The Services are directed solely to persons 13 years of age or older. We do not knowingly gather Data from visitors who are under 13. If we become aware that we have gathered Data from a person under 13, then we will attempt to delete such Data as soon as possible, subject to our obligations under applicable law. If you believe that we have gathered Data from a person under 13, please contact us at firstname.lastname@example.org
INFORMATION WE COLLECT AND HOW WE USE IT
A. Registration Data
Data Description: Registration Data consists of the name, e-mail address, job title, and other contact information your employer provides us using the Services. We do not collect registration information in the mobile or web app.
B. Business Data
Data Description: Business Data consists of all the information you input using the Services other than the Registration Data. It includes information that relates to your business and your relationships with your Vendors, including Vendor names and contact information.
Lawful Basis for Processing: Our lawful basis for processing Business Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Business Data we receive from you.
How We Use It and Who We Share It With: Your Business Data is accessible only to us, to you. We do not share it with other third parties, except at your specific request, but we may use Business Data to make inferences that help us provide and improve the Services. We may also use Business Data in an aggregated format that is not identifiable to any individual, and that aggregated information belongs solely to us. To the extent we are required to delete any Business Data about you, we may still retain aggregated and anonymized information that may have originated as your Business Data.
C. Usage Data
Data Description: Usage Data consists of the following:
· Information about your interactions with the Services which includes the date and time of any requests you make.
The timing of the information you post to the Services including messages you send and/or receive via the Services and your interactions with our customer service team, but not including the content of those interactions and messages, which would be included as Business Data.
Technical data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Services, unique device IDs, device attributes, network connection type (e.g. WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and application version.
Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) required for the purposes of providing specific features of the Services to you.
Lawful Basis for Processing : Our lawful basis for processing Usage Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Usage Data we receive from you.
How We Use It and Who We Share It With: Usage Data is accessible to us and to you. We do not share it with third parties, except at your specific request, but we may use Usage Data to make improvements to the Services. We may also use Usage Data in an aggregated format that is not identifiable to any individual, and that aggregated information belongs solely to us. To the extent we are required to delete any Usage Data about you, we may still retain aggregated and anonymized information that may have originated as your Usage Data.
D. Payment Data
– We do not collect any payment data.
E. Supplemental Mobile Data
- Data Description: Supplemental Mobile Data consists of the following:
· Your precise mobile device location – If you give us permission to access your precise location, this enables us to access your GPS or Bluetooth to provide location-aware functionality in the Services. Please note that this does not include your IP address. We use your IP address to determine non-precise location, for example, what country you are in to comply with our licensing agreements;
· The Loop Me In user profile does not include age, gender, or other personal characteristics.
· Your photos – If you give us permission to access your photos or camera, we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your photo library or camera roll.
- Lawful Basis for Processing: Our lawful basis for processing Supplemental Mobile Data is (1) our contract with you and (2) our legitimate interest in improving our Services based on the Supplemental Mobile Data we receive from you.
- How We Use It and Who We Share It With: We only use Supplemental Mobile Data when you specifically authorize it, and we only share it with those parties who are strictly necessary for the purpose you have authorized.
SHARING YOUR INFORMATION
Except where a specific limitation is noted above, we do not share your data outside of our organization.
YOUR CHOICES REGARDING OUR USE AND DISCLOSURE OF YOUR DATA
If you wish to opt-out of our data collection, please contact your employer or email email@example.com so we can remove your account. Since the dealership is the owner of the account, it will need to approve the account cancelation.
SECURITY AND PRIVACY FOR EU RESIDENTS
For employees and other authorized users operating in their role as administrators or users of our services, our lawful basis is the legitimate interest we have in providing the services to you.
In turn, you, your employees, and your other authorized users agree to be bound by the provisions of the GDPR with respect to any personal data (“Data”) with which you come in contact using Services, including without limitation the personal data belonging to individuals with whom you communicate or whose personal data you access using the Services. Specifically, you agree that you, your employees, or other authorized users will:
A. Never access, process, transfer, view, use, or store any Data of any third party without express authorization, and then only for purposes directly related to fulfilling your contractual obligations under your agreement with any third party (“Data Secrecy”);
B. Keep all Data strictly confidential and disclose Data only on a strict need-to-know basis to other employees or authorized users only as required for fulfilling an individual’s contractual obligations (” Confidentiality”); however, you agree that you shall not disclose or otherwise make accessible Data under any circumstances to anyone who has not been obliged to Data Secrecy and Confidentiality.
C. Ensure that your obligations of Data Secrecy and Confidentiality are observed forever, both during and after the expiration and/or termination of any agreement with us or any contractual relationship you may have with an employer or other party.
D. Upon our request to provide Company with satisfactory evidence that you have complied with your obligations of Data Secrecy and Confidentiality as set forth in this agreement.
The GDPR also requires us to take appropriate technical and organizational measures to protect the security of Data belonging to residents of Europe. We make commercially reasonable efforts to ensure the privacy and security of the Data of our European visitors and customers, and we are happy to give you a complete description of our most current efforts, if you will write us at firstname.lastname@example.org
The security of your Data is important to us. We use commercially reasonable efforts to store and maintain your Data in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Data that you provide to us. We have implemented procedures designed to limit the dissemination of your Data to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
Our software has the ability to send notifications through either Push, Email and SMS formats. If you choose to receive system generated notifications from our system, you are consenting to receive SMS or EMAIL or PUSH messages from us. You might also receive SMS messages from us if you text our support phone numbers. You may of course opt out at any time by changing the notification method or replying STOP.
SHARING INFORMATION WITH THIRD PARTIES
The Services are not directed to children under the age of 13 years – this is an enterprise application. We do not knowingly collect personal data from children under 13 years, and if you are under 13, please do not use the Services, and do not provide any personal data to us, unless you are accompanied and authorized by a parent or guardian. If you are a parent or guardian of a child under 13 and become aware that your child has provided personal data to us without your consent, please contact us at email@example.com. If we learn that we have collected the personal data of a child under the age of 13 years without your consent, we will take reasonable steps to delete the personal data. This may require us to delete the account for that child.
ACCESS AND ACCURACY
You have the right to access the information we hold about you in order to verify the information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your information, although in certain limited circumstances we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your information as appropriate. As appropriate, this amended information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate information about you enables us to give you the best possible service.
You can help by keeping us informed of any changes such as a change of your personal contact information. If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us at firstname.lastname@example.org. If you have a complaint concerning our compliance with applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate measures.
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