- The Intangles website https://www.intangles.ai/ (the “Website”).
- Web-based automobile fleet management software called Inroute (the “Software”).
- The Intangles mobile app called Inroute (the “App”).
- 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.
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:
- Access our social networking handles operated by us on Facebook, Twitter, and/or LinkedIn.
- Share our blogs through Facebook, Twitter, and/or Linkedin.
- 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:
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.
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:
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.
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.
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.
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 firstname.lastname@example.org.
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 email@example.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 firstname.lastname@example.org 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.
13. INFORMATION FOR CANADA USERS
- 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 email@example.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 firstname.lastname@example.org.
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:
- 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.
- 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 email@example.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
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 firstname.lastname@example.org.
Your Rights (For EU and UK Residents): As an individual residing in the EU or the UK, you have the following rights:
- 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.
- Right to Rectification/Modification: You have the right to rectify any inaccuracy in your Personal Data obtained and being processed by us.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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 email@example.com.
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.
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
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:
19. GOVERNING LAWS AND DISPUTES
20. CHANGES TO THIS POLICY
21. CONTACT US AND GRIEVANCE REDRESSAL
Address: 9th floor (office 904-907), Orville Business Port, Terminal 2 Airport Road, Viman Nagar, Pune, Maharashtra, India-411014