This Policy outlines PaperDoDo’s commitment to protecting the privacy of individuals (“you”) who: visit our website, subscribe to the PaperDoDo Solution or other services of ours, resell the PaperDoDo Solution, or attend events sponsored by PaperDoDo or its affiliates.
This Policy applies to our collection, processing and use of personal data when you use the following:
For the purposes of this Policy, personal data means information or data relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly, or indirectly, by reference to an identification number or to one or more factors that indicate their identity.
Our website may contain links to other websites that are operated by third parties. This Policy does not apply to those websites. We strongly suggest that you carefully review the privacy policies and statements of any third-party websites to properly understand their information practices.
Information in PaperDoDo is either entered by you when setting up your account, or is collected when you drive a vehicle connected to the PaperDoDo Solution.
To use PaperDoDo, you or another representative from your organization must set up a PaperDoDo account and provide us with certain information such as name, address, phone number, email address, company name, or company website.
We also collect information about an account holder’s activities on PaperDoDo. PaperDoDo provides Customers with the ability to obtain, among other types of data, GPS vehicle location data, engine and diagnostic data, and mapping information. GPS coordinates can be anonymously provided to a third party service provider to obtain mapping information without identifying a particular vehicle, Customer, or driver. We only process personal data about a driver operating a vehicle connected to the PaperDoDo solution when that Customer enters the driver’s personal data into the PaperDoDo platform, and only in accordance with the Customer’s written instructions or as required by applicable law.
To use Reseller Portal, a reseller’s representative provide us with certain information such as name, address, phone number, email address, company name, company website, company financial information, and payment information. We also collect information about a reseller’s activities on the Reseller Portal MyAdmin. Reseller Portal enables resellers to provide support, functionality, reports, and other product features to Customers.
The PaperDoDo Solution is comprised of a software platform and a vehicle device (hardware) to enable Customers to collect vehicle data to manage their fleets. The vehicle device is installed into a vehicle’s on-board diagnostic port (also called the OBDII) that facilitates the extraction of data about the vehicle and its use. Any data that is temporarily stored on the device is encrypted. The vehicle data on a device is then transmitted to PaperDoDo’s servers through secured wireless telecommunications networks and stored on encrypted cloud servers, in accordance with the applicable providers’ respective privacy, data handling and data usage policies. To the extent such data includes personal data about you, we only use such data at the direction of the Customer who uses the PaperDoDo Solution to collect personal data about you.
We may also collect personal data from our website in the event you use the interactive features of the website, such as accessing a white paper, commenting on a blogpost, or participating in surveys, contests, or promotions. If you apply for a position with PaperDoDo through a job posting on our website, we will collect personal data about you such as your name, resume, phone number, and email address. If you comment on articles or blog posts, we may also collect certain personal data about you that you include in your comment. We and our authorized partners may also collect information using cookies and other information gathering technologies for a variety of reasons.
The PaperDoDo website may also use web beacons, tags, and scripts or use them in email or other electronic communications we send to you. These assist us in sending cookies and counting visits to our website while helping us understand usage and the effectiveness of various campaigns and promotions. Furthermore, we may receive and develop reports based on the use of these technologies by our third party service providers on an individual and aggregated basis.
We may also ask for and collect personal data from individuals who register for or attend events sponsored by PaperDoDo or its affiliates. Such data may include your name, address, phone number, and email.
The PaperDoDo website includes social media features such as the Facebook “Like” and “Share” buttons as well as mini-programs that run on our website. These features may collect your internet protocol address (IP address), which webpage you are visiting, and may set a cookie to enable the feature to function properly. The use of such features is governed by the privacy policies of the feature owner.
If you created a PaperDoDo account, we use your personal data to provide, maintain, improve, and promote the PaperDoDo Solution. We may also use personal data to enable authorized Customers to access PaperDoDo, and to send Customers transactional messages in order to respond to comments, questions, and requests or to distribute important Customer information.
If you created a Reseller Portal account, we use your personal data to provide,maintain improve, and promote MyAdmin. We also use your personal data to process transactions, obtain purchase confirmations and invoices, and to send reseller specific communications, or to respond to comments, questions, and requests or distribute information pertaining to the PaperDoDo solution.
If you drive a vehicle connected to the PaperDoDo solution, we receive personal data about you to the extent our Customer provides such personal data to us, and we process such personal data in accordance with our Customer’s written instructions or as required by applicable law. To the extent that personal data about you may be inferred from technical vehicle information collected from the device, we process such personal data in accordance with this Policy.
We also use your personal data to provide customer service and support. Such support may include technical notices, updates, security alerts, and administrative messages. Where permitted by applicable law, we may also send you promotional communications from time to time to inform you of products, services, features, surveys, newsletters, offers, promotions, contests, and events. Information and news about our partners may also be communicated from time to time.
You can opt out of marketing communications at any time by contacting us at email@example.com or following the unsubscribe or opt-out instructions included in our marketing communications.
If you applied for a job position through our website, we may provide your data to a third party service provider to assist us in managing your application. The job application data you provided to us may also be used or accessed from any of PaperDoDo’s locations depending on the nature of the position.
Additionally, we use information to monitor and analyze trends, usage, and activities in connection with our website and Customer accounts in order to investigate and prevent fraudulent transactions, unauthorized access to the PaperDoDo Solution, and other illegal activities. We may also use personal data for any other purpose for which we have obtained your consent or where permitted or required by applicable law.
We extract vehicle data using the PaperDoDo device and aggregate it through Google’s BigQuery enterprise data warehouse. We extract data using the Geotab device and PaperDoDo software and aggregate it through a 3rd party enterprise data warehouse. Aggregated data sets made available by PaperDoDo do not contain personal data and cannot reasonably be used to identify an individual.
If you are located in the European Economic Area (EEA), PaperDoDo’s legal basis for collecting and processing the personal data we receive depends on the context in which it is sent to us. In our normal course of business, we will only collect and process personal data that has been sent to us by you or our Customer through: the PaperDoDo website, the PaperDoDo platform, the Reseller Portal We will process the personal data sent to us where you have provided your consent (as of May 25, 2018 based on Art. 6 of the GDPR) or where the processing of the information is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and not overridden by your data protection interests or fundamental rights and freedoms (as of May 25, 2018 based on Art. 6 of the GDPR). We may also process your personal data where we have a legal obligation to collect and process personal data and
are the controller in respect of such data (as of May 25, 2018 based on Art. 6 of the GDPR), or where the processing is necessary to protect your vital interests or that of another natural person (as of May 25, 2018 based on Art. 6 of the GDPR).
In circumstances where we rely on your consent to process the personal data, you have the right to withdraw your consent at any time. However, this may not affect the lawfulness of the processing based on the consent PaperDoDo has received prior to the withdrawal of consent.
If you provide PaperDoDo your personal data to comply with a legal requirement (e.g. Hours of Service) or to perform a contract (e.g. End User Agreement), we will make this clear to you at the relevant time. PaperDoDo recommends that Customers, users, and resellers take steps to minimize the personal data they ask PaperDoDo to process.
PaperDoDo may share information, including personal data, with our third party service providers that we engage for providing hosting, for maintenance of our websites, applications, backup, storage, payment processing, analytics, and other services. We do not allow our service providers with whom we share personal data to use that information for marketing or any other purpose other than in connection with the services they provide to PaperDoDo. See Exhibit “A” below for more information.
In some circumstances, we may receive a request from public authorities to disclose personal data in response to a legally binding request to meet national security or law enforcement requirements. As applicable, we may disclose personal data to comply with subpoenas, court orders, or legal process, or to enforce our legal rights and defend against legal claims. In some cases, we may also share personal data if we believe that illegal or fraudulent activity is or has taken place so that we can investigate, prevent, and take appropriate action regarding such activities that may pose a potential threat to the physical safety of any person, violations of our Customer agreements, or to comply with the law. If your personal data becomes subject to a legal disclosure requirement and we are permitted to do so, we will attempt to notify you of said disclosure, if we have current contact information on file.
From time to time, we may post success stories on our website or in other publicly distributed material that contains personal data. In such cases, we obtain your written consent before posting your name or other personal data with the success story. If you wish to delete or remove your success story, you can contact us at firstname.lastname@example.org.
We may share information, including your personal data, within the PaperDoDo group of companies.
We may also share information with third parties when you have provided us with your consent to do so.
PaperDoDo stores data about website visitors, Customers, and resellers on cloud servers located in North America, , Europe, and Asia. We may also store data on cloud servers located in other countries from time to time. PaperDoDo operates on a global scale and we may transfer and access such personal data from various parts of the world, including from other countries where PaperDoDo has Customers and operations. PaperDoDo stores European Customer data on servers located within the EEA and North American Customer data on servers within North America. However, data (including personal data) may be transferred across national boundaries for load balancing, availability, or other reasons. We have entered into the EU Standard Contractual Clauses with our cloud service provider to comply with the most stringent privacy laws.
Personal Data Transfers outside of the EEA (Applicable to EEA only)
To the extent PaperDoDo is a controller of your personal data and you reside in the EEA, please note the following. We may transmit some of your personal data to an international organization or a country where the data protection laws may not provide a level of protection equivalent to the laws in your jurisdiction. As required by applicable law, we will provide an adequate level of protection for your personal data using various means, including, where appropriate:
Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.
You can choose how we use your personal data to communicate with you through our website, PaperDoDo Solution, or email. You can manage your receipt of marketing and non-transactional communications by clicking an unsubscribe link in emails received from us or you may send a request to email@example.com.
Customers may change or update the information associated with their PaperDoDo and Reseller Portal accounts by logging into these services and editing their profile. You may request to have personal data that we maintain returned or removed by contacting our Customer support department or firstname.lastname@example.org. PaperDoDo reserves the right to validate requests to ensure legitimacy. Valid requests will be handled within 30 days.
An individual who seeks access to, or wishes to correct, amend, or delete inaccuracies in personal data stored or processed by PaperDoDo may have to direct such inquiries to the appropriate Customer who has access to PaperDoDo and acts as the data controller. Customers may, if required, then make a request to PaperDoDo who will act on valid requests within 30 days. We retain personal data that we store and process on behalf of Customers, resellers, and website visitors for as long as necessary to provide the PaperDoDo Solution. Information (including personal data) will be retained and used as necessary to enable us to comply with our legal obligations, resolve disputes, support our Customers and resellers, and to comply with and enforce our agreements.
We take the security of your personal data very seriously and follow generally accepted technological and organizational measures to safeguard such information. We do this when the information is in transit, in use, and at rest.
PaperDoDo will retain your personal data for as long as needed to fulfill the purposes for which the data was provided. PaperDoDo will delete or anonymize your personal data when we no longer have a legitimate business need for it. If it is no longer possible to delete it because, for example, it has been backed up in archives, then we will securely store the personal data and isolate it from further processing until deletion is possible.
For personal data that we process on behalf of resellers and customers users, we will retain such personal data in accordance with the terms of our agreement with them, subject to applicable laws.
If you reside in the EEA or certain other jurisdictions, you have the right to exercise additional rights available to you under the local law that applies to you:
In the event you would like to inquire about exercising these rights, you may contact our privacy officer by emailing us at email@example.com. In order to protect your privacy and that of others, we may take steps to verify your identity and the validity of your request before we comply.
You also have the right to communicate with a data protection authority about our collection and processing of your personal data. You may contact your local data protection authority for more information.
We do not knowingly or intentionally collect or process any personal data from children under the age of 13. If you are under the age of 13, do not submit any personal data through our website or the PaperDoDo Solution. Parents and legal guardians are encouraged to monitor their children’s internet use and assist in helping us enforce this Policy by teaching their children never to provide personal data through our website or the PaperDoDo Solution. If you have reason to believe that we may have been sent personal data of a child under the age of 13, contact us at firstname.lastname@example.org and we will use reasonable efforts to delete such information.
If PaperDoDo was to sell or divest all or substantially all of our business, stock, or assets with another entity, we may assign or transfer this Policy as well as your account and related data (including personal data) in accordance with applicable law.
If we make any changes to this Policy, we will post an updated policy on our website. You should periodically review this page for the latest information on our privacy practices. If you continue to use our website or the PaperDoDo Solution, you agree to be bound by such changes to this Policy. If you do not agree to such changes, please contact us. We will attempt to resolve your concern by either providing an explanation or making an accommodation. If we cannot accommodate you, then your only remedy is to discontinue use of the website or PaperDoDo Solution.
PaperDoDo, as a Canadian headquartered company, complies with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canadian Anti-Spam Legislation (CASL), and other applicable provincial and federal laws regarding the data we process, collect, store and use to provide the PaperDoDo Solution. Canada’s data protection standards have been deemed adequate by the EU.
If you have questions about this Policy or about PaperDoDo’s privacy practices, you can contact us by email at email@example.com.
Non-English translations of the Policy, if any, are provided for convenience only. If any ambiguity or conflict exists between such other translations, this English version will be held as the authoritative version.
Exhibit “A’ – Sub-Processors
|Sub-Processors Used by PaperDoDo to Support the PaperDoDo Solution, Recruitment activities, and Website|
|Google Cloud Platform|
|Amazon Web Services|