Privacy Policy

Last Updated: May 25, 2020

This privacy policy describes the personal data (defined below) that the telematics business of Vecima Networks Inc. (“Nero Global Tracking” (“Nero”), “we”, “us” and/or “our”) collect about you, and how we use and protect this personal data. Your privacy and the security of your personal data matters to us, so please get to know our privacy practices.

This Policy describes how we collect, use and disclose personal data when you use the following:

  • Any website that we operate and which displays or links to this Policy (“website(s)”), including www.neroglobal.com.
  • The Nero web-based fleet and asset management software platform (the “Nero Solution”) that is available to Nero customers (a “Customer”). The Nero Solution, together with a telematics device installed in a Customer vehicle, enables Customers to manage all fleet vehicle, driver, and asset information in one place and use it to make more informed decisions regarding their fleet and equipment.

If the Nero Solution collects information about you (e.g., as an employee of a Nero Customer), please note that this privacy policy covers only those instances when the purposes and means of processing your personal data are determined by us.  It does not apply to any of your personal data which we may process on behalf of our Customers. Please directly contact the relevant Customer (e.g., your employer, if you are an employee of a Nero Customer) for more information about their privacy practices.

If you are a California (USA) Resident: We have not sold personal information, as “sell” and “personal information” are defined under the California Consumer Privacy Act of 2018, in the preceding 12 months.

 

1.      COLLECTION AND USE OF DATA

1.1.            Personal Data

“Personal data” is any information that relates to an identified or identifiable individual. Nero may collect personal data when you provide such information directly to us, when personal data is automatically collected in connection with your use of the Nero Solution, or when third parties such as our service providers or business partners provide us with Personal data. Following is a description of the types of data we collect and the purposes of collection and processing.

  • Personal data you provide directly. We may collect personal data that you provide directly, such as when you visit our website, establish a user account, register our products, or otherwise give us your name, email address, contact phone number, etc. You may also voluntarily submit additional information, such as vehicle make, model, year, and VIN, as part of creating and maintaining an account with us. You may also choose to submit personal data to us via other methods, such as in connection with an actual or potential business relationship or in response to marketing communications.  When you contact Nero, we may also keep a record of your communication to better support you in the future.
  • Personal data we collect automatically. We may automatically collect information about how you use and engage with our business (e.g., via our websites and/or applications) and products and/or services used over time. Some of this information may be include personal data. In addition, we may use cookies and other technologies to function effectively.
  • Personal data we collect from other sources. We may receive your personal data via a referral. In addition, we may supplement other personal data we have collected with information from third parties or other publicly available sources, to the extent permitted by law.

Categories of personal data we collect.

Depending on your interaction with our business, we may collect:

  • Personal identifiers, such as your name, email address, phone number, account name, postal address, unique personal identifier, driver identification, or other similar identifiers.
  • Internet activity information, such as Internet protocol (IP) address, browser type, operating system, Internet service provider, the referring web page that directed you to our services, the date and time of your visit, information about how you engage with us, whether an email was opened, and other standard server log information.
  • Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consumption histories or tendencies.
  • Professional information, such as your title and company name.
  • Vehicle Data, such as if you drive a vehicle connected to the Nero Solution, we receive personal data about you to the extent our Customer provides such personal data to us, and we process such personal data in accordance with our Customer’s written instructions or as required by applicable law. To the extent that personal data about you may be inferred from technical vehicle information collected from the device, we process such personal data in accordance with this Policy.

How we use personal data we collect.

We collect, use, and store your personal data for the reasons set out below.

  • Administering our relationship with you. This includes:
    • Creating and administering orders
    • Registering, maintaining and managing your account  or for interacting with our business
    • Providing you with technical support and responding to your queries or feedback
    • Notifying you of service announcements, scheduled system maintenance, or business updates and offers.
    • When attending events
  • Where necessary for Nero’s legitimate interests, and where our interests are not overridden by your data protection rights. This includes:
    • Developing product or service features or functionality
    • Identifying, developing, and marketing products and services that will interest you
    • Communicating with you regarding our business, products and services
    • Protecting our legitimate business interests and legal rights, including use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes  and other ethics and compliance reporting requirements
  • Where necessary to comply with a legal obligation.

 

2.      COOKIES AND SIMILAR TECHNOLOGIES

Some personal data may be collected by us or our partners through cookies, pixel tags, and other similar technologies for a variety of purposes. Cookies, used by most websites, are text files stored on a user’s browser containing information about the user (e.g., information about devices and networks used to access our website). Pixel tags (also known as “clear GIFs” or “web beacons”) are very small images or small pieces of data embedded in images that can recognize cookies, the time and date a page is viewed, whether an email was viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. You may be able to set your browser to block cookies or to notify you before a cookie is set.  If you block all cookies you may not be able to use all of the features of our website.

Please note that some of our products and services may be offered jointly with partners. If you register with our partner, Nero may also receive your personal data from them, and Nero may share your personal data with our partners for these joint offerings. If applicable, you should also review our partner’s privacy policy, which may have different terms.

 

3.      SECURITY

We are committed to keeping personal data secure. We have implemented technical and organizational measures to protect personal data against its unauthorized access, use, and disclosure. Such measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of the personal data.

 

4.      THIRD PARTY WEBSITES AND FEATURES

As a convenience to you, we may provide links from our websites, products and/or services to other websites maintained by independent third parties. We are not responsible for the privacy practices of independent third parties. Please be aware when you leave this website, and we encourage you to read the privacy policies of any other websites that you may visit.

 

5.      DISCLOSURE OF PERSONAL DATA

Personal data we collect on behalf of our Customers is shared with our Customers pursuant to the terms of our contract with them.  We are not responsible for how our Customers collect, use and disclose personal data.

We may use service providers (including affiliates acting in this capacity) to provide certain services on our behalf such as data hosting and processing, customer service, marketing, analytics and similar services.  These service providers will have access to, or may otherwise collect and process, personal data on our behalf.  We require our service providers to only use the personal data that they have access to in performing services for us, for the purposes of providing the service, and to take appropriate steps to protect the personal data.  Some of these service providers may be located outside of your country of residence, including in Canada and the United States

If we were to enter into discussions regarding the sale or divestment of all or substantially all of our business, stock, or assets with another entity, we may assign or transfer this Policy as well as your account and related data (including personal data) in accordance with applicable law.

We may disclose personal data where permitted or required by law, including as required by foreign laws applicable to us, our affiliates and service providers.

 

6.      ACCESS AND CORRECTION OF PERSONAL DATA

The file containing your personal data will be maintained on our servers or those of our service providers and will be accessible by authorized employees, contractors and service providers as necessary for the purposes described in this Policy.  You may request access to or correction of the personal data in our custody or control by writing to our privacy officer at privacy @ neroglobal.com.  Your right to access and correct your personal data is subject to applicable legal restrictions.  We may take steps to verify your identity before providing you with access to your personal data or making corrections.  You may also contact us as described above if you have any questions or concerns about this Policy or our personal data handling practices.

 

7.      CHANGES TO THIS POLICY

If we make any changes to this Policy, we will post an updated Policy on our neroglobal.com website. You should periodically review this page for the latest information on our privacy practices. The updated Policy will become effective as of the date stated in the Policy and following any additional steps we may be required to take under applicable law.