Welcome to RAM’s privacy policy for the RAM Assist Application (the “App”).
RAM respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you Register for or otherwise use the App and tells you about your privacy rights and how the law protects you.
This privacy policy (together with our RAM Assist Agreement and Terms and Conditions) applies to both the Customer who signs up for the App for their business, and to users who register to use or access the App such as administrative employees of the Customer and Drivers.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE APP
3. THE DATA WE COLLECT ABOUT YOU
4. HOW IS YOUR PERSONAL DATA COLLECTED
5. HOW WE USE YOUR PERSONAL DATA
6. DISCLOSURES OF YOUR PERSONAL DATA
11. GLOSSARY
Purpose of this privacy policy
This privacy policy aims to give you information on how RAM collects and processes your personal data through your use of the App, including any data you may provide through your use of the App for example when uploading information from a mobile device.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Our Customer which contracts to use our App is the Controller and responsible for your data. RAM is the Processor of your data and processes it on behalf of the Customer.
This privacy policy is issued on behalf of the RAM Group so when we mention RAM, "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the RAM Group responsible for processing your data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise [your legal rights- Link], please contact the DPO using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Remote Asset Management Limited
Email address: info@ramtracking.com
Postal address: RAM Tracking, Nelson House, George Mann Road, Leeds, LS10 1DJ
Telephone number: 0330 100 3622
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on December 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Consent to installation of the App
Before you are granted access to or use of the App, you are required to indicate your consent to our processing of your personal data (including your name, contact details, financial, device information, mobile number ) as described in this policy. By agreeing that you accept this Policy you agree to where you are a user of the App this privacy policy and where applicable, the installation of the App onto your mobile telephone or handheld device (Device). The App can be turned off by you at any time through the controls on your Device.
How you can withdraw consent
You may change your mind and withdraw consent at any time by contacting us but that will not affect the lawfulness of any processing carried out before you withdraw your consent. It will also prevent use of the App which may have consequences in your employment with the Customer.
Consent to processing Location Data
If you are a driver, you consent to processing of your Location Data (including details of your current location disclosed by GPS technology on the Device so that location-enabled Services are activated to provide us and the Customer with real time location data). Location data is activated once you have downloaded or streamed a copy of the App onto your Device.
We may collect, use, store and transfer different kinds of personal data about you as follows:
We explain these categories of data here [LINK TO DESCRIPTION OF CATEGORIES OF PERSONAL DATA in GLOSSARY BELOW].
We also collect, use and share Aggregated Data such as location data where the Device is located and travelling, statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the flow of traffic in the area in which the Device is in use, and the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Information you give us.
This is information (including Identity, Contact, and Communications Data) you consent to giving us, or allowing your employer to give to us, about you by registering for the app, or by corresponding with us (for example, by email, SMS or chat), or through your contract of employment or terms of employment with our Customer. It includes information you provide when you register to use the App Site, upload information or documentation, and when you report a problem with an App or our Services. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device.
Each time you activate the App and whilst it is in use, we will automatically collect personal data including Device, Content and Usage Data. We will also collect data when you upload information or documentation to the App such as receipts. We collect this data using cookies and other similar technologies.
Location Data.
We also use GPS technology to determine your current location. Our location-enabled Services require your personal data for the feature to work. [You can withdraw your consent at any time by disabling Location Data in your settings].
Information we receive from other sources including third parties and publicly available sources.
We will receive personal data about you from your employer, namely identity, Contact and Vehicle details.
Cookies
We use cookies and/or other tracking technologies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App.
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
We will only send you information to enable you to interact with the App and our Services. We may send this by text/SMS or email where we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will not share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data
|
Purpose/activity |
Type of data |
Lawful basis for processing |
|
To install the App and register you as a new App user |
Identity Contact Financial Device |
Your consent |
|
To deliver Services to you and our Customer (your employer) |
Identity Contact Transaction Device Communications Location Data uploads |
Your consent Performance of a contract with you or your employer (our Customer) Necessary for our legitimate interests |
|
To manage our relationship with you including notifying you of changes to the App or in relation to any Services |
Identity Contact Profile Communications |
Your consent Performance of a contract with you or your employer (our Customer) Necessary for our legitimate interests (to keep records updated and to analyse how customers use the App/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
|
To administer and protect our business and this App including troubleshooting, data analysis and system testing |
Identity Contact Device |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
|
To deliver content to you To measure and analyse the effectiveness of the App To monitor trends so we can improve the App |
Identity Contact Device Content Profile Usage Communications Location |
Consent Necessary for our legitimate interests (to develop our products/Services and grow our business) |
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table [Purposes for which we will use your personal data]:
We do not transfer your personal data outside the and European Economic Area (EEA) save if/when the United Kingdom leaves the EU/EEA, data will continue to be processed in the UK.
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
[We will collect and store personal data on your Device using [App data caches and browser web storage (including HTML5) and other technology].
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. Where you are an employee of the Customer, we shall only retain data for so long as it is necessary for the purpose of providing our services to the Customer.
In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for assessing road traffic conditions (Device only), research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
You have the right to:
if you want us to establish the data's accuracy;
where our use of the data is unlawful but you do not want us to erase it;
where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
You can exercise any of these rights at any time by contacting us via the contact details given above. Further information is also available at the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
Lawful basis
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Third parties
Internal third parties
Other companies in the RAM Group acting as joint processors and who are based in the UK and provide IT and system administration services and undertake leadership reporting.
External third parties
Your employer (our Customer).
Service providers acting as processors based in the EEA who provide IT and system administration services.
Your legal rights
Description of categories of personal data
Version 1 - 12.2019