PrivacyPolicy

FleetZero Inc. and its subsidiaries and divisions (“FleetZero”, “we”, “us”, “our”) are committed to protecting your personal data. Please read this Privacy Policy carefully as it explains:

• how and why FleetZero uses your personal data when you access our website, services and/or otherwise engage with us; and
• your legal rights in respect of your personal data.

When you provide FleetZero with personal data about other individuals (for example, other people within your organization), please refer them to this Privacy Policy.

The term “personal data” used in this Privacy Policy is taken from data protection laws and broadly means any information that can identify individuals.

If you have any questions or comments about this Privacy Policy, please find our contact details in section 11, “How can you contact us?”.

Note that we may change this Privacy Policy from time to time by updating this page. This Privacy Policy does not apply to any third party websites, plug-ins or applications to which you may be directed from our website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you, so we encourage you to read the privacy policies/notices on the other websites you visit. We do not accept any responsibility or liability for the privacy practices of such third parties, and your use of them is at your own risk.

FleetZero sells certain services and products. Our contact details can be found in section 11 of this Privacy Policy.

When the FleetZero website is visited, we collect and use your personal data in accordance with applicable data protection laws. Where our clients decide how and why personal data should be used in the provision of services, those clients will be ultimately responsible for your personal data in such circumstances.

We may collect personal data about you in various circumstances, including in the provision of our services/products, use of our website, and/or where we otherwise engage with you, e.g., to procure a service. The personal data that we collect and the reasons for using it will depend on the nature of your relationship with us, but may include the types of information and purposes set out below.

Engaging with you. This includes personal data such as your name, title, position, the company you work for, your postal address, email address, and phone number. We require the above information in order to engage with you for business purposes.

Automated interactions. As you interact with our website, we may automatically collect personal data from your device by using cookies and other similar technologies. Processing such information is necessary for us to pursue our legitimate interests in improving our website and providing a more relevant service to our clients and business partners. This information is not used to develop a personal profile of you. For further details, please see our Cookie Notice.

Marketing and information gathered through our website and social media accounts. Certain sections of our website, including our blogs, invite you to request publications, newsletters and alerts, subscribe to receive invitations to events, seminars and webinars, take part in client surveys, and receive FleetZero announcements. If you do so, we will collect some or all of the following information: your name, email address, job title, organization name and company address. Our systems will recognize you as a user and, based on the content you view/request, we will strive to provide material that is relevant to you and your interests. We may also collect this information where you have physically attended an event hosted by FleetZero, so that we can invite you again in the future. In addition, FleetZero maintains accounts on social media platforms (such as LinkedIn, YouTube, Instagram, Facebook and X) and may collect pictures, demographic information, interests and other personal data that you share with the platform when interacting with these accounts. You can opt out of receiving marketing communications at any time, either by clicking the unsubscribe link in the relevant communication, or by emailing us at info@fleetzero.ai. For further information, please see section 9, “What are your rights over your personal data?”.

Profiling. “Profiling” refers to where your personal data is used for solely automated processing to evaluate or predict certain aspects about you without human assessment. FleetZero does not currently do any profiling using personal data. Should we decide to use completely automated processes to profile individuals in the future, e.g., to market FleetZero’s services more efficiently, we will notify you in accordance with applicable law and, depending on where you are located, you will have certain rights with respect to such use of your personal data (see section 9 below).

The main legal grounds that FleetZero relies on to collect and handle your personal data are:

With your consent. For example, where:

• it is mandatory under the data protection laws in a particular country that we operate in (this will be either your express consent or inferred consent where allowed by applicable law);
• FleetZero cannot lawfully handle personal data on the other permitted grounds under data protection laws; and/or
• FleetZero collects information that the data protection laws of certain countries consider to be inherently sensitive (for example, where you tell us about your dietary requirements so that we can cater to your health or religious requirements, or where you ask us to make adjustments to accommodate your disability).

You may withdraw consent at any time after you have given it. This would not affect the lawfulness of FleetZero’s prior use of that data. In certain situations, however, withdrawing consent might impact FleetZero’s ability to provide products to / otherwise engage with you.

Where it is necessary to perform a contract with you or your organization. For example, to conduct our business activities, we hold information (such as contact details and email communications) of our clients’, business partners’ and suppliers’ employees.

Where it is necessary for FleetZero’s or our clients’ legitimate interests. For example:

• to administer and improve our websites;
• to provide our services to / otherwise engage with you in the course of our day-to-day business activities;
• to manage the security of our systems and networks;
• for insurance purposes;
• to exercise or defend our legal rights or to comply with court orders; and
• to develop our business (including communicating with you about our services, events, surveys and other promotional activities).

FleetZero will only use your personal data for its legitimate interests where such interests are not overridden by the need to protect your privacy.

To comply with legal requirements placed on FleetZero. For example, to maintain accurate records, and for the purposes of fraud and crime prevention and detection or as otherwise required under applicable law.

We may share information that you have provided to us as necessary within the FleetZero group of entities and with certain third parties such as service providers acting on our behalf who will use the data to provide the service. These may include insurers, IT and cloud service providers, background screening providers, legal advisers, accountants, tax advisers, advertising agencies, insurance companies, financial or lending institutions, and facilities services providers. We will ensure that any third party service provider we use commits to an appropriate level of security and confidentiality to protect your personal data.

In some circumstances and in accordance with applicable law, we may have to disclose your personal data to other third parties for legal, tax or regulatory purposes, such as:

• where a domestic or foreign court, police, law enforcement agency, governmental agency, or regulatory body asks us for it;
• to protect FleetZero’s assets and interests, or to protect people’s safety, security, rights and/or property; and
• to manage, defend or settle any actual or potential legal claims.

We strive to maintain systems that are secure and meet industry standards, and we implement a combination of measures to protect your personal data, including:

• internal policies and procedures that define the roles and responsibilities of our staff throughout the life cycle of records containing personal data and limit their access to that information on a “need-to-know” basis;
• physical, electronic and procedural safeguards that comply with relevant standards to protect personal data;
• technical safeguards for information collected or stored electronically, such as encryption, firewalls, passwords and anti-virus software;
• a designated privacy officer and regional privacy coordinators to monitor FleetZero’s compliance with applicable privacy laws;
• staff training in privacy and information security;
• procedures for receiving, investigating, and responding to complaints or inquiries about FleetZero’s information handling practices;
• contractual protections and information security procedures to ensure that service providers with whom we share personal data maintain adequate protections and security standards; and
• policies and procedures to respond to and mitigate breaches involving personal data.

Due to the global nature of FleetZero’s business operations, it may be necessary to send your personal data to other overseas FleetZero offices or third parties (as per section 5 above), unless we have specifically agreed to retain your personal data within a particular location. Examples of situations where your personal data may be transferred to a different country than the one where you are based include:

• where FleetZero has outsourced one or more aspects of its business (such as IT support); or
• where we have utilized cloud services to store/host data (meaning personal data may be stored on FleetZero’s behalf by a cloud provider in different locations around the world).

The main jurisdictions where FleetZero may transfer your personal data include Canada, the United States and India.

Some of the countries where your personal data is transferred have a different standard of data protection than the country where you are based. However, we have / will put in place contractual or other appropriate protections as prescribed by applicable data protection laws to ensure your information is adequately safeguarded globally.

Your personal data will be retained as long as necessary to fulfil the purposes for which it was collected, unless FleetZero needs to retain it as required by applicable laws. When determining the retention period, we consider various criteria, such as:

• the nature and duration of our relationship with you;
• the types and sensitivity of personal data;
• the purposes for which we use your personal data and whether we can achieve those purposes through other means;
• statutory retention and limitation periods; and
• other applicable legal requirements.

At the end of any retention period, your personal data will either be securely deleted in its entirety or anonymized so that you can no longer be identified from that data.

You have various legal rights in relation to your personal data, with some restrictions and exceptions, depending on the laws of the country where you are based. Such rights may allow you to ask FleetZero to:

• tell you whether we are using or storing your personal data;
• provide a copy of your personal data (subject to the privacy rights of other people and the information already provided to you in applicable privacy notices);
• correct any inaccuracies in your personal data by informing us to make the necessary changes;
• modify or withdraw your consent for the collection, use and disclosure of your personal data, where FleetZero has obtained your consent for this (see section 4 above);
• delete your personal data where there is no lawful justification for FleetZero to retain it;
• pause use of your personal data until FleetZero verifies any inaccuracies you notify us of, or we assess that FleetZero’s legitimate interests in processing your personal data outweigh your interests in the data not being processed; and
• transfer your personal data to you or another organization in a commonly used electronic format (the right to data portability).

You may also be able to object to your personal data being processed (including if we use it for profiling purposes), when:

• it is in our legitimate interests or those of a third party;
• FleetZero is acting in the public interest; or
• we use it for direct marketing purposes.

If you object to the last ground, FleetZero will stop processing your personal data for marketing purposes (and any associated profiling). In the other cases, FleetZero will stop processing the relevant data unless we identify compelling legitimate grounds to continue which override your privacy rights, or we need to process the data for a legal claim.

You may have additional rights in accordance with the local laws of the country where you are based. You may exercise or enquire about the above rights by contacting FleetZero’s data protection team (see section 11 below).

We do not knowingly solicit or collect personal data from children under the age of 16. If we discover that a child under the age of 16 has provided us with personal data without the verifiable consent of a parent or legal guardian, we will take reasonable steps to delete that information.

We hope this Privacy Policy has been helpful in setting out the way we handle your personal data and your rights to control it. This Privacy Policy sets out most of your rights under relevant laws, but not necessarily every right you have.

If you have any concerns, requests related to the exercise of your rights, complaints or questions that have not been covered, please contact us by emailing info@fleetzero.ai.

You may have a right to make a complaint to the relevant Data Protection Authority (“DPA”) at any time. We would appreciate the chance to understand your concerns in the first instance before you contact the DPA, however.

The website of the DPA responsible for overseeing data protection compliance in your country can be accessed via the IAPP Global Privacy Law and DPA Directory.

This Privacy Policy was last updated on the date shown at the top of this page. We may change this Privacy Policy from time to time by updating this page.

The California Consumer Privacy Protection Act (“CCPA”) confers certain rights on California consumers. California’s “Shine the Light” law permits California residents to request and obtain information about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. FleetZero is a business-to-business company and does not sell Personal Information. FleetZero does not distribute personal information it holds to outside parties for their direct marketing, or any other purpose, except as provided for in this Privacy Policy.