Here’s some of the information we collect:
Account Information includes your name, telephone number, e-mail address, service-related details such as payment data, security codes, service history and other information like that.
Network Performance & Usage Information tells us how you use our network, our products and our services, and how well our equipment and network is performing.
Location Information tells us where your wireless device is located, as well as your ZIP-code.
Here are the basic ways we collect it. To:
We collect it for how you use our products and services.
We obtain information from other sources, like other service providers.
Here are just some of the ways we use it. To:
Provide services and improve your customer experience.
Send you bills for your services.
Respond to your questions.
Address network integrity and security issues.
Do research and analysis to maintain, protect, develop and improve our network and services.
Let you know about service updates, content, offers and promotions that may be of interest to you.
Improve entertainment options.
Deliver Relevant Advertising.
Create External Marketing & Analytics Reports.
Assist in the prevention and investigation of illegal activities and violations of our Terms of Service or Acceptable Use Policies.
Some examples of who we share your Personal Information with:
Across FLEETMODE companies to give you the best customer experience and to help you get everything we have to offer.
With other companies that perform services on our behalf only as needed for them to perform those services. We require them to protect your information consistent with our Policy.
With other companies and entities, to:
Respond to 911 requests and other emergencies or exigencies.
Comply with court orders and other legal process.
Assist with identity verification, and preventing fraud and identity theft
Enforce our agreements and property rights
Obtain payment for products and services including the transfer or sale of delinquent accounts to third parties for collection.
Details on Personal and Anonymous & Aggregate Information.
What is Personal Information? Information that identifies or reasonably can be used to identify you as an individual.
What is Anonymous? This is information that doesn’t identify you as an individual and can’t reasonably be used to identify you specifically.
What is Aggregate? We take a whole bunch of people’s data and combine it into anonymous groups or categories.
How we use this information? We use and share this information in many ways including research, analysis, retail marketing and Relevant Advertising. This data is also included in External Marketing & Analytics Reports.
Our privacy committments
We don’t sell your Personal Information to anyone for any purpose. Period.
We keep your Personal Information in our business records while you are a customer, or until it is no longer needed for business, tax, or legal purposes.
We will keep your information safe using encryption or other appropriate security controls.
We want you to know that we don’t knowingly collect personally identifying information from anyone under the age of 13 unless we first obtain permission from the child’s parent or legal guardian.
We understand that everyone thinks that privacy policies are long, complicated, and difficult to understand. So we’re going to try to make this as simple as possible.
Let’s start with what we mean when we say:
Aggregate Information: Information that we combine into anonymous groups of customers or users. One way to think of it is in terms of a survey or opinion poll. Aggregate information would tell you that 80 percent of the people voted for a candidate, but not who actually voted. These groups are large enough to reasonably prevent individuals from being identified. Anonymous Information: Information that doesn’t directly identify you as an individual and can’t reasonably be used to identify an individual customer or user. Customer: Anyone who purchases or uses our products or services. When a customer purchases retail products or services for use by others, like a family account, those family members also are customers. Mobile Application, Application or “App”: A software application that runs on smartphones, tablet computers or other mobile devices and that allows users to access a variety of services and information. Personal Information: Information that directly identifies or reasonably can be used to figure out the identity of a customer or user, such as your name, phone number and e-mail address. Personal Information does not include published listing information. Relevant Advertising: Uses aggregate information about groups of people (like age, ethnicity, income range, where those groups live and work, and their interests) to develop advertising that is more likely to be useful to that group. It does not use individual data about what a specific person might like. “Online behavioral advertising” is one type of relevant advertising. It uses interest categories based on the websites visited by groups of people to deliver advertising online. User: Anyone who visits our websites or uses our mobile applications. Website: And other terms like “Internet site,” “site” and “web page” all mean the same thing, namely any page or location on the Internet, no matter what device (cell phone, tablet, laptop, PC, etc.) or protocol (http, WAP, ftp or other) is used to access the page or location.
QUESTIONS ABOUT THE SCOPE OF THIS POLICY
What about my family members and other users of my FLEETMODE account? Does this Policy apply to them? Yes. You’re responsible for making sure all family members or other users under your account understand and agree to this Policy. Get everyone together and talk about it. Or, send it by e-mail to make sure they’re on board. Hang it on the fridge. Up to you, just share it!
When is information not covered by this Policy? Any time you give information to companies other than FLEETMODE. Some examples are:
If you use public forums – such as social networking services, Internet bulletin boards, chat rooms, or blogs – the information is publicly available, and we cannot prevent distribution and use of that information by other parties.
Information about your location, usage and the numbers you dial when you’re out and about and roaming on the network of another company
When we license our brand to other companies for their use in marketing and selling certain non-FLEETMODE products and services, information you give those companies is not covered by this Policy.
Can my information be covered by this policy and other privacy policies at the same time? Yes, that can happen. For example: Sometimes we will provide a service with other companies. In that case your information may be subject to this Policy and that of the other companies. If you connect to a Wi-Fi service through another network, such as one provided in a hotel, airport or other venue, any information collected from your use of that network could be subject to either the FLEETMODE policy or the venue policy, and sometimes both. We think it’s a great idea to take a look at the privacy policies of any companies you do business with to learn how they use your information.
QUESTIONS ABOUT THE INFORMATION WE COLLECT, HOW WE COLLECT IT AND HOW WE USE IT
What information do we collect? We may collect different types of information based on your use of our products and services and on our business relationship with you.
Contact Information that allows us to communicate with you. We get this information when you order or register for our services. This would include information like your name, address, telephone number and e-mail address.
Billing Information related to your financial relationship with us, such as the services we provide to you, the telephone numbers you call and text, your payment history, your credit history, your credit card numbers, Social Security number, security codes and your service history.
Technical & Usage Information related to the services we provide to you, including information about how you use the network, services, products or websites. Some examples include:
Equipment Information that identifies your equipment on the network, such as equipment type, device IDs, device status, serial numbers, settings, configuration and software.
Network Performance & Usage Information about the operation of the equipment, services and applications you use on the network. Examples of this might include wireless device location, the number of text messages sent and received, voice minutes used, bandwidth used, and resources you use when uploading, downloading or streaming data to and from the Internet.
Location Information includes your ZIP-code and street address, as well as the whereabouts of your wireless device. Location information is generated when your device communicates with cell towers, Wi-Fi routers or access points and/or with other technologies, including the satellites that comprise the Global Positioning System.
How Do You Collect Information? In three basic ways:
You Give It To Us when you make a purchase or set up an account with us.
We May Obtain Information from Outside Sources like credit reports, marketing mailing lists, and commercially available geographic and demographic information.
How Do You Use My Information? We use your information to improve your experience and to make our business stronger. Some examples include:
Providing and managing your services, responding to your questions and addressing problems.
Delivering customized content, or advertising, such as personalized offers for products and services that may be of interest to you.
Communicating service updates, offers and promotions
Protecting network integrity and security, ensuring quality control, optimizing capacity and preventing misuse.
Network enhancement planning, engineering and technical support.
Conducting research and analysis for maintaining, protecting and developing our network and our services.
Preventing illegal activities, suspected fraud, and potential threats to our network and our customers’ networks.
Investigating violations of our Terms of Service, Acceptable Use Policies, or other service conditions or restrictions.
Protecting the safety of any person.
Do you use the information I store using one of your cloud services? We only use it to provide you with that service, unless we first get your permission to use it for something different.
QUESTIONS ABOUT INFORMATION SHARING
Do you share my Personal Information internally? Yes. Our products and services are developed, managed, marketed and sold by a variety of FLEETMODE companies. Sharing this information helps us offer you the high quality, seamless and innovative range of products you have come to expect from us. If one of our subsidiaries does not operate under the FLEETMODE brand, information sharing with that subsidiary is handled as though it is a non-FLEETMODE company.
Do you share my Personal Information with other companies for them to market to me? We will only share your Personal Information with other companies for them to use for the marketing of their own products and services when we have your consent.
Are there any other times when you might provide my Personal Information to other companies or entities? Yes. We share your Personal Information with companies that perform services for us, like processing your bill. Because we take our responsibility to safeguard your Personal Information seriously, we do not allow those companies to use it for any purpose other than to perform those services, and we require them to protect it in a way consistent with this Policy. Companies that perform these services may be located outside the United States or the jurisdiction where you reside. If your Personal Information is shared with these companies, it could be accessible to government authorities according to the laws that govern those jurisdictions. There are also occasions when we provide Personal Information to other companies or other entities, such as government agencies, credit bureaus and collection agencies, without your consent. Some examples include sharing to:
Comply with court orders, subpoenas, lawful discovery requests and other legal or regulatory requirements, and to enforce our legal rights or defend against legal claims.
Obtain payment or make refunds for products and services that appear on your billing statements, including the transfer or sale of delinquent accounts or refund obligations to third parties for collection or payment.
Enforce our agreements and protect our rights or property.
Assist with identity verification and e-mail address validation.
Notify, respond or provide information (including location information) to a responsible governmental entity in emergency or exigent circumstances or in situations involving immediate danger of death or serious physical injury.
Notify the National Center for Missing and Exploited Children of information concerning child pornography of which we become aware through the provision of our services.
QUESTIONS ABOUT MY INFORMATION & ADVERTISING
Do you use my information to send me advertising? Yes. We may use information like the preferences you have expressed and interests you have demonstrated on our websites, through use of our products and services, to provide you with marketing information and advertisements for FLEETMODE products and services. Those ads may be delivered on our websites and mobile applications. This is called “first party” advertising. It is part of our service relationship and you are not able to opt-out from this type of advertising. We or our advertising partners may also use anonymous information gathered through cookies and similar technologies, as well as other anonymous and aggregate information that either of us may have to help us tailor the ads you see on non-FLEETMODE sites. For example, if you see an ad from us on a non-FLEETMODE driving-related website, you may later receive an ad for driving solutions delivered by us on a different website. This is called “online behavioral advertising,” which is a type of Relevant Advertising.
Do you use my information for other types of Relevant Advertising? Yes. We may also use information we get through your use of our products and services, from our advertising partners, and information like your age and gender to deliver Relevant Advertising that is not online behavioral advertising. We combine your anonymous information with that of other users into aggregate “audience segments.” These segments are based on particular interests and/or factual characteristics that everyone in that audience segment is likely to share. We might use that information to send you advertisements that are relevant to those interests or characteristics. We are careful to create Relevant Advertising with aggregate audience segments that are large enough that you can’t be identified individually.
Do you use the location of my device for advertising purposes? Yes. FLEETMODE uses information about the locations you visit in order to create combined wireless location interest characteristics that can be used to provide Relevant Advertising to you and others like you. Location characteristics are types of locations – like “movie theaters.” People who live in a particular geographic area (a city, ZIP-code or ZIP+ 4 code, for example) might appear to have a high interest in movies, thanks to collective information that shows wireless devices from that area are often located in the vicinity of movie theaters. We might create a “movies characteristic” for that area, and deliver movie ads to the people who live there. We may associate your wireless device with a particular geographic area, such as a city, ZIP-code, or ZIP + 4 code, based on your billing address or the cell towers you connect with most frequently. In addition to other privacy protections, the process we use to create our audience segment includes a requirement that the ZIP + 4 or other geographic area to which a wireless location is assigned must contain a minimum of 25 households. ZIP + 4 codes with less than 25 households are combined with other ZIP + 4 codes to satisfy this requirement.
What’s in it for me? Just like the name says, you get advertising that’s more relevant to your interests. For example, if a particular audience segment, like adults between the ages of 21 and 25 with a certain income range, has demonstrated a greater interest in movies than other segments, we might send them a movie ad for a movie geared toward young adults. This is just one way we deliver content that’s more relevant.
How do you use information about the programs I watch on U-verse TV to advertise to me? We combine information about the shows that our customers are watching with their common interests to help us figure out what types of advertising they might be interested in seeing. It sometimes works like this: We look at the group of people watching a particular show. We identify common characteristics within that group. We use those characteristics to identify and deliver advertising that might be most relevant to watchers of that TV show. We might also deliver that same advertising during shows that appear to have similar audiences.
Do I ever have a chance to tell you what I’m personally interested in? Yes. With some programs you can sign up to receive text-message offers from businesses that are near your current location and match the interests you’ve selected. You can change your mind at any time and stop participating in these programs. When we add new offers like FLEETMODE Internet Preferences we’ll let you know, so you can decide if you’d like to participate. For example, we may offer you free or discounted services in exchange for the use of your Personal Information for advertising and other similar purposes. We promise, before we use any of your Personal Information (including information we gather as an Internet service provider) for such purposes, we will always give you the opportunity to make an informed choice about whether to participate.
What information do you provide to advertisers? FLEETMODE may provide reports to advertisers and other business customers about the success of its advertising campaigns. Those reports contain aggregate information about the number of times a particular ad was viewed, when it was viewed, whether it was viewed on a TV, a mobile device or a computer, demographics associated with the viewing audience and other similar information. Your anonymous information will not be included in aggregate reports about the success of Relevant Advertising campaigns if you have opted-out of Relevant Advertising delivered by FLEETMODE.
QUESTIONS ABOUT LOCATION INFORMATION
What is location information? Exactly what it sounds like! It includes your ZIP-code and street address, as well as the whereabouts of your wireless device.
How is it used? We use it in all kinds of ways, here are some examples:
Location Based Services (LBS): Your device can be used to access a ton of services based on location. We offer these services via applications that have been pre-loaded or downloaded by you on your device. LBS also may be provided via text message or other functionality. We’ll give you prior notice and ask for your consent when your location is used or shared. The form of consent may vary, but will be appropriate for the type of FLEETMODE LBS you use.
LBS from other providers: With your consent (to us or the other company) we also may enable LBS from other companies by providing location information to their developers or location service providers.
We use it for Advertising.
How accurate is wireless location information? It depends on the technology we’re using. For example, we can locate your device based on the cell tower that’s serving you. The range could be up to 1,000 meters in any direction from the tower in urban areas, and up to 10,000 meters in rural areas. Wi-Fi networks provide more accurate location information, associating you with the place where the network is located – like a coffee shop – or to an area within or around that place. Services such as 411, 911, a “friend locator” application or a navigation/mapping application, require more precise information. So for those we develop a more precise estimate of location by associating the serving cell tower ID with other information, like the latitude and longitude of the tower, radio frequency parameters, GPS information and timing differences in radio signals. Depending on a variety of factors, those methods may estimate the location of your device to within 30 to 1000 meters.
Are you the only ones who can locate my wireless device? Other companies may also be able to locate your device. For example, your handset manufacturer and your operating system provider may be able to locate your device. If you download mobile applications, those apps may be able to obtain your location directly from your handset or the operating system. Mobile applications that give you access to your employer’s network may also give your employer the ability to locate your device. We urge you to review Policies of all providers.
QUESTIONS ABOUT AGGREGATE & ANONYMOUS INFORMATION
Where do you get anonymous information? Sometimes we’ll collect information about how you use our products using cookies and other similar technologies. This information doesn’t include your Personal Information and is considered anonymous. When we collect information that identifies you personally, we may anonymize it for certain purposes. We remove data fields (such as name, address and telephone number) that can reasonably be used to identify you. We also use a variety of statistical techniques and operational controls to anonymize data. Anonymizing information is one of the tools we use to protect your privacy.
Tell me more about aggregate information. Aggregate information is a form of anonymous information. We combine data that meet certain criteria into anonymous groups. For example, we might want to compare how customers in Beverly Hills, CA (or any city, county or ZIP-code) use their cell phones to how customers in Boulder, CO use their cell phones. In order to do that, we would combine customer data in each of the geographies into anonymous groups and look at all that aggregate data to understand how the two groups are different or similar.
Do you share anonymous or aggregate information? Yes, we may share this information with other companies and entities for specific uses, which may include:
Universities, laboratories, think tanks and other entities that conduct networking, social, behavioral, environmental and other types of scientific research, for the purpose of creating fundamental new knowledge.
Municipalities, government or other entities that may use this data for purposes such as municipal and transportation planning, and emergency and disaster response coordination.
We share this information in external reports like our External Marketing & Analytics Reports and Metric Reports.
QUESTIONS ABOUT EXTERNAL MARKETING & ANALYTICAL REPORTS
Tell me more about the External Marketing & Analytics Program. We use aggregate information to create External Marketing & Analytics Reports that we may sell to other companies for their own marketing, advertising or other similar uses. These reports may be a combination of information from wireless and Wi-Fi locations, U-verse, website browsing and mobile application usage and other information we have about you and other customers. You have a choice about whether your anonymous information is included in the reports that we sell or provide to other companies. Some examples of External Marketing & Analytics Reports include:
Reports for retail businesses that show the number of wireless devices in or near their store locations by time of day and day of the week, together with demographic characteristics or other information about the users (such as device type, age or gender) in those groups.
Reports that combine anonymous U-verse TV viewing behaviors with other aggregate information we may have about our subscribers to create reports that would help a TV network better understand the audiences that are viewing their programs, those that are not, how frequently they watch, when they watch and other similar information.
Reports for device manufacturers that combine information such as device type, make and model with demographic and regional location information to reflect the popularity of particular device types with various customer segments.
Do you provide companies with individual anonymous data as part of your External Marketing & Analytics Program? Yes. When we provide individual anonymous information to businesses, we require that they only use it to compile aggregate reports, and for no other purpose. We also require businesses to agree they will not attempt to identify any person using this information, and that they will handle it in a secure manner, consistent with this Policy.
Do you use my anonymous information in other types of external reports? Yes, we may use your anonymous information to provide Metrics Reports to our business customers and service suppliers. These reports are considered part of the underlying service and we do not sell them to other customers or suppliers.
Do you collect information about my children’s use? We do not knowingly collect personally identifying information from anyone under the age of 13 unless we first obtain permission from the child’s parent or legal guardian.
What happens when my child is using an account not registered to them? Internet and wireless devices and services purchased for family use may be used by children without our knowledge. When that happens, information collected may appear to us to be associated with the adult customer who subscribes to our services and will be treated as the adult’s information under this Policy.
What can I do to help better protect my child’s information? We encourage you to spend time online with your children, and to participate in and monitor their online activity.
QUESTIONS ABOUT DATA PROTECTION & SECURITY
Do we sell your Personal Information? No. We do not sell your Personal Information to anyone, for any purpose. Period.
How long do we keep your Personal Information? We keep your Personal Information as long as we need for business, tax or legal purposes. After that, we destroy it by making it unreadable or undecipherable.
What safeguards does FLEETMODE have in place? We’ve worked hard to protect your information. And we’ve established electronic and administrative safeguards designed to make the information we collect secure. Some examples of those safeguards include:
Maintaining and protecting the security of computer storage and network equipment, and our security procedures require employee user names and passwords to access sensitive data.
Applying encryption or other appropriate security controls to protect Personal Information when stored or transmitted by us.
Limiting access to Personal Information to only those with jobs requiring such access.
Requiring caller/online authentication before providing Account Information so that only you or someone who knows your Account Information will be able to access or change the information.
Although we strive to keep your Personal Information secure, no security measures are perfect, and we cannot guarantee that your Personal Information will never be disclosed in a manner inconsistent with this Policy (for example, as the result of unauthorized acts by third parties that violate the law or this Policy).
Will you notify me in case of a security breach? Laws and regulations guide us in how to give you notification when certain types of sensitive information are involved in a security breach. We will provide you with notice in accordance with these laws and regulations.
Can I review and correct my Personal Information? Yes. We are happy to help you review and correct the Personal Information we have associated with your account and billing records. Please contact us.
QUESTIONS ABOUT FUTURE CHANGES
What happens if there is a change in corporate ownership? Information about our customers and users, including Personal Information, may be shared and transferred as part of any merger, acquisition, sale of company assets or transition of service to another provider. This also applies in the unlikely event of an insolvency, bankruptcy or receivership in which customer and user records would be transferred to another entity as a result of such a proceeding.
YOUR CHOICES & CONTROLS
Do I have choices about receiving first party advertisements from FLEETMODE? Because first party advertising is part of the service you receive when you use our mobile applications, we don’t offer an opt-out for first party advertising.
You can also choose not to receive other types of marketing from FLEETMODE. We realize that unwanted marketing contacts can be a hassle and we’ve worked hard to meet the expectations of customers and potential customers who have expressed a desire to limit certain types of solicitation communications from us. E-Mail: Every marketing e-mail we send contains instructions and a link that will allow you to stop additional marketing e-mails for that product or service type. Text Messages: Opt-out of FLEETMODE marketing text message contacts by replying “stop” to any message. Federal Do Not Call: The FTC maintains a National Do Not Call Registry at donotcall.gov, and your state may maintain its own Do Not Call Registry.
Are there any other opt-out choices I should know about? We may use services provided by analytics companies to obtain information about website performance and how you use our mobile applications and other products and services.
HOW TO CONTACT US ABOUT THIS POLICY
E-mail us at firstname.lastname@example.org
You also have the option of filing a complaint with the FTC Bureau of Consumer Protection, using an online form, or by calling toll-free 877.FTC.HELP (877.328.4357; TTY: 866.653.4261). Other rights and remedies also may be available to you under federal or other applicable laws.