Updated: June 23rd, 2019
Personal Information That We Collect
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:
1.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. In addition, for users of any Service that requires individual payments such as Mentor for FamiliesSM, we collect information for payment, including: your name, credit, debit, or other card number, card expiration date, card CVV code, billing address, and zip/post code.
2. Personal Information That We Automatically Collect:
Other Automatically Collected Device Information: When you install and activate the Mentor by eDrivingSM 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.
- 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 or which other applications are running.
- Information about the device: The App collects webpage views, IP address, browser type, and operating system information.
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: Credit card numbers are used only for processing 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’ movements, 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.
Third-Party Service Providers: Your personal information will only be shared with your Consent, for example: your name, email address, location 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 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.
Employers: If you are driving as part of your employment and are using Mentor by eDrivingSM 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.
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.
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, rules 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 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: We keep your account information for as long as your account is in existence. 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 a signed request, including your email address, the minor’s email address, birth date, and first name using the contact details below.
Links to Other Sites
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 (including GT Affiliated entities) 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.
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.
How to Contact Us
North and South America, Canada, Asia Pacific and the Caribbean:
Attn: Privacy Officer
211 Bayberry Drive, Suites 1 D, E & F
Cape May Court House, New Jersey, 08210. UNITED STATES OF AMERICA
UK, Europe, Africa, and the Middle East:
Attn: Privacy Officer
Pennine Business Park
9 Longbow Close
Huddersfield, HD2 1GQ, England, UNITED KINGDOM
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, United Kingdom 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. Below is a chart indicating the legal basis we rely in processing personal information.
|Purpose of Processing||Legal Basis|
|To Provide the Services
To Respond to Your Inquiries
To Enforce our Terms and Agreements
To Provide Customer Support
To Ensure the Security of the Service.
Share with eDriving affiliated entities
Share with Our Service Providers, Business Partners and Others
|Processing is based on our contract obligations or to take steps at the request of the individual prior to entering into a contract.|
|To Personalize Your Experience on the Services
For Research and Development Purposes
Sharing Due to Corporate Reorganization
|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 Ensure the Security of the Service.
Share Due to Law Enforcement Requests
To Enforce our Terms and Agreements
|Processing is necessary for compliance with our legal obligations, the public interest, or in your vital interests.|
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, 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 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, indicating “EEA Individual Rights Request” in the subject line of the email.
Right to Lodge Complaint. If you believe we have infringed or violated your privacy rights, please contact us at Privacy@eDriving.com so that we may resolve your dispute directly. If you are a European data subject with an unresolved complaint or dispute with eDriving, arising under the requirements of the Privacy Shield Framework, we agree to refer your complaint under the Framework to an independent dispute resolution mechanism. See Privacy Shield Policy for more information. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.
WHAT IS A COOKIE?
“Cookies” are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
WHAT COOKIES DO WE USE?
- Cookies are used to remember the user who is currently logged into the system.
- Cookies that evenly distribute web traffic across our website infrastructure.
- Cookies which tell us statistical information about our website visitors, e.g. popular pages, what browsers are used, and how much time is spent on each page.
MORE DETAIL ON COOKIES WE USE
Here is a list of the cookies we use, their names and what we use them for.
|Website Infrastructure||NSC_Qspe-Bqq-IUUQT||Evenly Distribute Website Traffic||This is a first party cookie, and is set immediately upon visiting the website. This cookie stores a random set of characters, and is used to evenly distribute web traffic across the virtualriskmanager website infrastructure.|
|To allow logging in||These cookie stores random numeric entries unique to the user currently logged into the Virtual Risk Manager. These are to enable the user to remain logged in. These are first party cookies, and are set when logging into the site.|
|Google Analytics||__utma||Identifying Unique Visitors||Each unique browser that visits a page on this site is provided with a unique ID via the __utma cookie. In this way, subsequent visits to the website via the same browser are recorded as belonging to the same (unique) visitor. This is a first party cookie, and is set immediately upon visiting the website.||Google Analytics Opt-out Browser Add-on|
|Determining Visitor Session||Two cookies are used by Google Analytics to determine a session; a session is a period of interaction between a visitor’s browser and a particular website. These are first party cookies, and are set immediately upon visiting the website.|
|__utmz||Tracking Traffic Sources &; Navigation||When you reach this site via a search engine result, a direct link, or an ad that links to the website, Google Analytics stores the type of referral information in a cookie. This is a first party cookie, and is set immediately upon visiting the website.|
HOW DO I DELETE THE COOKIES?
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit https://ico.org.uk/for-the-public/online/cookies/