Eleos Technologies, LLC (“Eleos” or “we”) is committed to protecting our users’ privacy. We pledge that we will take reasonable steps to ensure that your information will only be used in ways that comply with this Privacy Notice. This Privacy Notice explains what information we collect about you, how the information is used, when the information may be disclosed, and what rights you have. This Privacy Notice also explains our data storage and deletion practices.
This Privacy Notice applies to our Drive Axle mobile application and other mobile apps, online platform, websites, online features, products, services and programs (collectively, the “Web Properties”). We will treat any offline collection, uses, and disclosures of your information consistently with our online privacy practices set forth in this Privacy Notice.
What Information We Collect
The types of information that we collect may include, among other things, the following categories of information:
- Contact information such as your name, company name, address, phone number and email address;
- Account information such as passwords and security questions and answers, and the date/time the account was created;
- Banking information such as your bank account and credit card numbers (the last 4 digits), card expiration date, and billing address;
- Your preferences related to selections you made;
- Access and activity logs, which may include contact information such as user names and IP addresses;
- Information about the device you are using;
- API token and platform token;
- System integration logs;
- Form data, messages and related metadata;
- Metadata about scanned documents, such as tagged document types, time scanned, time downloaded and identifiers, such as load numbers;
- Scanned documents, including images and photos (to document accidents, breakdowns, damaged freight, etc.), training videos, databases records and textual content extracted with optical character recognition;
- Navigation route activity logs;
- Load/trip data;
- TODO completion timestamps;
- News item read timestamps;
- Information regarding your acceptance of our terms of service and other agreements; and
- Information about when our in-motion locking function is overridden.
How Information is Collected
We may collect information about you from the following sources:
- Information we receive from your computer, mobile device, or any other device you use to access any of the Web Properties;
- Information we receive from you through the Web Properties and as a result of your use of our services, including when you create a user account (“User Account”);
- Information about your transactions with, or services performed by, us, our affiliates or nonaffiliated third parties;
- Information from the correspondence you and others send to us, including when you complete any online forms or send us an email;
- Information we receive from our affiliates, partners or service providers; and
- Information we receive from other sources, as permitted by applicable laws, rules and regulations.
We may also use other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, that indicate whether it had been viewed), web bugs (similar to pixel tags), and local storage objects (using mechanisms such as browser web storage (including HTML 5) and application data caches), which are used in mobile devices.
We use several pieces of third party software that use local storage technology. Like cookies, local storage is a tool that helps to collect your browsing behavior. Local storage technology allows us to generate reports and to facilitate live messaging between our web interface and our mobile applications. Local storage is generally deleted when the website that stored it deletes it. You can also delete storage from your browser at any time you like by visiting your web browser settings.
Web Beacons: Some of our web pages and electronic communications may contain images, which may or may not be visible to you, known as Web Beacons (sometimes referred to as “clear gifs”). Web Beacons collect only limited information that includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides. These Web Beacons are only used to track usage of the Web Properties and activities associated with the Web Properties.
Unique Identifier: We may assign you a unique internal identifier to help keep track of your future visits. We may use this information to gather aggregate demographic information about our visitors, and we may use it to personalize the information that you see on the Web Properties and some of the electronic communications you receive from us. We keep this information for our internal use.
How We Use Your Information
We use your information to improve our products and services. For example, your information allows us to review and optimize the functionality of our products.
We do not sell personal information that we collect about you. We may share your information with third party vendors that provide services in support of Eleos’ products and services. For example, we may share information with, or receive information from, third party payment processors, like Stripe, Inc. We may also share information with other third party vendors, including Periscope, to help us generate live reports for users of our system, and SendGrid, to help send outbound emails on behalf of our system and the users of our system. We may also share information with other third party service providers who provide production support and assist us in the collection of diagnostic data.
Our mobile applications may use the camera on your mobile device to enable certain features. These features enable you to scan work-related documents and to capture photos to document accidents, breakdowns, and damaged freight, and to share those images with your employer.
We may transmit your information to dispatchers to communicate when you have arrived at specific locations. We may also share certain documents, images, and videos related to your driving records with your employer for the purposes of integrating your information with your employer’s records.
The mobile applications may collect the approximate or precise geographic location of your mobile device. We may share your information with third party vendors who assist us with the navigation on our mobile apps. The shared information includes information about your location. These third parties may also collect their own usage analytics in connection with your use of the mobile navigation tools.
We may also disclose your information in connection with the intended use of our Drive Axle mobile application. The Drive Axle mobile application allows you to submit images of documents to other users, including your employer or a third party business affiliate. You understand that it us up to you to select with whom to share the documents, and you further acknowledge that once you share the documents, the recipients can do whatever they would like with those documents.
We reserve the right to transfer your information to third parties including buyers or service providers in connection with the merger, sale or other disposition of all or part of our business and/or assets, or in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of our creditors. You expressly agree and consent to the use and/or transfer of the foregoing information in connection with any of the above described proceedings. We cannot and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the information that is disclosed to us.
When We Disclose Your Information
We might disclose your information to law enforcement, government officials, or third parties when required by law or in the good-faith belief that such disclosure is necessary: (1) to comply with legal processes and applicable law; (2) to enforce this Privacy Notice; (3) to take precautions against liability and respond to any claim that any information provided by you violates the rights of a third party; (4) to assist government enforcement agencies; (5) to protect our rights, property, or the safety or the rights, property, or personal safety of our visitors and the public, which includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction, and, if required by law, disclosing information to U.S. federal and state governmental agencies; (6) to investigate potential unauthorized access or misuse of the Web Properties; and/or (7) to otherwise enforce or apply our website terms of service and other agreements.
You have control over the information you share with us and control over the applications you use. You may choose not to submit information, but that may affect your ability to use and the proper functionality of Eleos’ products and services.
When you share information about your driving history, take images of accidents, breakdowns or damaged freight, or when you upload documents for work purposes, such images and documentation will be used in support of the business you conduct. Your employer may use the information in accordance with the terms of your employment or contactor agreement. You should consult with your employer to understand your rights in connection with such images and documentation.
In accordance with applicable law, you may have the right to request access to and receive information about the personal data that Eleos maintains, you may provide updates and corrections to your personal data, and you may have your personal data transferred or deleted. We ask individuals to identify themselves and the information requested to be accessed before processing such requests. We will promptly respond to your requests, but we may decline to process requests in limited circumstances, as permitted by applicable laws, rules and regulations.
Security and User Accounts
When you access your User Account by logging into the mobile applications, some of your data, like messages, loads and stops, and images, is cached locally on your phone for offline use. Certain permissions, like read, modify and delete permissions are necessary in order for the data to be maintained and stored on your phone. You are solely responsible for all data that you store on your phone, and you are responsible for any loss, destruction or theft of such data. Although we implement measures designed to secure the information collected on our Web Properties from accidental loss and from unauthorized access, use, alteration or disclosure, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your information for improper purposes, nor can we guarantee that the transmission of data over the Internet will be 100% secure. You are ultimately responsible for protecting your username, password and User Account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. We recommend that you follow standard password protection best practices, for example creating long passphrases and not reusing old passwords. You agree to immediately notify us of any unauthorized use of your username, password and/or User Account, and/or any other breach of security, and ensure that you log out from your User Account at the end of each session.
A. Data Retention
In general, Eleos makes every effort, within 90 days or less (“Data Retention Period”), to automatically purge and/or anonymize all data linked to personally identifiable user activity that is not deemed necessary for the operation of our systems. Some users may have arranged with us to purge and/or anonymize information more or less expeditiously than the general Data Retention Period that is in place for our other users.
The following list contains examples of data that is retained beyond the Data Retention Period. This list is not exhaustive and may change from time to time.
- Agreement logs for in-motion locking, and navigation route approval;
- Telematics session data, including username, session id, session date/time, and Geotab database name;
- Push message token data, including platform iOS/Android, and token created, subscribed and deactivation dates;
- Metadata about scanned documents, such as tagged document types, time scanned, time downloaded and identifiers, such as load numbers;
- Drive Axle documents; and
- User Account information, such as:
- Full name,
- Email address (for backend users),
- Date/time account was created,
- Last two usage times and IP addresses,
- Most recently used device type and user agent,
- Total number of times accessing server,
- API token,
- Platform token, and
- Custom data provided by integration.
B. Third Party Controlled Systems
Eleos utilizes several third party service vendors for reporting and to assist in the collection of diagnostic data from remote devices upon which our mobile apps run. We make every reasonable effort to purge and/or anonymize data stored in these third party systems according to our own standards and practices.
App Store and Google Play Store reviews are stored by Apple and/or Google, and are fully controlled by the respective parties. Eleos does not have the ability to purge and/or modify app review data that is stored by Apple and/or Google.
C. Database Backups
Eleos performs regular database backups in accordance with standard industry practices, and does not retain database backups longer than the Data Retention Period.
D. Data Purging and Anonymization Practices
Eleos has configured batch jobs to archive transactional data from our database to external storage. In such cases we have configured external storage to automatically and permanently delete data after a period of time no longer than the Data Retention Period.
Eleos anonymizes and stores certain data indefinitely (1) for accounting and in-app purposes in order to provide historical billing details and application utilization reports, and (2) to identify potential opportunities to improve our products and services.
Information from Children
The Web Properties are not intended or designed to attract children under the age of thirteen (13). You affirm that you are at least eighteen (18) years of age, or you are an emancipated minor, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Privacy Notice, and to abide by and comply with this Privacy Notice. In any case, by using the Web Properties, you affirm that you are over the age of thirteen (13), as THE WEB PROPERTIES ARE NOT INTENDED FOR CHILDREN UNDER THIRTEEN (13) WHO ARE UNACCOMPANIED BY THEIR PARENT(S) OR LEGAL GUARDIAN(S).
Privacy Outside the Web Properties
The Web Properties may now or in the future contain various links to other websites. We are not and cannot be responsible for the privacy practices or the content of any of those websites. Please check with those websites in order to determine their privacy policies and your rights under them.
European Union Users
The Web Properties and our products are intended for individuals located in the United States, and your use of our products and services are governed by United States law. We are not targeting or marketing to international users. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using the Web Properties or our products and services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.
Choices with Your Information and Opting Out
Whether you submit any personal information to us is entirely up to you. You are under no obligation to provide any personal information to us. However, this information is essential for the provision and quality of some of the services and products that we offer to you, so we cannot provide you with certain services or products, or provide you with access to certain features, if you choose to withhold requested information, for example providing products that require your payment information.
You may choose to prevent us from disclosing or using your personal information under certain circumstances (“opt out”). You may opt out of any disclosure or use of your personal information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by notifying us by one of the methods at the end of this Privacy Notice, or by following the procedures set forth in an electronic communication from us, if applicable. Furthermore, even where your personal information is to be disclosed and used in accordance with the stated purposes in this Privacy Notice, you may elect to opt out of such disclosure to and use by a third party that is not acting as our agent. There are some uses from which you cannot opt out, such as to provide products, features or services that you have requested from us. In addition, we use third party diagnostic tools to track system errors, and you may not be able to opt out of such use.
Please note that making such requests does not ensure complete or comprehensive removal of your content. For example, we may retain the information for our own internal records in accordance with the terms of this Privacy Notice.
Your California Privacy Rights
Under California’s “Shine the Light” law, California residents who provide certain personally identifiable information in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from us (once per calendar year) information about the information that we shared (if any) with other businesses for their own direct marketing uses. If applicable, this information would include the categories of information and the names and addresses of those businesses with which we shared information for the immediately prior calendar year. To obtain this information, please send an email message to email@example.com with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in our response.
California residents who use the Web Properties are also entitled to the following consumer rights notice: The Web Properties are owned and/or operated by Eleos or one of our affiliated companies. Unless expressly stated, the Web Properties are provided without charge. If you have a question or complaint regarding the services or products provided through the Web Properties, please send an email to firstname.lastname@example.org. You may also contact us by writing to us at 200 North Main Street, Suite 205, Greenville, SC 29601 or by calling us at (855) 953-2953. California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
“Do Not Track” Signals
Because we may collect your personal information from time to time for our own use, we are required to disclose how we respond to “Do Not Track” requests, signals and other similar mechanisms. Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
Your Consent to This Privacy Notice and Contact Information
By accessing and using the Web Properties, you consent to the collection and use of your information by us as specified above or as we otherwise see fit, in compliance with this Privacy Notice, unless you inform us otherwise by means of the procedure identified below. If we decide to change this Privacy Notice or some part of it, we will make an effort to post those changes so that you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose that information to others. Your use of the Web Properties following our publication of any amendment of this Privacy Notice will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.
If you have questions or comments or would like to access your personal information or opt out of certain sharing, please let us know by sending your comments or requests to:
Eleos Technologies, LLC
200 North Main Street, Suite 205
Greenville, SC 29601
Phone: (855) 953-2953
Effective Date: August 12, 2019
Last Updated Date: August 9, 2019