1. The Axodel Group (comprising Axodel Limited, Axodel Bvba, Axodel IBERICA Sociedad Limitdada, Axodel ITALIA srl., and Kuantic SAS) (“Axodel”) is part of the Kuantic SAS Group of companies. Axodel is a provider of telematics services (including vehicle tracking) (“Telematics Services”) to business customers (our “Partners”) in respect of their fleet of vehicles (“Vehicles”) that are leased or otherwise made available to end users (“Users”). For more information about us. please see Who are we and what do we do?
2. Axodel provides its Telematics Services by utilising embedding devices in Vehicles and, in doing so, collects personal data related to the Users of Vehicles through those devices, and makes that information available via the Sites and Platform described in About our Sites and our Platform.
3. Axodel also collects and processes personal data relating to personnel of its Partners when it contracts with them to provide the Telematics Services and when it provides them and other users with access to the Sites and Platform described in About our Sites and our Platform.
4. This privacy policy explains our approach to protecting the personal data described above, which we may collect directly from you or from a third party (including our Partners), and the purposes for which we process it. This privacy policy also sets out your rights in respect of our processing of your personal data.
   

   For more information click here

   This privacy policy will inform you of the nature of the personal data about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.

   This privacy policy is intended to assist you in making informed decisions when using the Sites and interacting with us. Please take a moment to read and understand it.

   This privacy policy should also be read in conjunction with our Website Terms of Use. It only applies to the use of your personal data obtained by us and does not apply to your personal data collected during your communications with third parties.

5. Please note:
   • If you are the User of a Vehicle that is equipped with a device that we use to provide Telematics Services to a Partner, the personal data that we collect about you may be shared with our Partners. This privacy policy does not apply to any processing of such personal data undertaken by our Partners. To find out more about how and why your personal data is processed by our Partners, please contact the relevant Partner that has made a Vehicle available to you.
   • Our Platform is owned by our parent company, Kuantic SAS (“Kuantic”). This privacy policy does not apply to any processing of your personal data by Kuantic. Please see About our Sites and our Platform and Who are we and who is responsible for your data for further information.

1. Axodel provides its Telematics Services through the My Axofleet portal available at https://axofleet.axodel.com and through our Axo Driver mobile applications available on iTunes and Google Play (collectively the “Sites”).
2. The technology that underpins the services that Axodel makes available via the Sites is a platform known as Plastik (the “Platform”). The Platform is owned by our parent company, Kuantic, who may also be a controller of your personal data Who are we and who is responsible for your data for further information.

1. The Sites and our Telematics Services are provided by Axodel SAS or Axodel Limited. Depending on who the relevant Partner has contracted with, either one of these entities will be your data controller.
   

   For more information click here

   Axodel provides its services to Partners through the following companies :

   Kuantic SAS is a French company with registered office (31700) Blagnac, 2b rue Marcel Doret – Burolines – Building 2 RCS Toulouse 797 521 242  

   Axodel Limited is an English company with registered office 8th Floor South, 11 Old Jewry, London, United Kingdom, EC2R 8DU

   AXODEL Bvba is a Belgium company with registered office Brouwersvliet 37, 3de verdieping, Antwerpen, Belgium

   Axodel IBERICA Sociedad Limitdada is a Spanish company with registered office C/Pau Claris Nº138 7º 2ª C.P.08009 (Barcelona), Spain.

   AXODEL ITALIA srl . Environment Park Via Livorno, 60 10144 TURIN, Italy

   Please contact the relevant Partner to find out which of these companies is your data controller. Alternatively, you can contact us using the details below below – please see How to contact us.

2. References in the rest of this policy to “we”, “us”, or “our” are to the Axodel entity that is your data controller (see above).  The controlling Axodel entity may share your data with the other non-controlling Axodel entity so that the non-controlling entity can provide services to the controlling entity. The non-controlling Axodel entity will be a processor of your personal data.
3. Your personal data may also be shared with our parent company, Kuantic, who own the Platform that we use to provide our Telematics Services. Kuantic is a separate  and independent controller of your personal data. You can find out more about how and why Kuantic collects and uses your personal data by viewing Kuantic’s privacy policy here.

1. 4.1 If you have any questions about this privacy policy or want to exercise your rights set out in this privacy policy, please contact us by :
   • sending an e-mail to : info@kuantic.com
   • calling us on: +33 4898 70300

1. Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2. This section provides an overview of the personal data that we collect. A description of how we collect it and the purposes for which we process this personal data is set out in sections 6 and 7 below.
   • Personal data collected about Users when we provide Telematics Services (including Vehicle tracking) to our Partners.
     

     For more information click here.

     We may collect, use, store and transfer different kinds of personal data about Users of Vehicles in connection with our provision of the Telematics Services, which we have grouped together as follows:

     • User Data: Any data voluntarily submitted to us, including e-mail address, first name, last name, phone number, driving license number, registration, VIN code, date of purchase / start-up, device installation date, maintenance log, attributes of a heavy goods vehicle, identification number of DALLAS badges, identification number of RFID badges, identification number of tachograph cards.
     • Telematics Data: Data that is transmitted to us, including geographical position, course, speed, [CAN BUS data], accelerometer, accessory probes and sensors (temperature, fuel level, [logic state]).
     • Data calculated by us:
       • No data is pre-calculated as regards the Kuantic devices.
       • For partner devices (PSA BTA) the pre-calculation of data (note eco-driving by criteria and overall) is carried out by the partner and stored in the Kuantic servers in the same way as the data collected.
     • Data deduced by us: hardware installation and operational malfunction.
   • Personal data collected about users of our Sites and during our dealings with our Partners’ personnel.
     

     For more information click here.

     We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows :

     • Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.
     • Contact Data includes billing address, delivery address, email address and telephone numbers.
     • Financial Data includes bank account and payment card details.
     • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
     • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
     • Profile Data includes your username or similar identifier and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
     • Usage Data includes information about how you use our website, products and services.
     • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

     We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

     We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

1. 6.1 This section describes how we collect the personal data described in section 5 of this privacy policy :
   • Personal data collected about Users when we provide Telematics Services (including Vehicle tracking) to our Partners.
     

     For more information click here.

     Nous pouvons collecter, utiliser, conserver et transférer différents types de données personnelles au sujet des Utilisateurs des Véhicules, en rapport avec les Services télématiques que nous fournissons. Nous avons groupé lesdites données de la manière suivante :

     • User Data: This is voluntarily submitted to us via the Sites or platforms that our Partners and Users can access.
     • Telematics Data: This is transmitted to us from devices that are embedded in Vehicles.
   • Personal data collected about users of our Sites and during our dealings with our Partners’ personnel.
     

     For more information click here.

     We use different methods to collect data from and about you including through:

     • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :
       • apply for our products or services;
       • create an account on our Sites;
       • subscribe to our services;
       • request marketing to be sent to you;
       • enter a competition, promotion or survey; or
       • give us feedback or contact us.
     • Automated technologies or interactions. As you interact with our Sites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our Cookie Policy for further details.

1. This section describes how we use the particular classes of personal data that are identified in section 5 of this privacy policy and the legal basis that we rely on to process the personal data for each purpose.
2. If you are a User of a Vehicle that is equipped with a device that we use to provide our Telematics Services, our primary reason for collecting personal data is to help our Partners manage their fleet of Vehicles :
   • In particular, we may use your personal data for the following purposes.
     

     For more information click here.

     We collect and maintain User Data and Telematics Data to provide our Partners with the particular services that they have requested.

     Who do we share your personal data with for this purpose ?

     User Data and Telematics Data is shared with the Partner that has made the Vehicle available to the User that the personal data relates to. To find out more about how and why your personal data is processed by our Partners, please contact the relevant Partner that has made a Vehicle available to you.

     We will also share your personal data within our group of companies. Please see Who are we and who is responsible for your data? for further information.

     What is our legal basis ?

     It is in our legitimate interest for us to use your personal data to perform our obligations in accordance with any contract that we have with our Partner.

3. 7.3 If you are a user of our Sites or are a member of our Partners’ personnel, our primary reasons for collecting personal data relating to you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests made by you on the Sites; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enter into, administer and enforce our agreements with our Partners; (vii) protect the rights, property or safety of us or third parties, including our other customers and users of the Sites and at our stores; (viii) provide support for the provision of our Telematics Services; and (ix) use as otherwise required or permitted by law.In particular, we use your personal data for the following purposes:
   • Entering into and performing contracts with our Partners for Telematics Services.
     

     For more information click here.

     We collect and maintain Identity Data, Profile Data, Contact Data, Financial Data and Transaction Data so that we can enter into, administer and perform contracts that we have with Partners for the provision of our Telematics Services:

     Who do we share your personal data with for this purpose ?

     We will share your personal information with the following categories of third parties:

     • To verify and process payments and refunds – electronic payment providers

     We may also share your personal data within our group of companies. Please see Who are we and who is responsible for your data? for further information

     What is our legal basis ?

     It is in our legitimate interest to use your personal data so that we can perform our obligations in accordance with any contract that we have with our Partner.

   • Providing secure access to restricted sections of our Sites.
     

     For more information click here.

     In order to receive the Telematics Services, our Partners’ personnel may need to register and create accounts for access to restricted areas of our Site. In doing so, we will ask for Profile Data to be submitted to us and we may combine this data with other data, including your Contact Data, to manage your account.

     Who do we share your personal data with for this purpose ?

     We do not share your personal data with third parties for this purpose.
     We may share your personal data within our group of companies. Please see Who are we and who is responsible for your data? for further information.

     What is our legal basis ?

     It is in our legitimate interest to use your personal data in such a way to ensure that we can deliver our Telematics Services to our Partners.

   • Customer service and relationship management.
     

     For more information click here.

     We use various user interfaces to allow you to request information about our products and services. These include printed and electronic enquiry forms and a telephone enquiry service. Contact Data may be requested in each case, together with details of other personal data that is relevant to your enquiry. This information is used in order to enable us to respond to your requests.

     Who do we share your personal data with for this purpose ?

     We do not share your personal data with third parties for this purpose.
     We may share your personal data within our group of companies Please see Who are we and who is responsible for your data? for further information.

     What is our legal basis ?

     It is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best customer service we can to you.

   • Your feedback about our products and services.
     

     For more information click here.

     From time to we may use your Contact Data to invite you to provide feedback about our services in the form of electronic or postal surveys or to provide a review or endorsement. We use this information to help us improve the quality of service provided us. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.

     Who do we share your personal data with for these purposes?

     We use a third party service provider to assist us with customer surveys and feedback requests.

     We may also share your personal data within our group of companies. Please see Who are we and who is responsible for your data? for further information.

     What is our legal basis ?

     It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

   • Customer insight and analysis.
     

     For more information click here.

     We receive and/or gather Usage Data by analysing your Contact Data with other personal data that we observe about you from your interactions with our Sites, our email communications to you and/or during our supply of Telematics Services.

     Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect the Technical Data described above.

     Our web pages [and e-mail]s contain “cookies” “web beacons” or “pixel tags.” (“Tags”) which allow us to track [receipt of an e-mail to you], to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. [Once you click on an e-mail that contains a Tag, your Contact Data may subsequently be cross-referenced to the source e-mail and the relevant Tag].

     [In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications].

     Please see our Cookie Policy for further information.

     This information is used to create profiles and insights about your browsing habits and the browsing habits of our other users to our Sites.

     By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our services. This allows us to learn what pages of our Sites are most attractive to our visitors and which parts of our Sites are the most interesting.

     We also use this information to help us with the selection of future product and service lines and websites design.

     Who do we share your personal data with for these purposes ?

     We do not share your personal data with third parties for this purpose.

     We may also share your personal data within our group of companies. Please see Who are we and who is responsible for your data ? for further information.

     What is our legal basis ?

     Where your personal data is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised data may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

     Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best products and services to you and our other customers.

   • Marketing communications.
     

     For more information click here.

     We carry out the following marketing activities using your personal data, including your Contact Data and Marketing and Communications Data.

     • Postal marketing
       We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your address details, to send you marketing communications by post.

       Who do we share your personal data with for these purposes?

       We share your personal data with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.

       We may also share your personal data within our group of companies. Please see Who are we and who is responsible for your data? Who are we and who is responsible for your data?

       What is our legal basis ?

       Where your personal data is completely anonymised, we do not require a legal basis to use it as the personal data will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

       Where your personal data is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal data for postal marketing.

     • Email marketing
       We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email.

       Who do we share your personal data with for these purposes ?

       We do not share your personal data with third parties for this purpose.

       We may share your personal data within our group of companies. Please see Who are we and who is responsible for your data? for further information.

       What is our legal basis ?

       Where your personal data is completely anonymised, we do not require a legal basis to use it as the personal data will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

       Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data for marketing purposes.

       We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

   • Business administration and legal compliance.

     For more information click here.

     We use your personal data for the following business administration and legal compliance purposes:

     • to comply with our legal obligations;
     • to protect our business, including our Sites, and enforce our legal rights;
     • protect rights of third parties, including our Partners; and
     • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

     Who do we share your personal data with for these purposes?

     We will share your personal data with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

     We may also share your personal data within our group of companies. Please see Who are we and who is responsible for your data?

     What is our legal basis ?

     Where we use your personal data in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal data to comply with any legal obligations imposed upon us such as a court order.

Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

We do not transfer your personal data outside the European Economic Area.

1. Our Sites may contain links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this privacy policy no longer applies.
   

   For more information click here.

   Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third party service provider’s own rules and policies.

   We do not monitor, control, or endorse the privacy practices of any third parties.

   We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

   This privacy policy applies solely to personal data collected by us and does not apply to these third party websites and third party service providers.

1. We keep Telematics Data and User Data during the term of our contract with the relevant Partner and for periods that are determined by the relevant Partner. When our contract with the relevant Partner ends, we will retain Telematics Data and User Data for two months after which point it will be deleted.
2. In relation to the other classes of data that are described in this policy, We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
3. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
4. If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.
5. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

1. We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.
   

   For more information click here.

   We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from :

   • unauthorised access;
   • improper use or disclosure;
   • unauthorised modification; and
   • unlawful destruction or accidental loss.

   All of our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of the personal data that we control.

1. You have the following rights in relation to the personal data we hold about you :
   • Your right of access.
     

     For more information click here.

     If you ask us, we’ll confirm whether we’re processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

   • Your right to rectification.
     

     For more information click here.

     If the personal data we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

   • Your right to erasure.
     

     For more information click here.

     You can ask us to delete or remove your personal data in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal data with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

   • Your right to restrict processing.
     

     For more information click here.

     You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it. It won’t stop us from storing your personal data though. We’ll tell you before we lift any restriction. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

   • Your right to data portability.
     

     For more information click here.

     With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal data you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

   • Your right to object.
     

     For more information click here.

     You can ask us to stop processing your personal data, and we will do so, if we are.

     • relying on our own or someone else’s legitimate interests to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or;
     • processing your personal data for direct marketing.
   • Your rights in relation to automated decision-making and profiling.
     

     For more information click here.

     You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

   • Your right to withdraw consent.
     

     For more information click here.

     If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.

   • Your right to lodge a complaint with the supervisory authority.
     

     For more information click here.

     If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal data, you can report it to the [UK Information Commissioner’s Office (ICO]). You can find details about how to do this on the [ICO] website at [https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113].