Marketplace Privacy Policy

Marketplace Privacy Policy

08/30/2020

The Locate2u Marketplace (the “Marketplace”) is a one-stop solution for discovering, purchasing and accessing third-party solutions and applications for fleets. The purpose of this privacy policy is to explain to our customers and their employees (collectively, “you”) what data we collect from you, how that information is used, and what measures we take to protect that data.

In order to provide you with 3rd- party solutions and applications and other services through this Marketplace we work with – and share your information with – different 3rd-party partners, including Roadz, which is our “Marketplace Platform Provider”, and “Vendors,” which refers to the third-party solution providers whose solutions and applications are available for you to purchase and use through the Marketplace (collectively “we” or “us”).

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us including to our Marketplace Platform Provider, and Vendors such as name, address, contact information, passwords and security data, and payment information.

We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about Vendor solutions and services, buying a Solution or while using the Marketplace for other purposes (such as administering your solutions or user profiles) or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the services, the choices you make and the products and features you use. The personal information we collect may include the following:

• Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

• Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.

• Payment Data. We collect data necessary to process your payment if you make purchases through the Marketplace, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find Stripe’s privacy policy here.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit the Marketplace.

We automatically collect certain information when you visit, use or navigate the Marketplace. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Marketplace and other technical information. This information is primarily needed to maintain the security and operation of the Marketplace, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Telematics and Other Fleet Data

The Marketplace provides you with the ability to find, purchase, and access third-party Vendor solutions that rely on, among other types of data, GPS vehicle location data, engine and vehicle or device diagnostic data, driver behavior data like speed and acceleration, VINs, fuel levels, odometer data, seatbelt and other safety related data, routs, and administrative fleet data. We, which includes the Vendors whose solutions you buy and access through the Marketplace, may be collecting or generating such data in the course of providing services to you, and this information is shared between us, including the Vendors whose solutions you have purchased through the Marketplace and the Marketplace Platform Provider, in order to provide you services. Any use of your information by the Vendors we partner with for purposes of selling their solutions on the Marketplace, and with whom you have entered into an agreement through the Marketplace, or directly by signing a contract with them, is subject to your agreement with those Vendors and those Vendors separate privacy policy.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for business purposes related to the fulfillment of your contracts with Locate2u, the Locate2u Marketplace or the Vendors, or compliance with our legal obligations.

We, which include the Marketplace Platform Provider and Vendors, use personal information collected via our Marketplace for a variety of business purposes such as those described below. We process your personal information for these purposes in reliance on our legitimate business interests, with your consent, or in order to support Vendor services you purchased through the Marketplace or Marketplace services offered to you, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on for each of the purposes listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process through a single-sign-on (“SSO”) authentication process. This allows you to access the Marketplace, as well as multiple Vendor applications, solutions and services, through one set of login credentials.

• To send you marketing and promotional communications. We may use the personal information you send to us for marketing purposes. You can opt-out of our marketing emails at any time by using the “Unsubscribe” link located at the bottom of the emails or by sending an email to marketplace@locate2u.com (see the "WHAT ARE YOUR PRIVACY RIGHTS "below).

• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

• Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Marketplace.

• To post testimonials. We may post testimonials on our Marketplace that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at marketplace@locate2u.com and be sure to include your name, testimonial location, and contact information.

• Request Feedback. We may use your information to request feedback and to contact you about your use of our Marketplace.

• To enforce our terms, conditions and policies.

• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

• To manage user accounts. We may use your information for the purposes of managing your account and keeping it in working order.

• To deliver services to you. We may use your information to provide you with the requested service.

• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Marketplace.

• To share data with Vendor whose solutions you purchased on the marketplace in order to enable those solutions, according to the data required by those solutions, to fulfil your order and provide the service to you.

• To share data with Roadz, the Marketplace Platform Provider, in order to enable the Marketplace, and Marketplace services.

• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, evaluating and improving our Marketplace, and selecting Vendor products that will enhance your experience on the Marketplace.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

• In Short: We only share personal information to comply with laws, to provide you with services, to protect your rights, to fulfill business obligations, or as we may describe to you at the time the personal information is collected, or as described in this privacy policy. We, including Roadz, the Marketplace Platform Provider, may also share data and information for business purposes in an anonymized form which is not associated with individual end users or customers, and does not include personal information. Vendors may also share data according to the agreement you signed with them through the marketplace or directly.

• We may need to share your personal information in the following situations:

• At Your Request. We may share personal information about you with third parties when you request that we do so for a specific purpose.

• Vendors, Consultants and Other Third-Party Service Providers. We may share your data between us: Locate2u , the Marketplace Platform Provider and Vendors, as well as with other third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. In addition we may also share your information with our partners for purposes of payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Marketplace, which will enable them to collect data about how you interact with the Marketplace over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this privacy policy, we do not , sell, rent or trade any of your personal information that may be used to identify you with third parties for their promotional purposes. We may sell, rent or trade data collected from you that has been anonymized by either us or the Marketplace Platform Provider and cannot be used to specifically identify you.

• 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.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

• 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.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We, which includes the Marketplace Platform Provider, may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

5. VENDORS

In Short: We, including the Marketplace Platform Provider, may share information with Vendors (third party solution providers on the Marketpalce), and those Vendors may, likewise, share information with us, that is essential to the operation of our business. As our Marketplace Platform Provider, any information submitted through the Marketplace is also accessible by Roadz, and may be used by that provider in order to provide you, Locate2u and Vendors with services.

To the extent we share your information with a Vendor through our Marketplace, and in accordance with your agreement with that particular Vendor that you have engaged through our Marketplace, and you accepted the Vendor’s agreement through the Marketplace, or approved sharing of data with the Vendor either specifically, or by way of agreement with us, or signed a contract with that Vendor directly, then that Vendor’s privacy policy controls the Vendor’s use of that information.

The personal information we may share with Vendors and other third parties, is shared for purposes of engaging Vendors to provide applications and solutions to you.

6. 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 policy unless otherwise required by law.

We will only store your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). This includes storing data in order to be able to provide Vendors the data collected and/or generated by Locate2u, Roadz, and other Vendors, in order to enable the services of those Vendors to you.

When we have no ongoing business need to keep your personal information, we will either delete or anonymize it, 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.

7. 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, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Marketplace is at your own risk. You should only access the services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect personal 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 Marketplace, 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 Marketplace. 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 have collected from children under age 18, please contact us at marketplace@locate2u.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review your Marketplace account at any time, as well as terminate your Marketplace account at any time provided that you have no active subscriptions with Vendors or with Marketplace services for which you have signed up and committed to a contract period which hasn’t ended yet.

Account Information

If you would like to review the information in your Marketplace account, or terminate your account provided that you have no active subscriptions with Vendors or with Marketplace services for which you have signed up and committed to a contract period which hasn’t ended yet, please contact us using the contact information provided in this Privacy Policy.

Upon your request to terminate your Marketplace account, and assuming no outstanding contracted obligations to Vendors or Marketplace services, we will deactivate or delete your Marketplace account. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

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. 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, except as may be required by applicable law. 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 policy.

12. YOUR CALIFORNIA PRIVACY

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.

14. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy 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 policy, 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 policy frequently to be informed of how we are protecting your information.

If you use the Marketplace, you agree to be bound by such changes to this privacy policy. If you do not agree to such changes, please contact us. We will attempt to resolve your concern by either providing an explanation or making an accommodation. If we cannot accommodate you, then your only remedy is to discontinue use of the Marketplace.

15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at marketplace@locate2u.com or write to us at

Address:

1080 Holcomb Bridge Rd, Bldg 200, Suite 350
Roswell, GA 30076
(866) 320-5810