sensitive personal information (denoted by *) for business purposes to the following categories of recipients:

Category of Personal Information	Categories of recipients
Identifiers such as name, email address, and IP address.	Service providers including internet service providers, data analytics providers, and operating systems and platforms.
Internet and other electronic network activity information such as information regarding your interaction with a portal.	Service providers including internet service providers, data analytics providers, and operating systems and platforms.
Personal information categories listed in the California Customer Records statute such as name.	Service providers including internet service providers, data analytics providers, and operating systems and platforms.
Geolocation data such as IP address.	Service providers including internet service providers, data analytics providers, and operating systems and platforms.
Inferences drawn from other personal information.	Service providers including internet service providers, data analytics providers, and operating systems and platforms.
Account access credentials such as account log-in and password.*	Service providers including internet service providers, data analytics providers, and operating systems and platforms.
Precise geolocation data.*	Service providers including internet service providers, data analytics providers, and operating systems and platforms.

Your California privacy rights

As a resident, you may have the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to Know:

You have a right to request the following information about our collection, use and disclosure of your personal information:

The categories of personal information we have collected and disclosed for a business purpose
The categories of sources from which personal information is collected
The business or commercial purpose for collecting personal information
The categories of third parties with whom we share personal information
The specific pieces of personal information we have collected about you

Right to Delete:

You have a right to request that we delete personal information we maintain about you.

Right to Correct:

You have a right to request that we correct inaccurate personal information we maintain about you.

If you are a resident and wish to exercise your rights under the CCPA, contact us at +1 224 331 0772 or email us at privacy@xirgo.com. We will not discriminate against you if you choose to exercise any of your rights under the CCPA. We may need to collect information from you, for example, your email address, government issued ID, date of birth, or information related to your recent interactions with us to help us confirm your identity before we fulfil your request.

You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will ask for evidence that you have provided such agent with authority to act on your behalf, and we may need you to verify your identity directly with us.

Changes to this Privacy Notice

This Privacy Notice may be amended by us from time to time, in which case we will update the "Last Updated" date in the Privacy Notice. If we make any material changes to this Privacy Notice, we will make reasonable efforts to provide you with notice and will take additional measures as required by law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

If you have any questions or need further information about our privacy practices, or would like to let us know that your details require updating, please write to us at:

Xirgo Holdings, Inc.
1016 Lunt Avenue
Schaumburg, IL 60193
USA
Attn: General Counsel / Legal Department

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