1. The Intangles website https://www.intangles.ai/ (the “Website”).
  2. Web-based automobile fleet management software called Inroute (the “Software”).
  3. The Intangles mobile app called Inroute (the “App”).
  4. The telematics device (the “Intangles Solution”).

Collectively, these are referred to as the “Platform”. The Platform allows our Users to monitor and manage their Vehicles remotely from anywhere in the world. Our Users use the Platform to make more informed decisions regarding their Vehicles.

We respect data privacy rights and are committed to protecting personal information collected on the Platform. This privacy policy (“Privacy Policy”) sets forth how we collect, use, store, process, transfer, share, and protect the information that identifies or can identify you on this Platform.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. By continuing to use the Platform and providing us with personal information, you consent to our use of your personal information in accordance with the terms of this Privacy Policy. If you do not agree to this Privacy Policy, you may withdraw your consent or alternatively choose not to provide your personal information on the Platform. To withdraw your consent, please email intouch@intangles.com.

If you are accessing the Platform on behalf of a third party, you represent that you have the authority to bind such third party to the terms and conditions of this Privacy Policy. In such an event, your use of the Platform shall refer to use by such third party. If you do not have such authority or do not agree to the terms of this Privacy Policy, then you should refrain from using the Platform.

This Privacy Policy is an electronic record in the form of an electronic contract and is compliant and construed in accordance with data protection laws of the jurisdictions where we have our presence.

1. DEFINITIONS

a) Personal Information shall mean and include information that directly, indirectly, or in connection with other information, allows for the identification or identifiability of a natural person. Personal Information includes but is not limited to name, identification number, residential address, email address, contact number, emergency contact number, blood group, driver name, driver’s driving license number, etc.

b) Non-personal Information shall mean and include information of the Vehicle Information, engine information, chassis number, technical specifications, servicing details, test results, etc.

c) “User(s)”, “you”, “your”, “Customer” shall mean and include individuals, business organizations, commercial establishments, and their permitted users who use the Platform or who may share Personal Information to that avail the services through the Platform.

d) “Vehicle” shall mean and include automobile vehicles that have installed the Intangles Solutions.

e) “Vehicle Information” shall mean and include information about the Vehicle such as the Vehicle registration number, Vehicle type, Vehicle’s performance, engine and diagnostic data, Vehicle GPS location, odometer readings.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect your Personal Information in the following cases:

a) Website: When you get in touch with us through our ‘contact us’ page on our Website or subscribe to our blogs/newsletters, you are required to provide us with information including but not limited to your full name, e-mail address, company’s name, resume, job application details, mobile number, etc.

b) Intangles Solution: When you purchase, use, or install the Intangles Solution in your Vehicle, we may collect information including but not limited to the Vehicle owner’s name, email address, residential address, Vehicle Information, Vehicle registration number, Vehicle and driver location, Driver Details (driver name, driver’s driving license number or equivalent identification, contact number, emergency contact number), blood group, driver performance information, driver behavior monitoring, in-vehicle CCTV footage, etc.

c) User Account: To use our Platform, you must set up an account (“User Account”) with us. To create the User Account, you will be required to provide Personal Information including but not limited to name, address, phone number, email address, unique username, corporate name, etc.

d) App: If you install or use our App, we may collect certain Personal Information from you including but not limited to your full name, email address, login ID, password, contact number, Driver Details (driver name, driver’s driving license number or equivalent identification, contact number, emergency contact number), blood group, driver performance information, driver behavior monitoring, in-vehicle CCTV footage, etc. We may also collect information about your device including but not limited to device name, model number, device type, IP address, operating system, device compatibility, etc.

e) Employees and Job Applications: If you work with us or you are a job applicant and apply for a job at Intangles (“Applicant”), we collect your Personal Information you provide to us. We may collect Personal Information about you including but not limited to your name, resume, phone number, and email address.

f) Social media accounts: We may also collect, store, and use your Personal Information when you:

  1. Access our social networking handles operated by us on Facebook, Twitter, and/or LinkedIn.
  2. Share our blogs through Facebook, Twitter, and/or Linkedin.
  3. Comment/provide feedback/testimonials on such social networking handles.

g) Payment Information: You may have an option to make purchases through our Platform and we may collect certain information including but not limited to full name and email address to process your request. You will be required to provide certain payment information directly to our payment processing partners, including but not limited to your name, credit/debit card/bank information. We do not access, store or collect your credit/debit card information or
payment related sensitive information.

3. ACCURACY OF INFORMATION:

User undertakes that they shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Information shared with us, whether of their own or any third party. In the event the User is sharing any Personal Information on behalf of a third person, the User represents and warrants that they have the necessary authority to share such Personal Information with the Company, obtained written consent from such third party, and the Company shall not be responsible for verifying the same. The User understands and acknowledges that such Personal Information shall be subject to the terms and conditions of this Privacy Policy.

4. WHAT DO WE DO WITH YOUR PERSONAL INFORMATION?

We use the Personal Information for the following purposes:

a) To inform you about our services and to respond to your request(s).

b) To provide you real-time updates including those of the Vehicle, Vehicle performance and health, Vehicle maintenance, Vehicle errors, etc.

c) To provide you real-time updates of the driver, driver and Vehicle location, performance, cases of overspeeding, unscheduled driving and stoppages, etc.

d) To provide services to our customers where we process Personal Information on behalf of customers.

e) For the creation or development of business intelligence or data analytics in relation to the services provided by us.

f) To improve the services on our Platform.

g) To process job applications (if you apply for a position with our organization).

h) To maintain and manage our Platform.

i) To manage our relationship with you.

j) For internal record keeping.

k) To comply with our legal or statutory obligations.

l) To enable your access to the Mobile App and Website.

m) To send you transactional messages.

5. COOKIES

A cookie is a small piece of data stored on your computer or mobile device by your web browser (“Cookie/s”). We use Cookies to identify the users who visit our Website. We use Cookies to enhance the performance and functionality of our Website and App. Without the Cookies, certain functions may become unavailable, or you would be required to log in every time you visit the Website or App. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access all the functions of our Website correctly or at all.

a) Types of Cookies Used

i. Permanent cookies – Permanent cookies help us recognize you as an existing user, making it easier for you to return to the website without signing in again. After signing in, the permanent cookies stay on your browser and will be read when you return to our sites. These cookies remain on your computer/device for a predefined period.

ii. Session cookies – Session cookies only last for as long as the session exists (they get erased when the user closes the browser).

As for the domain to which it belongs, there are two types:

i. First-party cookies: These cookies are set by the web server of the visited page and share the same domain.

ii. Third-party cookies: These cookies are placed by a third party on your device and may provide information to us and third parties about your usage of the website.

iii. Analytical Tools:

  • Google Analytics: We use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, which are text files stored on your computer and enable the analysis of your use of the website. The information generated by the cookies about your use of the website is usually transferred to a server of Google in the US and stored there. We do not control third-party cookies. You can prevent the data generated by the cookie and related to your use of the website from being sent to Google and processed by Google by visiting the following link: Google Analytics Opt-out.
  • Google Maps API: Google Maps API is a robust tool that can be used to create custom maps, searchable maps, check-in functions, display live data syncing with location, plan routes, or create mashups, just to name a few. Google Maps API may collect information from you and from your device for security purposes. Google Maps API collects information held in accordance with its Privacy Policy.
  • Mixpanel: Mixpanel is a business analytics service company. It tracks user interactions with web and mobile applications and provides tools for targeted communication with them. The data collected is used to build custom reports and measure user engagement and retention. Mixpanel collects information in accordance with their data privacy policy.
  • Hotjar: Hotjar is a powerful tool that reveals the online behavior and voice of your users. By combining both Analysis and Feedback tools, Hotjar gives you the “big picture” of how to improve your site’s user experience. Hotjar collects information in accordance with its Privacy Policy.

b) Use of Cookies

We use Personal Information captured through cookies to make your interaction with us faster and more secure. They may be used for the following purposes:

i. Preferences – Cookies allow the Website to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in. Remembering your preferences enables us to personalize and display advertisements and other content for you.

ii. Security/Optimization – Cookies allow us to maintain security by authenticating users, preventing fraudulent use of login credentials, and protecting user data from unauthorized parties. We may use certain types of cookies to allow us to block many types of attacks, such as attempts to steal content from the forms present on the website.

iii. Processing – Cookies enable the website to work efficiently. Based on such cookies, we are able to deliver services that a website visitor expects, like navigating around web pages or accessing secure areas of the website.

iv. Advertising – We use cookies to make advertising more engaging for our users. Some common applications of cookies are made to select advertising based on what’s relevant to you, improve reporting on campaign performance, and avoid showing ads you would have already seen. Cookies capture information about how you interact with the website, which includes the pages that you visit most.

v. Communication – We may use information collected via cookies to communicate with you, such as sending newsletters, seeking your opinion and feedback, and providing you with services and promotional materials.

vi. Analytics and Research – We may use cookies to better understand how people use our Offerings so that we can improve them.

c) Disabling Cookies

You can decide whether to accept or not to accept cookies. You can disable cookies by adjusting the settings on your browser (see your browser’s Help for how to do this). Disabling cookies may affect the functionality of our website.


6. ANONYMIZED DATA

We may anonymize and aggregate your Personal Information that we have collected (so that we can no longer identify you, directly or indirectly). We may use such anonymized information for purposes that include testing our IT systems, research, data analysis, improving our services, and developing new products and features. We may also share such anonymized and aggregated information with others.

7. WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?

We do not sell, rent, share, distribute, lease, or otherwise provide your Personal Information to third parties without your prior consent. However, there are circumstances where we may disclose your Personal Information:

i. Affiliates: We may provide your Personal Information to our affiliates to enable them to improve our services, provide feedback, and respond to their queries.

ii. Service Providers: We may share your Personal Information with service providers who work with us in connection with operating the Platform and/or providing the service. All such service providers are subject to stringent confidentiality restrictions consistent with this Privacy Policy.

iii. Merger or Acquisition: We may transfer your Personal Information if we are acquired by another entity or if we merge with another company or transfer a part of our business, including the Platform, to a third party. Any such third party or resultant entity that receives your Personal Information shall have the right to continue using your Personal Information in line with the purposes set out herein. In the event of such a sale or transfer, we may notify you.

iv. Legal and Regulatory Authorities: We may disclose your Personal Information to comply with our legal obligations, court orders, or requests by government authorities.

v. Security and Emergency Situations: We may also disclose Personal Information if we determine in good faith that disclosure is necessary to protect our rights, resolve legal conflicts, enforce our terms and conditions, investigate fraud, or protect our users.

8. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION?

We endeavor to only collect Personal Information that is necessary for the purposes indicated here and to retain it for no longer than is necessary for such purposes. The length of time Personal Information is retained and the criteria for determining that time are dependent on the nature of the Personal Information and the purpose for which it was provided or collected.

Subject to this section, we will try to delete your Personal Information upon reasonable written request for the same. Please note, however, that there might be latency in deleting Personal Information from our servers, and backed-up versions might exist even after deletion. For more information on where and how long your Personal Information is stored, and for more information on your rights of erasure and portability, please contact us at intouch@intangles.com.

9. OUR SECURITY MEASURES AND STORAGE FACILITIES

Our Platform employs a number of current technology security measures to protect the security of Personal Information. We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. All Personal Information is accessible only to authorized personnel. Although we provide appropriate firewalls and protections, we cannot warrant the security of Personal Information transmitted as these systems are not hack-proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we will take necessary measures to mitigate such events. You are required to be careful to avoid “phishing” scams, where someone may send you an email that looks like it is from us asking for your personal information.

10. YOUR RIGHTS

Depending on the nature of your request, we may ask you to complete a Personal Information request form or seek certain details to verify the request. In certain cases, we may charge a fee for this service, but we will inform you at the time. All requests for Personal Information will be handled within a reasonable period of time. If you would like to exercise ANY of your rights, please contact us at intouch@intangles.com.

In accordance with applicable law, you have the following rights in respect of your Personal Information:

a) Right of access: You have the right to obtain access to your Personal Information. This includes the right to obtain:

(i) confirmation of whether we are processing your Personal Information;

(ii) information about the categories of personal information we are processing, the purposes for which we process your Personal Information, and information on how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your Personal Information and if those recipients are located in third countries; and

(iv) a copy of the Personal Information we hold about you.

b) Right of portability: You have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use or to request the transfer of your Personal Information to another person.

c) Right to rectification: You have the right to rectification of any inaccurate or incomplete Personal Information we hold about you without undue delay. However, you understand and agree that we do not hold any responsibility towards the accuracy or authenticity of the user information which you have submitted or we have collected through your use of our service.

11. CHOICE AND OPT-OUT

We may send you communications, including but not limited to: (a) notices about your use of our Platform and services, including those concerning violations of use, (b) updates, (c) promotional information regarding our Platform, and (d) newsletters.

You may opt out of receiving promotional emails and newsletters from us by following the unsubscribe instructions provided in those emails. Alternatively, you can opt out at any time by emailing intouch@intangles.com with your specific request.

12. INFORMATION FOR AUSTRALIAN USERS

  • Applicability of Privacy Act: We are bound by the Privacy Act 1988 (“Privacy Act”) and the Australian Privacy Principles (APPs) for Personal Information provided by Users from Australia on our Platform.
  • Transfer of your Personal Information outside of Australia: We will ensure that the transfer of Personal Information is in accordance with the requirements of the Privacy Act.
  • Inquiries and Complaints: If you have any concerns or complaints about our privacy practices or this Privacy Policy, you may contact us at intouch@intangles.com. We will respond to your concerns/complaints within a reasonable period of time. If you are not satisfied with how your complaint has been addressed, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC) at GPO Box 5218, Sydney NSW 2001.

13. INFORMATION FOR CANADA USERS

  • Applicability of PIPEDA: This Privacy Policy is subject to the Canada Personal Information Protection and Electronic Documents Act (the “PIPEDA”).
  • Personal Information: Personal Information provided by Users of the Platform is information about an identifiable individual. Personal Information does not include business names and business contact information used in a commercial context.
  • Accuracy of Personal Information: We will make reasonable efforts to ensure that Personal Information collected by us or on our behalf is accurate and complete.
  • Withdrawal of Consent: In accordance with PIPEDA, upon reasonable notice given by you about the withdrawal of your consent given with respect to the collection, use, or disclosure of Personal Information, we will inform you of the likely consequences of withdrawing this consent and will cease (and cause any of our data intermediaries and agents to cease) collecting, using, or disclosing the Personal Information unless it is required or authorized under applicable laws.
  • Transfer of your Personal Information outside of Canada: We will ensure that the transfer of Personal Information is in accordance with the requirements of PIPEDA.
  • Inquiries: If you have any concerns, inquiries, or complaints related to your Personal Information, please contact us at intouch@intangles.com.

14. CALIFORNIA RESIDENT RIGHTS

If you are a California resident, you have the rights outlined in this section. If you are a California resident and there are conflicts between this section and any other provision of this Policy, the portion that is more protective of your Personal Data shall control. If you have any questions about this section or whether any of the following applies to you, please write to us at intouch@intangles.com.

We do not sell, rent, distribute, lease, or otherwise provide your Personal Information to third parties without your prior consent.

Access: You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:

  • The categories of Personal Data that we have collected about you;
  • The categories of sources from which that Personal Data was collected;
  • The business or commercial purpose for collecting or selling your Personal Data;
  • The categories of third parties with whom we have shared your Personal Data; and
  • The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient.

Deletion: You have the right to request that we delete the Personal Data that we have collected from you. Under the California Consumer Privacy Act of 2018 (“CCPA”), this right is subject to certain exceptions. For example, we may need to retain your Personal Data to provide you with the services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights: To exercise the rights described above, you must send us a request that meets the following criteria:

  1. The request must provide sufficient information to allow us to verify that you are the person about whom we have collected Personal Data. This may require you to send an email from the account in question or provide login credentials.
  2. The request must describe your request in sufficient detail to allow us to understand, evaluate, and respond to it.

Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within a reasonable time after receipt. You may submit a Valid Request by emailing us at intouch@intangles.com.

We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to do so, and we may request a copy of this written permission from your Authorized Agent when they make a request to exercise your rights on your behalf.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA: We will not discriminate against you for exercising your rights under the California Consumer Privacy Act (CCPA). We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.

15. INFORMATION FOR EU AND UK INDIVIDUALS

Residents of the European Union (EU) and the United Kingdom (UK) should note that this Privacy Policy has been updated in accordance with the requirements of the EU General Data Protection Regulation (GDPR) and the UK General Data Protection Regulation (UK GDPR), the United Kingdom Data Protection Act 2018, the Privacy and Electronic Communications Regulations, and any regulation superseding any of the foregoing (collectively referred to as the “UK Privacy Laws”). As per the provisions of the GDPR and UK Privacy Laws, we shall be considered the Controllers of the Personal Information collected as a result of your use/access of the Platform.

Legal Basis (for EU residents and UK residents): We will not process your Personal Information without a lawful basis to do so. We will process your Personal Information only on the legal bases of consent, contract, or on the basis of our legitimate interests, provided that such interests are not overridden by your privacy rights and interests.

Transfer of your Personal Information across borders (for EU Residents): The Personal Information we collect from EU and UK residents might be processed outside the EU and the UK at a secure center located in India. We collect and transfer Personal Information outside the EU and the UK in accordance with the provisions of the GDPR and the UK Privacy Laws. If you have questions, please contact intouch@intangles.com.

Your Rights (For EU and UK Residents): As an individual residing in the EU or the UK, you have the following rights:

  1. Right to Access: You have the right to access your Personal Data being processed by us and understand the purpose, recipients to whom your Personal Data has been disclosed, and the envisaged period of retention of Personal Information.
  2. Right to Rectification/Modification: You have the right to rectify any inaccuracy in your Personal Data obtained and being processed by us.
  3. Right to Erasure: You have the right to have your Personal Data erased on grounds of completion of purpose, withdrawal of consent, unlawful processing of data, pursuant to exercise of the right to restrict processing, or any statutory requirement.
  4. Right to Restriction of Processing: You have the right to require us to restrict the processing of your Personal Data on grounds where you contest the accuracy of the Personal Data being processed, and in cases of unlawful processing, among others.
  5. Right to Data Portability: You have the right to receive your Personal Data collected and being processed by us in a structured, commonly used, and machine-readable format. You also have the right to transmit such Personal Data to another controller without any hindrance from us when the processing of Personal Data is based on consent and where processing is carried out by automated means.
  6. Right to Object to Processing: You have the right to object to the processing of your Personal Data on grounds related to your particular situation, especially when such Personal Data is being processed for direct marketing purposes.
  7. Right to Lodge Complaints: If you believe that we have violated or presented a potential risk to your right to privacy, you have the right to lodge a complaint with the supervisory authority under the applicable regulations.
  8. Right to Withdraw Consent: You may withdraw your consent at any time by writing to us.

UK residents have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance. We may need to request specific information from you to help us confirm your identity or also contact you for further information in relation to your request. If you would like to exercise ANY of these rights, please contact intouch@intangles.com.

Governing Laws: For EU and UK residents, this Privacy Policy shall be governed respectively by the provisions of the GDPR and UK Privacy Laws.

16. INFORMATION FOR TURKISH USERS

  • Applicability of Privacy Laws: We are bound by the Law on Protection of Personal Data No. 6698 (Turkish LPPD) for Personal Information provided by Users from Turkey on our Platform.
  • Transfer of your Personal Information outside of Turkey: We will ensure that the transfer of Personal Information is as per the requirements of Turkish LPPD.
  • Inquiries and Complaints: If you have any concerns or complaints about our privacy practices or this Privacy Policy, you may contact us at intouch@intangles.com. We will respond to your concerns/complaints within a reasonable period. If you are not satisfied with how your complaint has been addressed, you have the right to lodge a complaint with the Turkish Data Protection Authority (KVKK) if you think we have not used your personal information in accordance with the Turkish LPPD.

17. CHILDREN’S PRIVACY

This Platform is not meant for any person below the age of 16 years. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you become aware that a child has provided us with Personal Information, please contact us at the below-mentioned email address. If we become aware that we have collected Personal Information from anyone under the age of 16, we take the necessary steps to remove such Personal Information from our servers without any undue delay.

18. LINKS TO OTHER WEBSITES/APPLICATIONS

Our Platform may contain links to other third-party websites/applications of your interest. This Privacy Policy does not apply to those websites. We do not have any control over such other websites/applications, and you will be accessing these websites/applications at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/applications, and those are not governed by this Privacy Policy. We strongly recommend that you exercise caution and look at the privacy policy applicable to such websites/applications.

We use certain third-party services, such as Mixpanel, Google Maps, and Hotjar, to provide our service. As a result of the use of such services, certain additional information may be collected and processed by Mixpanel, Inc., Google LLC, and Hotjar Ltd. in accordance with their own respective policies relating to privacy, which may be accessed from their respective websites, including the following URLs:

  • Mixpanel – To access the applicable privacy policy click here;
  • Google Maps – To access the applicable privacy policy click here;
  • Hotjar – To access the applicable privacy policy click here;

19. GOVERNING LAWS AND DISPUTES

This Privacy Policy shall be construed and governed by the laws of India without regard to principles of conflict of laws. Any dispute arising between you and us shall be submitted to arbitration to be conducted in Pune, India, in the English language, in accordance with the rules of Arbitration and Conciliation Act of 1996, by a sole arbitrator, who shall be appointed by us, and the award made in pursuance thereof shall be binding on you and us. Subject to the arbitration provisions, you agree that the courts in Pune, India, shall have exclusive jurisdiction over such disputes.

20. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time, and you are encouraged to check this Privacy Policy on a regular basis to be aware of the changes made to it.

21. CONTACT US AND GRIEVANCE REDRESSAL

If you have any questions, concerns, or grievances regarding this Privacy Policy, you can reach out to our appointed Data Protection Officer/Grievance officer, Neil Unadkat, via email at dpo@intangles.com.

Address: 9th floor (office 904-907), Orville Business Port, Terminal 2 Airport Road, Viman Nagar, Pune, Maharashtra, India-411014