Effective: September 24, 2020
Last Updated: March 22, 2022
We take your privacy seriously. This Openroad Mobile App Privacy Policy (“Privacy Policy” or “Policy”) informs you of important information about how Cambridge Mobile Telematics ("CMT" "Company,” “we,” “us” or “our”) collect and process information and protect your privacy. This policy describes:
This policy applies only to information we collect in this App, in email, text, and other electronic communications sent through or in connection with this App.
This Policy DOES NOT apply to information that:
Our websites and other apps, and other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Please read this Policy carefully. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this Privacy Policy. This Policy may change from time to time (see UPDATES TO THIS PRIVACY POLICY). Your continued use of this App after we revise this Policy means you accept those changes, so please check the Policy periodically for updates.
We are committed to complying with the Children’s Online Privacy Protection Act (COPPA) and the California Consumer Privacy Act (CCPA). Our mobile apps are not intended for children under the age of 16 and we do not knowingly collect personal information form children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us as provided below in HOW TO CONTACT US.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see YOUR CALIFORNIA PRIVACY RIGHTS for more information.
When we use the term, “Personal Data,” we mean information or data that directly or indirectly identifies, describes, relates to or is reasonably capable of being associated with or can reasonably link to a particular individual, consumer or household.
We offer a service through the App that aids in detecting vehicle crashes and contacting emergency services. We also enable App users to request roadside assistance via a tool called Blink. When we use the term “Service(s)” we mean, collectively, the services and information that we provide through the App; and our marketing and business development activities, including any social media properties we create, and emails that we send (“Marketing Activities”); and not any third-party services.
When we use the term, “Subscriber(s)” we mean individuals who download, purchase, and/or use the App.
HOW WE COLLECT YOUR PERSONAL DATA
We may collect your Personal Data through different means, when you:
TYPES OF PERSONAL DATA WE COLLECT
We may collect the following types of Personal Data:
Types of Information You May Provide to Us:
If you submit any Personal Data to us relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy. By submitting Personal Data, you grant CMT the right to transmit, monitor, retrieve, store and use your information in connection with the operation of the App.
Types of Information We Collect Through Technology: When you use our App, the App may gather information as follows:
Location Information. This App collects real-time information about the location of your device. We collect your location information through your device IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. We collect and maintain location data to provide you the features and functionality of the Services. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the app’s access to your location data. Please see YOUR PERSONAL DATA CHOICES below. Note, however, that opting out of the App’s collection of location information will disable its location-based features, and as a result, you may not be able to use our Services.
Driving Event Data. We collect sensory, audio and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass, and possibly Bluetooth, in order to calculate and detect crashes and other driving events. Your mobile device provider may also generate motion classifications which we may access such as whether the device has classified you as walking, running, cycling, etc. This information is referred to as “Motion and Fitness” data (descriptions may vary according to device and platform). If you want to opt-out of the collection of your sensory and motion, please adjust your settings in your mobile device to limit the app’s access to your sensory and motion data. Please see YOUR PERSONAL DATA CHOICES below.
COOKIES NOTICE
The technologies we use for automatic information collection may include:
If you do not want us to collect this information do not download the App or delete it from your device. Or, you may opt out at any time as provided below in YOUR PERSONAL DATA CHOICES.
We do not track our customers over time and across third party websites to provide targeted advertising and therefore we do not respond to Do Not Track signals from your browser at this time. However, some third parties that provide services or content for our App may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific site.
HOW AND WHY WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information, to:
We may also offer the following services:
The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:
We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us and please see HOW TO CONTACT US.
We may periodically send you relevant alerts and newsletters by text, e-mail or push notifications. To help improve our Marketing Activities, we often receive a confirmation when you open an e-mail or click on a link included in one of these emails, if your computer supports such capabilities. Instructions on how to unsubscribe from these alerts and newsletters are included in each e-mail.
We do not monitor or profile visitors to our App or collect, in any automated manner, any special categories of sensitive Personal Data about you. No automated decision-making, including profiling, is used when processing your Personal Data. We may use your driving behavior to predictively or reactively tune our crash predictions for purposes of providing the Services.
DATA SECURITY
We use reasonable organizational, technical and administrative measures to maintain the privacy and security of your Personal Data within our organization. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using TLS technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We are not responsible for any outcome if you circumvent any privacy settings or security measures. You are responsible for choosing a password of appropriate strength, not sharing or reusing passwords used on other websites or apps and keeping your password confidential. CMT employees will never ask for your password.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk.
Please note that email is considered a non encrypted (and therefore non-secure) form of communication, and it can be accessed and viewed by others without your knowledge and permission. For that reason, to protect your privacy, please do not use email to communicate information that you consider confidential. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below. We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
RETENTION OF PERSONAL DATA
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy and in order to provide you the Service(s), and to improve our products and/or services. We will also retain your information to comply with our legal obligations, to conduct audits, resolve disputes, and enforce our agreements.
FINANCIAL INFORMATION
If applicable, CMT may use a third-party payment processor to process any online payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information will be submitted directly to the third-party payment processor.
YOUR PERSONAL DATA CHOICES
You have choices in how your Personal Data is used and shared. You have the right to:
• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You can choose whether or not to allow your device to collect information through tracking technologies. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or NOT function properly.
• Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location. There are 3 ways you can disable location:
• Promotion by the Company. If you do not want us to use your email address to promote our own or third parties’ products or services, you can opt-out by sending us an email at security@cmtelematics.com. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or un-checking the relevant boxes.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website http://optout.networkadvertising.org/?c=1.
California residents may have additional personal information rights and choices. Please see YOUR CALIFORNIA PRIVACY RIGHTS for more information.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You may send us an email at security@cmtelematics.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Certain Exceptions to Deletion Request Rights: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Choice and Opt-Out:
Exercising Access, Data Portability and Deletion Rights: To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at security@cmtelematics.com.
Verification of Your Identity: Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability twice within a 12-month period. You must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
WITHDRAWAL OF YOUR CONSENT
Where you have provided consent to process personal information, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. You may do this by contacting us as set forth in the "How to Contact Us" section below.
RESPONSE TIMING AND FORMAT
We endeavor to respond to a verifiable consumer request within thirty (30) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
YOUR CALIFORNIA PRIVACY RIGHTS
As of January 1, 2020, under the California Consumer Privacy Act (CCPA), California Residents have the right to request the following information from CMT by emailing us at security@cmtelematics.com and CMT will provide the following information to you upon verification of your identity:
You may opt out of any marketing by us and from the disclosure of your Personal Data to third parties.
Personal Information Sales Opt-Out And Opt-In Rights: If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing us at security@cmtelematics.com.
Non-Discrimination: If you elect to exercise any of your rights under CCPA, CMT will not discriminate against you for exercising any of your CCPA rights. Unless otherwise permitted by the CCPA, we will not: deny you goods or services, charge you a different price or rate for our goods or services, or provide you a different level or quality of goods or services because you exercised such rights. Under the current definition of CCPA, CMT does not sell your Personal Data.
In addition, please check the following sections of this Privacy Policy: TYPES OF PERSONAL DATA WE COLLECT, HOW AND WHY WE USE YOUR INFORMATION, and HOW WE SHARE AND DISCLOSE PERSONAL DATA.
RESIDENTS OF THE EUROPEAN ECONOMIC AREA
Your personal information will be treated in a secure and confidential manner in compliance with all applicable laws and regulations, including the European General Data Protection Regulation (“GDPR”). Depending on the context in which personal information is provided, CMT may be the data processor (“processor”) or data controller (“controller”) of your personal information. In most instances, CMT is a controller of personal information that you submit to us directly through the App. The Data Subject owns the data submitted to the Service. If the Subscriber requests that CMT remove the personal information, we will respond to the request within 30 days.
If you have any questions or concerns regarding this Privacy Policy or our privacy practices, including the processing of your personal information, if you would like to exercise your data rights under applicable laws, or if you believe your privacy rights have been violated, please contact us as provided in the section HOW TO CONTACT US below.
LINKS TO OTHER SITES
Occasionally we may provide links to other sites for your convenience and information. These sites operate independently from our Apps and are not under our control. These sites may have their own privacy notices or terms of use, which you should review if you visit any sites linked through our Apps. We are not responsible for the content or use of these unrelated sites.
UPDATES TO THIS PRIVACY POLICY
CMT may change its Privacy Policy from time to time, and at CMT's sole discretion. CMT encourages visitors to frequently check this page for any changes to its Privacy Policy.
HOW TO CONTACT US
If you have any queries, questions or concerns about this Privacy Policy or our Personal Data handling practices, please contact us at security@cmtelematics.com or write to us at Cambridge Mobile Telematics, 314 Main Street, Suite 1200, Cambridge, MA 02142, United States.
