Privacy Policy

1. OVERVIEW 

”We” are Matrix Telematics Limited. 

This policy sets out the personal data processing practices and your related rights in relation to the personal data collected about you when you use our Telematics and Camera Service, the Telematics and Camera device we provide you and associated Trak+ App (together, our "Services"). 

We have developed a Telematics and Camera Service comprised of certain software applications which allow the Customer to monitor and interact with their Telematics and Camera device. In order to provide the Telematics and Camera Service we make software applications available to subscribers via the Trak+ App. 

We take your privacy very seriously. We ask that you read this privacy policy ("Policy") carefully as it contains important information about how we will use your personal data and how we will ensure we meet our legal obligations to you under the UK data protection rules (including associated guidance) (the "Data Protection Laws"). 

We are a processor of your information which means that we are responsible for looking after it. We will use your personal data fairly, lawfully and in a transparent manner, and in accordance with the Data Protection Laws. 

You are the controller of the data and as such you should be registered with the Information Commissioner’s Office (www.ico.org.uk). You will receive a specific membership number which you will need in order to conform with criteria set out by most Taxi Licensing Authorities. 

2. PERSONAL DATA WE MAY COLLECT ABOUT YOU 

2.1 Information that you provide 

We will obtain personal information about you (such as your name, email address, location data and telephone number) when you purchase a device, when you register with us to use our Services, install and use our Telematics and Camera device and access the Trak+ App. 

We will also obtain personal information about you when you use our Services, send us feedback, post material, contact us for any reason and by any medium, sign up to a service or receive notifications when you have switched on such service within the app, report a problem with the Trak+ App or otherwise communicate with us. 

A condition of you using our Services, and being granted access to our Trak+ App and the Telematics and Camera device, is that you will not share any information relating any other person than yourself within any communications or information you share with us, or include it within any information submitted to us. 

You must ensure that all personal data collected through our Service and Trak+ App relates directly to you as our customer and the personal data collected relates to you and your vehicle or property for which you are permitted to attach the Telematics and Camera device only. You must not share any information relating to any other person than yourself within any communications or information you share with us or include it within any information submitted to us.   

We will not ask you to provide us with any sensitive personal data. Sensitive personal data (or otherwise called special categories of personal data) means information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation or any information relating to criminal convictions or offences. 

We may retain a record of any contact you make with us. 

2.2 Information about you that we will collect 

Information from your purchase and use of our Telematics and Camera device. When you purchase our Telematics and Camera device through our ecommerce website, we will collect information about you such as your name, address and contact details to provide you with the Telematics and Camera device. When you then use our Telematics and Camera device as part of our Services, we may periodically collect information related to GPS derived location data. As part of the provision of our Services, we use the Telematics and Camera device to identify the location of your vehicle on which the Telematics and Camera device is attached. 

Information from your use of our App 

We may also collect information about your device each time you use the Trak+ App. For example, we may collect information on the type of device that you are using and its unique device identifier (for example, IP Address, the IMEI number, the device’s mobile phone number, or the MAC address of the device’s wireless network interface), the type of browser that you are using, the operating system that you are using, network information and the time zone setting. 

Cookies 

We may monitor your use of our Trak+ App through the use of cookies and similar tracking devices. For example, we may monitor how many times you use the Trak+ App, which pages you go to and traffic data. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. For further information on our use of cookies, please see the sections on cookies below. For more information on cookies and how they work please visit www.allaboutcookies.org. 

3. HOW WE USE YOUR PERSONAL DATA 

The main purpose for which we use personal information relating to you is to provide you with access to the Trak+ App and receive our Telematics and Camera Services. 

We also use your personal data for the following purposes:  

  • to communicate with you and respond to requests and inquiries; 
  • to notify you of any changes to the Services that may affect you 
  • to create and administer accounts and log in access to our Trak+ App; 
  • for identification, and authentication purposes so you can use and access our Trak+ App and Services; 
  • for research, statistical analysis and behavioural analysis; 
  • to deliver functionality on the Trak+ App including customising future use for you; 
  • for service improvement, research and to contact you for surveys; 
  • to analyse, develop and improve the function and performance of the Trak+ App and the Services; 
  • to manage security and operation of the Trak+ App; 
  • to comply with applicable laws and regulations in the operation of our business; 

3.2 WHAT IS OUR LAWFUL BASIS FOR USING YOUR INFORMATION 

Performance of a Contract. You may have directly entered into a contract with us for the provision of certain services. For us to fulfil our obligations under such contract (e.g. to provide you with the information around your Telematics and Camera device), we will need to collect, process and share (as further detailed below) your personal information, to register and communicate with you. 

Legitimate Interest. We need to collect and process your personal data for our legitimate interests to enable us to provide you access to the Telematics and Camera device, provide you with our Services and access to the Trak+ App as required, while providing our services. 

We also use your personal data as set out in this privacy policy for our legitimate interests to enable us:  

  • to administer your account and use of our Services 
  • for research, statistical analysis and behavioural analysis; 
  • to deliver functionality on the Trak+ App 
  • for service improvement, research and to contact you for surveys; 
  • to analyse, develop and improve the function and performance of the Trak+ App and our Services; 
  • to manage security and operation of the Trak+ App, our networks and systems; 

As indicated below, we may also pass your personal data to members of our group and other third parties and this is also for our legitimate business interests. 

We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the Data Protection Laws. As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that we have a legitimate business interest. 

Legitimate interest 

We have a legitimate interest in processing your information as: to grant you access to the Trak+ App and receive our Services. 

Necessity

We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as we process your personal data only so far as is necessary to achieve the purpose outlined in this Policy. 

Impact of processing

We consider that it is reasonable for us to process your personal data for the purposes of our legitimate interests outlined above as the processing of your personal data does not unreasonably intrude on your privacy. 

Consent 

We do not expect to process your personal data subject to consent, however where we do so we will inform you of the purpose of processing, obtain your consent, and where given you will have the right to withdraw your consent to processing at any time by contacting us on the contact details provided at the beginning of this privacy policy. 

Legal Duty 

We will also process your personal data, as necessary, to comply with applicable laws and regulations in the operation of our business. 

4. DISCLOSURE OF YOUR PERSONAL DATA 

 We may disclose your personal data to: 

  • a third party who acquires our business or acquires substantially all of our assets, in which case the personal data shall be one of the acquired assets; 
  • third parties who provide the installation services of the Telematics and Camera device; 
  • iRevolution Group who provide the claims management services to assist you through the process after an incident; 
  • our agents and service providers, in order to help us better manage, support or develop our organisation and comply with legal and regulatory obligations; 
  • law enforcement and regulatory agencies in connection with any investigation to help prevent unlawful activity or as otherwise required by applicable law. 

We use HubSpot as our marketing automation platform and you must acknowledge that the information you provide will be transferred to HubSpot for processing in accordance with their privacy policy and terms. 

4.1 Transfers outside of the European Economic Area 

The information which we collect about will not be transferred outside the United Kingdom ("UK") and/or the European Economic Area ("EEA"). If this changes and we transfer such data outside the UK / EEA this will only be for the purposes of providing our users with technical support and we will ensure that any such transfer shall be made in accordance with data protection laws and that the level of data protection will be at least as protective as that required in the United Kingdom/ European Economic Area. 

4.2 Keeping your data secure 

Ensuring the security of your information is an important part of our business. We take commercially reasonable and appropriate security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of data. 

While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not completely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet; any transmission is at your own risk.   

5. DATA RETENTION 

We may retain your personal data (such as contact details provided for account creation and log in purposes) for as long as you continue to use our Services, have an online account with us, and typically for up to six years after the termination of your account or registration with us, in order to enable us to deal with any issues or concerns you may have about our Services, and also to allow us to bring and defend legal proceedings, or for as long as is necessary to fulfil the purposes outlined above. We will only hold information related to GPS derived location data and Camera video footage for the duration of your use of our Services. 

We may however retain personal data for an additional period as is permitted or required under applicable laws, for legal, tax or regulatory reasons, for legitimate and lawful business purposes and for our own internal audit and record keeping purposes. 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We will only use personal data for a purpose that is materially different than the purpose for which it was collected where your explicit consent to the new purpose has been provided. Such consent will be obtained prior to further processing under the different purpose. 

6. YOUR RIGHTS 

You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below. You may contact us using the details at the beginning of this Policy to exercise any of these rights. 

In some instances, we may be unable to carry out your request, in which case we will write to you to explain why. 

1. You have the right to request access to your personal data 

You have the right to request confirmation that your personal data is being processed, access to your personal data (through us providing a copy) and other information about how we process your personal data. 

2. You have the right to ask us to rectify your personal data 

You have the right to request that we rectify your personal data if it is not accurate or not complete. 

3. You have the right to ask us to erase your personal data 

You have the right to ask us to erase or delete your personal data where there is no reason for us to continue to process your personal data. This right would apply if we no longer need to use your personal data to provide the debt management services to you, where you withdraw your consent for us to process special categories of your personal data, or where you object to the way we process your personal data (see right 6 below). 

4. You have the right to ask us to restrict or block the processing of your personal data 

You have the right to ask us to restrict or block the processing of your personal data that we hold about you. This right applies where you believe the personal data is not accurate, you would rather we block the processing of your personal data rather than erase your personal data, where we don't need to use your personal data for the purpose we collected it for but you may require it to establish, exercise or defend legal claims. 

5. You have the right to port your personal data 

You have the right to obtain and reuse your personal data from us to reuse for your own purposes across different services. This allows you to move personal data easily to another organisation, or to request us to do this for you. 

6. You have the right to object to our processing of your personal data 

You have the right to object to our processing of your personal data on the basis of our legitimate business interests, unless we are able to demonstrate that, on balance, our legitimate interests override your rights or we need to continue processing your personal data for the establishment, exercise or defence of legal claims. 

7. You have the right not to be subject to automated decisions 

You have the right to object to any automated decision making, including profiling, where the decision has a legal or significant impact on you. 

8. You have the right to withdraw your consent 

You have the right to withdraw your consent where we are relying on it to use your personal data. 

7. COMPLAINTS 

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handing of any request may by you, or would otherwise like to make a complaint, please contact our Data Protection Officer at saasoperations@matrixiq.com in the first instance using the details at the start of this Policy, so that they can do their very best to sort out the problem. You can also contact the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk. 

8. USE OF COOKIES 

8.1 What is a cookie? 

A cookie is a small text file which is placed onto your device when you access our App. We use cookies and other online tracking devices on our App for several purposes as described below. enable the App to remember choices you have previously made (for example language settings) where such devices are necessary to enable the functionality of the App. 

In some cases, we will need your consent in order to use cookies on the App. We obtain this through the pop up notice which appears when you navigate to the App. The exception is where the cookie is essential in order for us to provide you with a service you have requested (for example to enable you to log in to the App and enable you to view the telematics information, and for us to communicate with you). 

If you wish to remove cookies placed on your device by our App or stop our App placing further cookies on your device, you can do this at any time through your browser by following the instructions at www.allaboutcookies.org. 

8.2 What categories of cookies are used on the App? 

Strictly necessary cookies. 

These are cookies that are required for the operation of our App. They enable core functionality such as security, network management and accessibility. We do not require your consent to place these cookies. Nevertheless, you may be able to block these cookies yourself on your device/ browser, but restricting these cookies is likely to mean that our site will not work as you would expect and certain functionality may be inoperable. 

Non-essential cookies 

Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our App when they are using it. This helps us to improve the way we provide our Services, for example, by ensuring that users are finding what they are looking for easily. 

Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences. 

9. OUR CONTACT DETAILS 

In this privacy policy, the terms "we", "our", and "us" are used to refer to Matrix Telematics Limited. We welcome your feedback and questions. If you have any questions in relation to this policy or generally how your personal data is processed by us please contact saasoperations@matrixiq.com.  

10. CHANGES TO THIS PRIVACY POLICY 

We may change this Policy from time to time. You should check this Policy frequently to ensure you are aware of the most recent version that will apply each time you use our Services or our Trak+ App.