1. IMPORTANT INFORMATION AND WHO WE ARE

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.

2. THE APP

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.

3. THE DATA WE COLLECT ABOUT YOU

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data
• Contact Data
• Financial Data
• Transaction Data
• Device Data
• Content Data
• Profile Data
• Usage Data
• Marketing and Communications Data
• Location Data

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.

4. HOW IS YOUR PERSONAL DATA COLLECTED

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.

5. HOW WE USE YOUR PERSONAL DATA

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:

• Where you have consented before the processing, either through the App or with your employer (our Customer) through your terms of employment with your employer.
• Where we need to perform a contract we are about to enter or have entered with you or the Customer, by whom you are employed.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

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)

6. DISCLOSURES OF YOUR PERSONAL DATA

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]:

• Internal Third Parties as set out in the [Glossary].
• External Third Parties as set out in the [Glossary].
• Your employer (our Customer).
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

7. INTERNATIONAL TRANSFERS

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.

8. DATA SECURITY

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.

9. DATA RETENTION

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.

10. YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

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.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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).

11. GLOSSARY

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

• Identity Data: first name, last name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data: delivery address, email address and telephone numbers.
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone settings.
• Content Data: includes information stored on your Device, including [login information,] [photos, videos or other digital content,] [check-ins,] [OTHER INFORMATION].
• Profile Data: includes [your username and password, in-App purchase history, your interests, preferences, feedback and survey responses].
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, [traffic data [and other communication data],] whether this is required for our own billing purposes or otherwise [and the resources that you access].
• Marketing and Communications Data: includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
• Location Data: includes your current location disclosed by GPS technology.

Version 1 - 12.2019