ROAD READY® privacy notice

Protecting your information is important to us. The following guidelines set forth our general privacy practices and principles that apply to information we collect through our website located at https://www.rrtelematics.com and https://services.roadreadysystem.com (the “Website”) and the Road Ready fleet tracking dashboard and telematics platform (together with the Website, the “Service”), which is owned or operated by Truck-Lite Co., LLC, or companies related by common ownership or control (collectively, “we,” “us,” or “our”). We use this privacy notice to clearly disclose to you our privacy practices in a manner that is easy to understand.  If there is something you do not understand about our privacy practices, please feel free to contact us at [email protected].

This privacy notice does not apply to products or services provided, or information obtained, other than through the Service.  We do not intentionally collect information from persons under the age of 18, so please do not use this Service if you are under the age of 18. We may change this notice from time to time so please check back often.  If we significantly change our collection, use, or disclosure practices, we will try to send you a notice via email if you have provided us with an email address.  Please keep in mind that some of the services mentioned specifically in this notice may not be available on the site at this time.  This Privacy Notice is effective as of March 25, 2022.

Our Service is used to provide you a user platform to access information connected to our trailer telematics services and to provide information about the products and services we offer.

What information do we collect from you?

As part of providing products and services to you, we may collect information, including personal information, about you or your business.  Personal information is data that can be used to identify you.  The information includes but is not limited to:

• Name
• Email address
• Phone number
• Financial information
• Other information you disclose when you ask us a question about our Website or our products and services.
• Technical information about your use of our site including IP address, device identifier, and viewing information.
• Geo-location information telling us from where you are accessing the Service.
• Information relating to fleet vehicles that you or your company includes in our dashboards and platform.

How do we collect information from you?

Direct Collection

We collect much of the information listed above directly from you when you submit it on our Website.  This includes information you share on the Talk to Us page of our Website.

Third Parties.

We may receive information about you from other sources, including from our Customers. If you provide information to one of our Customers, your data is also subject to their Privacy Policy.

Indirect Collection – Cookies and Other Technology

As part of offering and providing customizable and personalized services, we use cookies and other online tracking technologies to store and sometimes track information about you.  We may use these technologies to:

• Provide you with personalized content based on your use of our site
• Enable you to more easily use our site by remembering and using contact information, purchasing information, and registration information
• Evaluate, monitor and analyze the use of our site and its traffic patterns to help improve our site and services
• Assist us with ad reporting functions such as to learn which ads are bringing users to our Website

The types of technologies we use include:

Cookies.  A cookie is a small amount of data that is sent to your browser from a Web server and stored on your computer’s hard drive.  Cookies enable us to identify your browser as a unique user.  Cookies may involve the transmission of information from us to you and from you to us.  Cookies may also be used by another party on our behalf to transfer information to us in accordance with their privacy statement.  Some cookies are “persistent cookies.”  They are used by us each time you access our Website.  Other cookies are called “session cookies.”  Session cookies are used only during a specific browsing session.  We may use a session cookie, for example, to remember that you have already navigated through a particular menu, or that you have entered in age information for a portion of a site that is restricted by age.  We may also use “analytics cookies” that allow web analytics services to recognize your browser or device and, for example, identify whether you have visited our Website before, what you have previously viewed or clicked on, and how you found us.  This information is provided anonymously for statistical analysis only.  Analytics cookies are usually persistent cookies.

Web Beacons.  We also employ a software technology called a clear GIF (Graphics Interchange Format), also known as a pixel tag or Web beacon.  A clear GIF is a line of code that we place on our Websites or in e-mails which allows us to analyze our advertising and the general usage patterns of visitors to our Websites.  These help us better manage content on our site by informing us what content or promotions are effective.  Unless you consent, we do not collect personally identifiable information from you through the use of web beacons.  You may not disable Web beacons.

Log Files.  Like most standard website servers, we use log files.  Log files track Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks.  We utilize this information to analyze trends, administer the site, prevent fraud, track website navigation in the aggregate, and gather broad demographic information for aggregate use.

What choices do you have about the collection of information about you?

Direct Collection.  If you do not want to share your information, you can choose not to participate in a particular service or activity.

Cookies.  You may disable browser cookies in your browser or set your browser to warn you when a cookie is being sent.  You may lose some features or functionality when you disable cookies.  Remember, also, that disabling cookies is browser specific.  If you log on using Google Chrome, you must also disable cookies in Safari if you use that browser at a different time.

Web Beacons.  It is not possible to disable Web beacons.

Log Files.  It is not possible to disable log files.

Marketing Emails.  To ensure that you will not receive recurring marketing or other information from us unless you choose to, we will provide you with simple instructions on each marketing email from us for you to let us know that you have chosen to stop receiving such emails from us.

Do Not Track.  Do Not Track (DNT) is a privacy preference that users can set in their web browsers.  While the United States Federal Trade Commission has endorsed DNT, our Website does not support DNT codes.

Google Analytics.  You may opt-out of Google Analytics collection by downloading the browser plugin “Google Analytics Opt-out Browser Add-on” here.

How do we use your information?

We may use your personal information to:

• Answer questions you may have about our products and services
• Notify you of other products or services available from us and our affiliates
• Personalize online content so that is applies to you and your interests
• Provide you with advertising targeted on your interests
• Make our products, services, and Website better
• Compile, analyze and do research on our users’ demographics and behavior
• Detect, investigate and prevent activities that may violate our policies or be illegal

We use, and share user location data only to provide and improve our service and to provide you with information about services that may be appropriate for your location.

Who is collecting your information?

When you are on our Service and are asked for personal information, you are sharing that information with us and our affiliates and service providers.  Although we generally operate the Service and collect the information, we may engage third party service providers to assist us in that collection.

Other websites to which we link may collect personally identifiable information about you when you visit those sites.  The information practices of other websites linked to our websites are not covered by this privacy notice.

With whom do we share your information?

We will not disclose any of your personally identifiable information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described below.  These are some of the ways that your information may be disclosed:

Service Providers

We occasionally hire other companies to provide limited services on our behalf, including website development and operation, answering customer questions about products or services, sending postal mail or email, analyzing website use, processing payments, providing investor information and processing data.  We will only provide those companies the information they need to deliver the service, and they are contractually prohibited from using that information for any other reason.

Data in the Aggregate

We may disclose “blinded” aggregated data and user statistics to prospective partners and other third parties.  Blinded data is data that does not identify an individual person.

Other

We also may disclose your information in special cases.  For example, when we believe that we must disclose information to identify, contact or bring legal action against someone who may be violating our Terms of Use, or may be causing injury to or interference with our rights or property, other website users or customers and their information, or anyone else who may be harmed by such activities.  We may disclose, access or monitor your personal information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service and improve our products and services and our information security.

As we continue to develop our business, we may buy or sell businesses or assets.  In such transactions, confidential customer information generally is one of the transferred business assets.  In the event of a transaction involving the sale of some or all of our businesses, customer and site visitor information may be one of the transferred assets and may be disclosed in connection with negotiations relating to a proposed transaction.  In such case, the transferred information may become subject to a different privacy notice.

How can I control my personal information?

You may contact us at [email protected] if you wish to view, edit, or delete your personal information from our database, and we will use commercially reasonable efforts to accommodate your request. 

If you believe that any inaccurate or inappropriate information has been obtained or provided to others through your use of this Website, you should contact a representative at [INSERT E-MAIL ADDRESS OR HYPERLINK TO THE CONTACT US FORM]

How do we protect your information?

We take reasonable measures to protect all information that is provided to us. Because information sent through the Internet travels from computer to computer throughout the world, when you give us information, that information may be sent electronically to servers outside of the country where you originally entered the information.  Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure.  Except as specifically stated, this site does not use security encryption measures.  Information that you disclose by use of this site (as with any site that is non-secure), by posting a message or using e-mail, potentially could be collected and used by others.  This may result in unsolicited messages from third parties or use of such information by third parties for their own purposes, legal or illegal.  As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or from our services, and you do so at your own risk.  Once we receive your transmission, we use commercially reasonable efforts to ensure its security on our systems.

Your California Privacy Rights.

This Privacy Notice for California Residents supplements the information contained above in our general privacy policy and applies solely to all visitors, users, households and others who reside in the State of California.

 

Your Rights

The California Consumer Privacy Act (“CCPA”) grants State of California residents the following rights, to:

 

• Know what personal information is being collected about them;
• Know whether their personal information is sold or disclosed and to whom;
• Say no to the sale of their personal information;
• Access their personal information;
• Have their personal information deleted (subject to certain exceptions); and
• Have the right to equal service and price, even if they exercise their privacy rights under this law.

Categories of Information Collected

 

We collect, use and disclose personal information for various business purposes described below. While collection practices vary depending on the business purpose, we collect and have collected the following categories of information over the past 12 months, as defined in the CCPA:

 

Identifiers (such as name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or similar identifiers)
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared (see also “With whom do we share your information?” section above)
We collect the above identifiers when you contact us.  However, we typically do not collect social security numbers, driver’s license numbers, or passport numbers from customers.	Directly from individuals submitting information to us; certain information is automatically collected from website visitors; advertising and marketing partners; business report providers.	Performing services,; providing customer service; verifying customer information; providing advertising and marketing services; analytics; auditing related to customer interactions and transactions; security detection and enhancement; enhancing products and services.	Marketing and advertising service providers and vendors; security services; analytics service providers; providers of customer service assistance, government entities and law enforcement, if necessary; affiliates.
Financial, medical, or health information (such as insurance policy number, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information)
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared
We collect financial information.  We do not collect medical or health information from customers.	Directly from individuals submitting information to us	Performing services; performing support services; accounting purposes.	Payment and charge back processors, financial reporting companies, or address verification providers; providers of customer service assistance; government entities and law enforcement, if necessary; affiliates.
Characteristics of protected classifications under California or federal law (such as such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status)
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared
Not collected.	N/A	N/A	N/A
Commercial information (such as transaction history, products or services purchased, obtained, or considered, records of personal property, or other purchasing or consuming histories or tendencies)
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared
Commercial information relating to purchases is collected including serial proof of purchase and date of purchase.	Directly from individuals submitting information to us; web browsers and devices.	Performing services; maintaining account information; verifying customer information; providing advertising and marketing services; analytics; auditing related to customer interactions and transactions; security detection and enhancement; enhancing services and products.	Payment processors’ marketing and advertising service providers and vendors; analytics service providers; government entities and law enforcement, if necessary; affiliates.
Biometric information (physiological, biological or behavioral characteristics, including images, voice recordings, keystroke patterns)
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared
Not collected.	N/A	N/A	N/A
Internet or other electronic network activity information (such as browsing history, search history, and information regarding an interaction with a website, application, or advertisement.
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared
We collect electronic identifiers such as IP address, log files, viewing information, cookies, website browsing and interaction activity, and other device or browser identifiers.	Web browsers and devices.	Performing services; providing customer service; verifying customer information; providing advertising and marketing services; analytics; auditing related to customer interactions; security detection and enhancement; enhancing products and services.	Marketing and advertising service providers and vendors; security services; suppliers; analytics service providers; government entities and law enforcement, if necessary; employee-related service providers, affiliates.
Geolocation
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared
We collect location information for your device.  It is collected anonymously in a form that does not personally identify you.	Web browsers and devices.	Verifying customer information; fraud detection, security detection and enhancement; enhancing products and services.	Marketing and advertising service providers and vendors; security services.
Audio, electronic, visual, thermal, olfactory, or similar information
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared
Not collected.	N/A	N/A	N/A
Professional and employment-related information
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared
We collect employment-related information regarding your position and employment status.	Directly from individuals submitting information to us.	Performing services,; providing customer service; verifying customer information; analytics; auditing related to customer interactions and transactions; fraud detection; security detection and enhancement; enhancing products and services.	Security services; analytics service providers; providers of customer service assistance, government entities and law enforcement, if necessary; affiliates.
Educational information
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared
Not collected.	N/A	N/A	N/A
Inferences drawn from any information identified above (such as to create a profile about preferences, characteristics, rends, predispositions, behavior, or attitudes)
Collected now or in the preceding 12 months?	Categories of Sources	Business or commercial purpose for which it will be used	Categories of third parties with whom personal information is shared
We collect and analyzes preferences, behavior, and trends to create a user profile and provide product and service suggestions to improve online customer experiences.	Analytics conducted internally and by service providers.	Performing services to improve the customer experience; customer service; verifying customer information; auditing related customer and employee interactions; analytics; security detection and enhancement; product and service enhancement.	Marketing and advertising service providers and vendors; security services; suppliers; affiliates.

 

Exceptions to our Disclosure Limitations

 

We also may disclose your information in special cases related to our legal obligations and to protect from the misuse of our website. We may share your personal information in regard to legal proceedings if stemming from a violation of our Terms of Use and Sale or causing injury to us, our property, our website, our clients or others. We may disclose visitor information when subpoenaed, if ordered or otherwise required by a court of law, arbitrator, or other similar proceeding, for government investigations, with government agencies if required by law, and when we otherwise believe in good faith that any applicable law requires it.

 

How We Retain and Store Your Personal Information

 

We retain your personal information for as long as necessary to fulfill the purpose(s) for which we collected it and to comply with applicable laws.  We use reasonable security precautions to protect your information while in storage.

 

Requests to Know

 

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

 

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Requests to Delete

 

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 including the business to business exception description described below. 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:

 

1. Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise performing our contract with you. This includes fulfilling a warranty request.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug online services to identify and repair errors that impair existing intended functionality.
4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
6. Comply with a legal obligation.
7. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

How to Submit a Request to Know or a Request to Delete

 

To request this information please submit a verifiable consumer request to us by emailing us at [email protected] and asking for a Consumer Request Form

 

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, email us at [email protected] and we will provide you with a form to make a designated agent request. Please do not send us any sensitive personal information using email. Email transmissions are not secure.

 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

 

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. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

We will try to respond to your request within forty-five (45) days of when we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. 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, specifically by electronic mail communication.

 

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.

 

We do not process privacy requests sent to us using third-party services.  This is because such services often request that we click on hyperlinks which we will not do for data security reasons.  These services are also susceptible to spoofing and other phishing attacks.  One of our highest priorities is to treat your information safely and securely.  If you live in a state that permits you to make a privacy request using a third-party agent, please have them contact us using the information above and we will take steps to identify them and ensure that they are your agent.

 

An amendment to the CCPA provides an exemption to the Right to Know and Right to Delete for personal information between a business and a person who is acting as an employee, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government where the information is used in the context of a business transaction.  This exemption is currently set to expire on January 1, 2023.  Until that date, we will not respond to requests to know or delete that meet this exemption.

 

How to Submit an Opt-Out Request

 

We do not sell your personal information to third parties for money or other consideration.  If we change that practice in the future, we will add a mechanism to enable you to opt-out of such sharing.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

 

Your Nevada Privacy Rights

Opt-Out Requests

Nevada law (SB 220), permits customers in Nevada to opt-out of the sale of certain kinds of personal information. A sale under Nevada law is the transfer of this personal information to third parties for monetary consideration so these third parties can then re-sell or license the sold information. We do not sell your personal information to third parties as defined in Nevada law. If you are a Nevada resident and wish to opt-out of the sale of your personal information should we change our practices in the future, you must send a request by e-mail at [INSERT EMAIL].  Make sure to state that you are a Nevada resident.

Who do you contact with questions or concerns about our Privacy Notice?

If you need further assistance, please send an e-mail with your questions or comments to [email protected].