Privacy Policy

Last modified: 12/5/20

Introduction

Clue Insights Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website (our “Website”) or when otherwise using the Company’s apps, products and/or other services (collectively, the “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information. The Company’s Services include, without limitation, access to its proprietary fleet tracking and management software-as-a-service.

This policy applies to information we collect:

⦁ On this Website.

⦁ In email, text, and other electronic messages between you and this Website.

⦁ In performing our Services and providing access to the Company’s proprietary fleet management tool.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or Services. By accessing or using this Website and/or using our Services, you agree to this privacy policy and that your personal information may be disclosed, used, and processed by us in accordance with this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website and Services are not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website or Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website and Services, including information:

⦁ by which you may be personally identified, such as name, username, company name, and e-mail address (“personal information”);

⦁ that is about you but individually does not identify you; and/or

⦁ about your internet connection, the equipment you use to access our Website and usage details.

⦁ additional information such as photos, videos, files and contacts, in order to provide the Services

We collect this information:

⦁ Directly from you when you provide it to us.

⦁ Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, and other tracking mechanisms.

Information You Provide to Us.

The information we collect on or through our Website or Services may include:

⦁ Information that you provide by filling in forms on our Website. This includes information provided at the time of posting material on our public forums.

⦁ Records and copies of your correspondence (including email addresses), if you contact us.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

You may change your personal information by emailing us at [email protected].

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website or Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

⦁ Details of your visits to our Website or Services and other communication data and the resources that you access and use on the Website or Services.

⦁ Information about your computer and internet connection, including your IP address, geo-location, operating system, and browser type.

The information we collect helps us to improve our Website and Services and to deliver a better and more personalized service, including by enabling us to:

⦁ Estimate our audience size and usage patterns.

⦁ Store information about your preferences.

⦁ Speed up your searches.

⦁ Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). We may use cookies, flash cookies, local shared objects, web beacons, pixels, single pixel GIFs, clear GIFs, and/or other technologies along with your information to enhance and personalize your experience and gather information that helps us optimize our Services. You can choose to accept or decline some cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, it is important to remember that many of our Services may not function properly if your cookies are disabled.

Our Third Party Vendors or Third Party Services (as defined below) may use their own cookies and/or other third-party cookies together (subject to their own privacy policies) to (a) inform, optimize, and serve ads across the web based on your past visits to our Services and others and (b) report to us how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site. If and to the extent from time to time we use Double Click or another Google brand for ad serving, analytics, remarketing, retargeting, etc., you can set certain preferences and opt-outs using Google Ads Settings, and Google Analytics’ currently available opt-outs, found here https://www.google.com/ads/preferences/ and here https://adssettings.google.com/.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

⦁ To present our Website and its contents to you.

⦁ To provide, maintain, and/or customize the Services to its subscribing customers.

⦁ To provide you with information, products, or services that you request from us.

⦁ To fulfill any other purpose for which you provide it.

⦁ To allow you to participate in interactive features on our Website.

⦁ To send administrative or product marketing emails to you.

⦁ In any other way we may describe when you provide the information.

⦁ For any other purpose with your consent.

We may create anonymous data from your personal information, by excluding information that makes the data personally identifiable. The Company may use such anonymous data for any business purpose.

We do not collect and ask that you do not send us or disclose any sensitive personal data (e.g. data related to racial or ethnic origin, political opinions, health or biometric data, or criminal background). If you send us sensitive personal data, you consent to our processing and use of such data in accordance with this privacy policy.

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

⦁ To contractors, service providers, and other third parties we use to support our business.

⦁ To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

⦁ To fulfill the purpose for which you provide it.

⦁ For any other purpose disclosed by us when you provide the information.

⦁ With your consent.

We may also disclose your personal information:

⦁ To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

⦁ To enforce or apply our terms of use and protect the Company’s rights, privacy, and safety.

Your California Privacy Rights – California Consumer Privacy Act

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]

We may share your personal information with third parties and affiliated third parties (such as local, state and regional affiliates and affiliate alliances), but they do not share your name for their direct marketing purposes. As these third parties and this category of affiliated third parties are considered an unaffiliated party under California law, you may opt-out of our disclosure of personal information to third parties for their direct marketing purposes. To opt out, please contact us as described in the “How to Contact Us” Section below.

We will continue to provide your information to local, state and regional affiliates and affiliate alliances identified in your membership application or account for the purpose of processing your membership in such affiliate and affiliate alliance programs.

The California Consumer Privacy Act (CCPA), effective January 1, 2020, gives California consumers enhanced rights with respect to their personal information that is collected by businesses. First, California consumers may opt out of having their personal information sold to other persons or parties. Second, they have a right to know:

1. What specific pieces of information a business has about the consumer;

2. Categories of personal information it has collected about the consumer;

3. Categories of sources from which the personal information is collected;

4. Categories of personal information that the business sold or disclosed for a business purpose about the consumer;

5. Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and

6. The business or commercial purpose for collecting or selling personal information.

In addition, California consumers can request that the personal information a business has collected about them be deleted from the business’s systems and records.

Company may be considered a covered business under the CCPA as it collects and processes the personal information of California consumers. This Privacy Policy provides the required notices to California consumers. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the Act.

We do not rent or sell your personally identifiable information (such as name, address, telephone number and credit card information) to unaffiliated third parties for their marketing purposes. We may share your information with third parties to provide products and services you have requested, when we have your consent, or as described in this Privacy Policy.

To make a “request to know” or request to delete your personal information, send us an e-mail at [email protected] (Please put either “Request to Know” or “Request to Delete” in the subject heading of your email.) We will use commercially reasonable efforts to honor these requests whether or not you would qualify as a California consumer under the CCPA.

If and to the extent we are considered a covered business under the CCPA: We will confirm receipt of your request within 10 days along with a description of what steps we will take to verify and respond. We must provide the requested information or delete your personal information within 45 days of receipt of your request but can use an additional 45 days, but we must let you know the additional time is needed.

When contacting us, we may ask you to provide certain, limited personal information, such as your name, email address and/or account login ID and/or password, to verify your request and to match with our records and systems. This is also to protect against fraud. We will not retain this personal information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months.

Residents of other states may also have similar rights to request information about or delete their personal information. To inquire about exercising these rights, please contact us at [email protected].

Pursuant to California’s “Shine The Light law (California Civil Code § 1798.983), California residents are entitled, once a year and free of charge, to request the disclosure of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year, if any. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt out of this type of sharing. You may request this information by contacting us at [email protected] and indicate in the email subject line, “California Shine The Light Request.” Please include your mailing address, state of residence and email address with your request.

USA BASED SERVICES

Out Websites and Services are operated in the USA, designed for USA based users. We are not designed to accommodate users from other countries, and do not necessarily comply with laws other than this in the USA. If you are a non-USA based user, your use is at your risk, and Your personal information may be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. If you are a European resident, our legal basis for collecting and using your personal data or information is to do so with your consent; where we need the personal data or information for performance of a contract, or where the collection and use is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If we collected your personal data or information with your consent, you may withdraw your consent at any time if and to the extent permitted by applicable laws. Your personal information may be stored on servers in the United States and may also be stored or processed in other countries by our service providers, if and to the extent compliant with law. You understand and agree that We may collect, use, disclose, and otherwise process the information you provide as described in this Privacy Statement even if you are from an area outside the United States. Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the United States. We will retain your personal information for as long as it is needed to provide you with the Services, or to fulfill any legal or contractual obligations we may have, or as otherwise permitted herein and by law.

DO NOT TRACK DISCLOSURES (California & Europe)

Some web browsers incorporate a "Do Not Track" feature that signals to websites and Services that you visit that you do not want to have your online activity tracked. Each browser communicates "Do Not Track" signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and our Services, we do not respond to or honor "Do Not Track" signals at this time. As the technology and communication between browser and website improves, we may elect in our discretion to reevaluate the ability to honor "Do Not Track" signals and may make changes to our policy. You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. To learn more about the use of cookies or other technologies to deliver more relevant advertising and your choices about not having this information used by certain Service Providers (defined below), please click here. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

How Your Information may be used

Your information may be used for purposes that include, without limitation:

⦁ to operate and improve the Services available through us;

⦁ to personalize the content and advertisements provided to you (including to present offers to you on behalf of business partners and advertisers);

⦁ to fulfill your requests for tools, software, functionality, features and other products, and services;

⦁ to communicate with you and respond to your inquiries;

⦁ to conduct research about your use of our products; and

⦁ to help offer you other products, features or services that may be of interest.

We reserve the right to make full use of Usage Data. For example, we may use Usage Data to provide better service to Service visitors or end users, customize the Services based on your preferences, compile and analyze statistics and trends about the use of our Services and otherwise administer and improve our Services.

Sharing of Your Information

We do not rent or sell your personally identifiable information (such as name, address, telephone number and credit card information) to unaffiliated third parties for their marketing purposes. We may share your information with third parties to provide products and services you have requested, when we have your consent, or as described in this Privacy Policy.

We may share aggregated, non-personally identifiable information, publicly and with our partners like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our websites and/or other products or services.

The contents of your online communications, as well as other information about you as a user of our Services, may be accessed and disclosed under the following circumstances: in response to lawful governmental requests or legal process (for example, a court order, search warrant or subpoena), in other circumstances in which we have a good-faith belief that a crime has been or is being committed by a user of our Services, that an emergency exists that poses a threat to the safety of you or another person, when necessary to protect either our rights or our property or for us to render the service you have requested.

Many of our Services let you share information with others. Remember that when you share information publicly, others besides us have access to it, and it may be indexable by search engines, or copied, forwarded, saved or archived by others.

Our offerings may include features or functionalities provided by third parties (“Third Party Vendors”), or may integrate or interact with third-party products and services (including, without limitation, via APIs, plug ins, links, frames, embedding, or other interactions) (“Third Party Services”). For example, without limitation, we may use a third party for ad serving, retargeting, remarketing and/or for analytics, in which case such third party may have access to your data, subject to its policies. In the process of providing such functionalities within our services, your browser or other tools or technology may send certain information to the Third Party Provider and/or Third Party Services. The use of these third-party-provided features or functionalities is subject to their own privacy policies.

Business partners or other third parties may receive data about groups of our users, but, except as otherwise permitted herein, do not receive information that personally identifies you. We may use agents and contractors in order to help operate our Services. Their use of information is limited to these purposes, except as otherwise permitted herein.

In the event that ownership of us was to change as a result of a merger, acquisition, or transfer to another company, your information may be transferred. If such a transfer results in a material change in the use of your information, you will be provided notice (which may be via updates to this page) about your ability to decline to permit such a transfer.

Any personal information which we may collect via the Services may be stored and processed in our servers located in the United States or in any other country in which we, or our affiliates, subsidiaries or agents, maintain facilities. You consent to any such transfer of personal information outside your country of residence to any such location.

General Disclosure Policy. We reserve the right to disclose your personal information as described below. We reserve the right to disclose Usage Data without restriction.

Affiliated Entities. We reserve the right to provide your personal information and Usage Data to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we control or that control us.

Service Providers. We reserve the right to provide access to your personal information and Usage Data to our trusted service providers that assist us with the operation and maintenance of our sites and services. For example, we may contract with third parties to process payments, host our servers, provide security and provide production, fulfillment, optimization, analytics and reporting services. We will use commercially reasonable efforts to ensure that our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.

Successors. If we sell or otherwise transfer part or all of our business or assets to another organization, such as in the course of an acquisition, merger, bankruptcy or liquidation, we may transfer your personal information and Usage Data.

Legal Process, Enforcement and Security Notice. We reserve the right to disclose your personal information and Usage Data if we have a good-faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud or other illegal activity and (iii) to investigate, respond to, or enforce violations of our rights or the security of our sites and services.

When We Participate in a Joint Venture with Marketing Partners. We may participate with another company or individual for purposes of jointly promoting our products, services, promotions or contests or their products, services, promotions or contests. We reserve the right to disclose your personal information to them for purposes of (i) compensation, transaction processing, fulfillment and support, and (ii) for purposes of offering you other products, services, promotions and contests. These joint venture marketing partners may also contact you about other products, services, promotions or contests.

Display of Advertising

Your information may be used for the presentation of advertisements. We may use ad networks to customize and display advertising on our Services. We may share certain information about you as a user (such as age, zip code or other information we have collected or received) with certain ad network and service providers to help them deliver more relevant content and advertisements through their networks. We may from time to time work with other companies for certain services such as analytics or advertising, and you may be subject to their privacy policies as well, though you may opt out through them directly or contact us with questions.

Your Choices

You can review, correct, update, or delete the information you provide to us by contacting us at [email protected]. If you request that we delete your information, please note that your information may continue to reside in our backup systems, subject to this privacy policy.

From time to time, we may send you marketing information. You can opt out of these communications by clicking on the unsubscribe link at the bottom of each message or by contacting us at [email protected]. Please note that we are unable to opt you out of third party communications that you may have opted into. Please follow the opt out instructions on the applicable communications.

We will retain your information as long as required to provide the Services or as otherwise necessary to comply with applicable law, resolve disputes, and enforce our agreements.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. The date the privacy policy was last revised is identified at the top of the page.

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