Dasar Privasi

Updated: March 11^th 2021
PRIVACY POLICY FOR EDRIVING SITE AND SERVICES

Introduction

This privacy policy explains how eDriving, LLC (“eDriving,” “our,” “we” or “us”) handles and treats personal data when you use our website located at www.eDriving.com (“Site” or “Website”), Mentor^® by eDriving App (“Mentor App”) and all its derivatives, Mentor^® by eDriving portal (“Mentor Portal”), or our portal for Virtual Risk Manager^® (“VRM”) (collectively, “Services”). It describes the nature of the personal information that is processed by us, how we use or share that information, the choices available to you regarding our use of your information, how you can access and update your information, and the measures eDriving takes to keep your information safe.

Personal Information That We Collect

Throughout this policy, we use the term “personal information” to describe information that identifies or makes you identifiable. Information that has been anonymized so that it does not identify a specific individual is not “personal information.” When you use our Services, we collect information that you choose to send to us and certain other information relating to your use of our Services that is collected automatically. By using our Services, you consent to the terms of this privacy policy. We also may provide in-time notice or obtain consent for certain practices. For example, we may obtain consent using standard permissions available on your device that apply to the Mentor App.

eDriving only collects your personal information if you have provided your consent in your capacity as a private individual using one or more of eDriving’s Services, or in your capacity as an employee of a company who is providing you access to one or more of eDriving’s Services:

Personal Information You Provide Voluntarily:

When you register for an account using one or more of our Services, we collect your first name, last name, and email address.

Personal Information That We Automatically Collect:

Cookies; Log Files and Similar Technologies: We use cookies, log files, web beacons and other similar technologies to automatically collect information, display information more effectively and improve Services, and for security purposes. The information that we collect using these technologies includes user preference, computer or device settings, page views, Internet protocol (IP) address, browser type, operating system, Internet service provider (ISP) name, referring, entry and exit pages, platform type, date/time stamp, whether you have viewed certain communications, and so forth. Strictly necessary cookies are always enabled; however, you can manage all other cookie settings, using our cookie banner.

Other Automatically Collected Device Information: When you install and activate the Mentor by eDriving^SM application (the “App”) on your mobile device, it collects the following information.

Your driving behavior: The App uses your mobile device’s internal sensors (e.g., its gyroscope and motion tracker) to collect information regarding your driving behavior data, including acceleration, hard braking, cornering, and speeding.
Location, travel and route information: When you are on a driving trip, the App gathers location and route information in the form of GPS signals. This is NOT shared with your organization.
Phone usage and activity: The App measures general phone activity, including when the screen is on, texting, phone calls and phone movement. The App does NOT record any individually identifying usage or activity information, such as key strokes, content of phone calls, contacts, photographs (unless uploaded by the driver) or which other applications are running.
Information about the device: The App collects eDriving specific webpage views, IP address, browser type, and operating system information.

My Work Team Circles

If your organization has opted to use Mentor My Work Team Circles, your immediate team will see your 7-day rolling FICO Safe Driving Score and summary of events (shown only as red, amber, green – not the number of events). The circle automatically includes all team members, as directed by the Data Controller. If you wish to stop sharing summary information with your colleagues, you can set this by going to ‘Edit’ at the top right of the screen and switch sharing to ‘off’. Thereafter, only your manager will see your scores.

Privacy protection reminder for shift-based drivers

The Mentor DSP/DDP app only records driver activity after the driver selects “Begin Route” at the beginning of their shift and until they select “End Route” after the Post Trip DVCR at the end of their shift. The app does NOT record data, including driving activities and location, at any other time.
If you FORGET to complete your Post-trip DVCR at the end of your route, you will be automatically logged out of the Mentor DSP/DDP app at midnight, which will automatically end any on-going trip scoring – until then, you could be scored while driving off duty!

Our Use of Personal Information

Your personal information that you provide, whether it be voluntarily or automatically collected, may be used in one or more of the following ways:

To Provide Features of Our Apps and Website and Improve Our Business, Products and Services: We use data that we collect to deliver existing features and functions of our Services. For example, we use your location and driving behavior data to perform and provide analytics, including calculating and providing you with your personalized driving score; information regarding positive and negative driving events; daily, weekly and monthly driving trends; and targeted coaching modules based on your driving analytics. We also may use this information to perform testing, conduct research and deliver or offer new Services or new features or improve the overall user experience.

To Process Payments: If you purchase a private subscription of Mentor, your credit card number will only be used to process payments and are not used for any other purposes. Personal information collected during the payment process, such as your email address and phone number, is used to get in touch with you if we have trouble processing an order. We share information as necessary with a third-party service credit card processing service provider with which we maintain a written agreement to ensure appropriate security and confidentiality measures are in place to safeguard your personal and financial data. We will not authorize the release of your personal or financial information to anyone not directly involved in processing the transaction of your order.

To Communicate about Products and Services: eDriving and its subsidiaries or affiliates offer additional products and services. We may provide relevant offers to you as well as from eDriving subsidiary or affiliate brands and service providers, unless you have opted out of receiving such communications.

To Comply with Legal Obligations and Protect Your and Others’ Rights, Property and Safety: The personal information we collect online or via the App is also used for verification of your identity while using any of our products and services or used to prevent fraudulent use and, when applicable, for accurate processing.

General Analytic Purposes: We use IP addresses to analyze trends, administer our Services, track customers’ usage of our website, and gather broad demographic information for our exclusive use. IP addresses are not linked to other personal information and we do not store IP addresses in our database. Occasionally, we may disclose aggregate statistics from our logs that do not contain personal information when dealing with service providers, affiliates, or business partners.

Sharing and Disclosure of Personal Information

We do NOT share any personal information, location or driving behavior data, other than as specified below.

Employers: If you are driving as part of your employment or contract and are using Mentor by eDriving^SM as part of your company or organization’s contracted relationship with eDriving, your FICO^® Safe Driving Score, driving behavior and derivative scores (including but not limited to acceleration, braking, cornering, speed, and distraction), areas of improvement, and general trending on your driving behavior will be shared with your company or organization per the terms of the agreement with your company or organization in accordance with your company or organization’s policies. Your GPS or location information will NOT be shared with your employer.

Parent/Guardian: If you are under the age of 18, your driving behavior data and/or location will be shared with your parent/guardian

Family: If you have provided consent or opted in to providing your driving behavior data and/or location to family members who are also using the Mentor for Families service.

Insurance Carrier: If you have provided consent or opted in to providing your driving behavior data to your insurance carrier to receive discounts, rewards, etc.

Third-Party Service Providers: Your personal information will only be shared with your Consent, for example: your name, email address, country of residence or driving behavior may be shared with one or more third-party service providers as set forth below:

Certain Services or product features may be delivered by third parties. By using our App or other Services, you hereby acknowledge and consent that eDriving may share such information and data with any third party with whom eDriving has a contractual relationship to provide the requested product, service or functionality on behalf of users and customers of the Services. This sharing may include, for example, third party verification partners such as licensing authorities, fleet management companies, insurance companies, to whom data is passed for means of authenticating users and third party hosted call center solutions, for telecommunication (including chats and emails) and call monitoring services. As another example, your personal information may be shared with various course providers we contract with to provide course delivery and certificate fulfillment. These agents access our database to offer customer support to students in their respective states, print certificates of completion, and/or report course completions results to regulatory bodies.

Your personal information may be anonymously aggregated into our scoring and other models of safe driving to improve our ability to assess driving behavior and these models may be shared with our customers or other third parties, as permitted by applicable laws.

In addition, eDriving may sell or buy other businesses or entities. In such transactions, your personal information may be one of the transferred business assets.

Compliance with Legally Required Disclosures or Enforcement of Rights: Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law when we have a good-faith belief that such action is necessary to comply with an appropriate law enforcement investigation, current judicial proceeding, a court order, or legal process, or is otherwise required by law, as directed by the Data Controller.

Business Transfer: We reserve the right to transfer your personal information in the event of a potential or actual sale or transfer of all or a portion of our business or assets. Following such sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of your personal information.

Protection and Management of Your Personal Information

Security: If you have a user name and password for any of our Services, you have the responsibility of keeping your password secret. You should not reveal your password to anyone. eDriving will not ask you in an unsolicited telephone call or e-mail for your password. In addition, you should take reasonable precautions when using a computer that is not yours in a public setting. We are committed to keeping the personal information provided to us secure and we have implemented appropriate information security policies, processes and technical measures to protect the personal information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss, including the following:

All personal information is encrypted and secured during Hyper Text Transfer Protocol Secured (HTTPS) transmission and at rest (minimum 256 bit encryption);
Access online to VRM and Mentor^® services is via HTTPS only;
Multiple levels of security, including CCTV, restricted access, and locked cabinets;
24/7 monitoring and intrusion protection;
Regularly scheduled security testing;
ISO27001 certification for Information Security and regularly audited (both internally and by third parties);
Strict employee procedures regarding data protection, including staff vetting and training; and
All of our partners, employees, contractors, and service providers who have access to, and are associated with the processing of personal information, are contractually obligated to respect the confidentiality of your personal information.

Retention: For visitors to our Website, we retain personal information for at least [three (3)] years from the date of our last interaction or such longer period as required by applicable law. For users of Services, we retain information regarding your use of the Services, such as your driving behavior, for at least seven (7) years from the date of our last interaction or such period agreed with your employer or as required by applicable law.

Access and Management of Your Personal Data: Your account settings allow you to access your personal information, as well as change and delete your personal information. For example, you can edit or delete personal information such as your name, email, and password. In addition, if you are a parent or guardian of a minor using one or more of the Services, you may review and request that we update or delete your minor’s information by sending us a request via our secure request form.

Links to Other Sites

For your convenience, eDriving’s Services may contain links to other websites. Some of these websites are administered by or on behalf of eDriving, while others are unrelated. eDriving is not responsible for the privacy practices or the content of linked websites not administered by eDriving, and this privacy policy does not apply to those linked websites. Each linked website should be checked for its own privacy statement.

Special Notification – California

Notice to California Residents: Civil Code Section 1798.83. California law requires us to inform California residents who have provided us with personal information that they may request of us information about our disclosures to third parties for their direct marketing purposes. To do so, contact us at: Privacy@eDriving.com and indicate in the subject line “California Privacy Rights”.

Collection of Information from Children: We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of the Website or the App is directed to children under the age of 13. If you learn that your child has provided us with personal information without your consent, you may alert us using the contact details below. If we learn that we have collected any personal information from children under 13, we will promptly take steps to delete such information. A parent or guardian using Mentor^® for Families may register a child age 14 or over to visit or join one of our courses.

Notice Regarding Communications to You from eDriving: eDriving may send to you one or more of the following communications:

Status updates on progress with our Services via weekly and monthly emails and/or text or in-app notifications.

Transactional emails: Our products, services and courses are designed to generate email notifications at certain intervals, such as password information, course completion information, reminders, transactional confirmations and notices of updates to this privacy policy (if we choose to provide such notices to you in this manner). These emails are exclusively related to the products and services offered through and subscribed to by you on the Website or other Services.

Parental Notification Emails: If you are a teen or novice driver (at least 14, but under the age of 18) using Mentor^® for Families and want to participate in the use of the Services, we must receive permissions from your parent or legal guardian to participate and to provide personal information to us necessary to process your registration (such as name and email address).

Informational and Marketing Emails: Occasionally, we will provide safety tips, news and promotional offers for eDriving and subsidiary product and service offers. You have a right at any time to stop us from contacting you for marketing purposes. You can opt out of all marketing and newsletter emails by clicking the “Unsubscribe” link at the bottom of the email, or by contacting us directly using the contact details below. If you ask us to remove your name and address from marketing and newsletter emails, we will maintain your name in a “do not contact” file to ensure that we can honor your request, however it may take up to 10 days to process your request. Please be aware that if you opt out of eDriving emails, you will still receive transactional emails from eDriving for essential communications.

Notice to Individuals in the European Economic Area and Switzerland

This section only applies to individuals using or accessing our Services while located in the European Economic Area and/or Switzerland (collectively, the “Designated Countries”) at the time of data collection.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in the Designated Countries.

Legal Basis. In the sections above we explain various ways that eDriving collects and uses your personal information on its own and with respect to third parties. We will use your personal information only (1) with your consent; (2) to perform a contract between you and us; (3) to comply with a legal obligation or (4) where we have a legitimate interest to do so, balancing this interest against your interests and fundamental rights.

Processing is based on our contract obligations or to take steps at the request of the individual, prior to entering into a contract.

To Provide the Services, as directed by the Data Controller
To Respond to Your Inquiries
To Provide Customer Support
To Ensure the Security of the Service
To Enforce our Terms and Agreements
Share with eDriving affiliated entities
Share with Our Service Providers, Business Partners and Others

Processing is based on our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services.

To Personalize Your Experience on the Services
For Research and Development Purposes
Sharing Due to Corporate Reorganization

Processing is necessary for compliance with our legal obligations.

To Ensure the Security of the Service.
Share Due to Law Enforcement Requests
To Enforce our Terms and Agreements

Marketing. We will only contact individuals located in the Designated Countries by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law, and/or the individual’s consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.

If you do not want us to use your personal information in this way, please click an unsubscribe link in your emails or send us a request via our secure request form or send us an email at Privacy@eDriving.com. You can object to direct marketing at any time and free of charge.

Individual Rights. We provide you with the rights described below when you use our Services. We may limit your individual rights requests (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or burdensome.

We may seek to verify your identity when we receive an individual rights request from you to ensure the security of your personal information.

Access, Correct, Delete. You have the right to access, correct, update or request deletion of your personal information under certain circumstances.

Object to Use. You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

Right to Withdraw Consent. For any consent-based processing of your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

If you would like to exercise your rights under applicable law, please contact us at Privacy@eDriving.com.

Right to Lodge Complaint. If you believe we have infringed or violated your privacy rights under the EU GDPR, please contact us at Privacy@eDriving.com so that we may resolve your dispute directly. As a European data subject, you also have the right to lodge a complaint with a supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

Notice to Individuals in the United Kingdom

This section only applies to individuals using or accessing our Services while located in the United Kingdom at the time of data collection.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the United Kingdom. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in the United Kingdom.

Legal Basis. In the sections above we explain various ways that eDriving collects and uses your personal information on its own and with respect to third parties. We will use your personal information only (1) with your consent; or (2) to perform a contract between you and us; (3) to comply with a legal obligation or (4) where we have a legitimate interest to do so, balancing this interest against your interests and fundamental rights.

Processing is based on our contract obligations or to take steps at the request of the individual, prior to entering into a contract.

To Provide the Services as directed by the Data Controller
To Respond to Your Inquiries
To Provide Customer Support
To Ensure the Security of the Service.
To Enforce our Terms and Agreements
Share with eDriving affiliated entities
Share with Our Service Providers, Business Partners and Others

To Personalize Your Experience on the Services
For Research and Development Purposes
Sharing Due to Corporate Reorganization

Processing is necessary for compliance with our legal obligations.

To Ensure the Security of the Service.
Share Due to Law Enforcement Requests
To Enforce our Terms and Agreements

Marketing. We will only contact individuals located in the United Kingdom by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law, and/or the individual’s consent. When we rely on legitimate interest, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you.

We may seek to verify your identity when we receive an individual rights request from you to ensure the security of your personal information.

Access, Correct, Delete. You have the right to access, correct, update or request deletion of your personal information under certain circumstances.

Object to Use. You can object to the processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

If you would like to exercise your rights under applicable law, please contact us at Privacy@eDriving.com.

Right to Lodge Complaint. If you believe we have infringed or violated your privacy rights under the UK GDPR or Data Protection Act, please contact us at Privacy@eDriving.com so that we may resolve your dispute directly. As a United Kingdom data subject, you also have the right to lodge a complaint with the Information Commissioner’s Office. https://ico.org.uk/

How to Contact Us

If you have any questions about this privacy policy, or your dealings with our Services, please contact us via mail or e-mail as set forth below:

North and South America, Canada, Asia Pacific and the Caribbean:

eDriving LLC
211 Bayberry Drive, Suites 1 D, E & F
Cape May Court House, New Jersey, 08210.
UNITED STATES OF AMERICA
Email: Privacy@eDriving.com

UK, Africa, and the Middle East:

eDriving Limited
Pennine Business Park
9 Longbow Close
Huddersfield, HD2 1GQ, England, UNITED KINGDOM
Email: Privacy@eDriving.com

Europe

eDriving Europe Limited
1F North Valley Business Centre
Mallow Road
Cork
T23 KH58
Ireland
Email: Privacy@eDriving.com

Revisions to Our Privacy Policy

We may change this privacy policy from time to time. The published date is shown at the top of this page. Any new policy will not apply retroactively. We will use information in accordance with the privacy policy under which the information was collected.