Privacy Policy

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.

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 as instructed by your organization, in your capacity as an employee of a company who is providing you access to one or more of eDriving’s Services:

When you install and activate the Mentor by eDrivingSM application (the “App”) on your mobile device, it collects the following information.

1. 1. Your driving activity: The App uses your mobile device’s internal sensors (e.g., its gyroscope and motion tracker) to collect information regarding your driving activity, including acceleration, hard braking, cornering, and speeding.
   2. 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. You can remove personal or passenger trips from scoring for trip-based users.  
   3. Emergency Response Services: If you subscribe (or your organization subscribes you) to the Mentor Emergency Response Services Automatic Collision Detection or Personal SOS, powered by Sfara Bosch, your personal SOS profile and location will be shared with our partner, Bosch Mobility if a collision is detected or  you activate the SOS. Please refer to your individual privacy notice for specific details of this processing and how/when your information will be shared. 
   4. Phone usage and activity: The App measures general phone activity, including if a call is received or made, or the phone is touched or handled while driving. The App does NOT record any individually identifying usage or activity information, such as key strokes, content of phone calls, messages, contacts, photographs (unless uploaded by the driver using Driver Event Reporting or Driver Vehicle Inspection features) 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.

If your organization has opted to use Mentor My Work Team Circles, your circle automatically includes all team members, as directed by the Data Controller. Only your manager will see your scores. If you wish to start 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 ‘on’.

Rewards is a feature that allows you to earn badges and collect points for safe driving which you can redeem for tangible rewards. Rewards are redeemed in the app and no personal information is shared with our rewards partner.

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. Data is hosted in the EU or the US, depending on your location, in line with our overall privacy strategy. 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.

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 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/Defender User Circle: 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 Defender 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 or when instructed by the Data Controller, in accordance with applicable laws, 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 may be provided with limited access to 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.
Partners and Vendors we currently share personal information with are:

1. Behind the Wheel in person training partner: identification data, name of referrer;
2. Emergency Response Services (Mentor App only): identification data, SOS profile and geolocation.

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.

The following types of personal information may be collected directly from you, or the person or organization that subscribed you to the Service

1. Identification Data such as a name, online identifier, email address, account name, driver’s license number, or other similar identifiers.
2. Commercial Transaction Information such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories.
3. Vehicle Data such as vehicle registration and licensure, vehicle identification number, vehicle pictures of damage..
4. Technical Data such as 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. Only strictly necessary cookies are enabled by default. You can manage all other cookie settings, using our cookie settings.
5. Usage Data such as how you use our website or service.
6. Employment related information: the name of your employer or organization, business location.
7. Geolocation Data: Mentor Business and Defender Apps – your location latitude and longitude.
8. Inference Data: the derivation of information, data, assumptions, or conclusions from facts, evidence, or another source of information or data

Your Rights
Under state privacy law, you have the right to:

Request access/disclosure of what personal information the business collects, uses or discloses. Request correction of your information if you believe the information is incorrect.
Request deletion of personal information collected or maintained by us.
Request to opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data (see statement below), or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects.
Request to obtain a copy of the personal data we hold for you.
Non-discrimination. Your exercise of privacy rights conferred under your state privacy law will not result in discriminatory treatment.
Request to limit the use and disclosure of your sensitive personal information – eDriving only uses personal and sensitive personal information for the purpose of performing our contract with you and providing you with the service. This means that eDriving is not required to provide a link to limit the use of your personal information** to the purposes required for the service.
**The purposes identified in Civil Code section 1798.121, subdivision (a), for which a business may use or disclose sensitive personal information without being required to offer consumers a right to limit are as follows. A business that only uses or discloses sensitive personal information for these purposes, provided that the use or disclosure is reasonably necessary and proportionate for those purposes, is not required to post a Notice of Right to Limit or provide a method for submitting a request to limit.

Under certain circumstances, you also have the right to: Use an authorized agent. California law allows you to use an authorized agent to make a request under CCPA/CPRA on your behalf. You must provide us with written documentation that the agent is authorized to act on your behalf or a power of attorney. We may also contact you directly to verify your identity.

SALE OF PERSONAL INFORMATION: We do not sell information that identifies a person to other businesses. We have not sold personal information within the last twelve months.

To exercise your rights , contact us via our secure request form or by email at: Privacy@eDriving.com and indicate in the subject line “Request to Exercise Privacy Rights”.

Appeals Process: If you make a request to exercise your rights and you are not satisfied with the final response or decision, you have the right to appeal. To appeal the decision or response to your request, you can do so by writing to us at any of the addresses shown below, or by email to legal@edriving.com using the subject title “Rights Request Appeal”. Please note that when eDriving processes on behalf of a Data Controller, we will refer your request to them for instructions

Nevada residents have the right to opt out of the sale of their personally identifiable information. While we do not sell personal information, Nevada customers have the legal right to opt out even if their information is not currently being sold. Use the secure request form to make a request.

This section only applies to individuals using or accessing our Services while located in the European Union, European Economic Area and/or Switzerland (collectively, the “Designated Countries”) or 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 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. When we process on behalf of a Data Controller, the legal basis is detailed in your individual privacy notice so please refer to that for specific details. Where we process as a Data Controller, 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.

1. To Provide the Services directly to you, or as directed by the Data Controller
2. To Respond to Your Inquiries
3. To Provide Customer Support
4. To Ensure the Security of the Service
5. To Enforce our Terms and Agreements
6. Share with eDriving affiliated entities
7. Share with Our Service Providers, Business Partners

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.

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

Processing is necessary for compliance with our legal obligations.

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

Marketing. We will only contact individuals located in the Designated Countries or 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.

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 or UK 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. 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/

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

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.