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Otonomo Privacy Policy

otonomo Ltd. and its subsidiaries (“otonomo”, “we”, “us” or “our”) put great efforts in making sure that your personal information is secured and used properly. otonomo owns and operates a cloud-based marketplace for car-generated data (the “Service”).

This policy explains our privacy practices for processing personal information on the Service and otonomo’s website (the “Site”). We process your personal information on the Site subject to the terms of this policy. Please contact our Privacy Officer at: [email protected] for any further information.

Otonomo Privacy Policy

otonomo Ltd. and its subsidiaries (“otonomo”, “we”, “us” or “our”) put great efforts in making sure that your personal information is secured and used properly. otonomo owns and operates a cloud-based marketplace for car-generated data (the “Service”).

This policy explains our privacy practices for processing personal information on the Service and otonomo’s website (the “Site”). We process your personal information on the Site subject to the terms of this policy. Please contact our Privacy Officer at: [email protected] for any further information.

The Service

We provide a marketplace for vehicle-generated data

otonomo receives personal information from otonomo marketplace partners, such as vehicle-data aggregators, car manufacturers and data telematics service providers, to provide the Service and for additional specific purposes, as described in this policy.

We do not receive identifiers, such as your name, your car’s license plate number, any government issued IDs, telephone numbers and addresses, without receiving appropriate assurances that you have explicitly consented to provide such details.

We will receive vehicle-generated data such as car make, car model, geo-coding country and city, longitudes and latitudes of the vehicle location, RPM, battery voltage, fuel level, vertical and longitudinal acceleration and altitude.

We will not receive, or process vehicle-generated identifiable personal information related to you, without receiving sufficient assurances from our data providers, that you have been provided with clear and appropriate notices and that you explicitly consented to provide such details.

You are not required by law to provide personal information to the Service.

The Personal Information that We Receive

We receive and process vehicle-generated data

otonomo receives personal information from otonomo marketplace partners, such as vehicle-data aggregators, car manufacturers and data telematics service providers, to provide the Service and for additional specific purposes, as described in this policy.

We do not receive identifiers, such as your name, your car’s license plate number, any government issued IDs, telephone numbers and addresses, without receiving appropriate assurances that you have explicitly consented to provide such details.

We will receive vehicle-generated data such as car make, car model, geo-coding country and city, longitudes and latitudes of the vehicle location, RPM, battery voltage, fuel level, vertical and longitudinal acceleration and altitude.

We will not receive, or process vehicle-generated identifiable personal information related to you, without receiving sufficient assurances from our data providers, that you have been provided with clear and appropriate notices and that you explicitly consented to provide such details.

You are not required by law to provide personal information to the Service.

The Personal Information that we Collect

We automatically log ‘traffic/session’ information and additional activity information on our Site.

When you access our Site or our blog, our servers log certain ‘traffic/session’ information from your device, such as your user agent and the Internet Protocol (IP) address.

When you use our Site or our blog, we may collect information about your activity, for example your log-in and log-out time, the duration of sessions, viewed web-pages or specific content on web-pages and activity measures.

The Personal Information that you Provide

When you register to our mailing list, we will need your name, your company name and email address, for registration, communication and notice purposes.

We may offer you to register to our mailing list. We will need information such as your name, your company name and email address, for registration, communication and notice purposes.

We will receive any personal information that you provide when you contact us.

The Site may also include links to third-party social media websites such as Facebook®, Twitter®, LinkedIn® and Google+®, as well as associated social media features and scripts, such as the Facebook® “like” button and widgets.

You may also share information through links to social media websites.

These features and scripts may collect your IP address, the website pages (URLs) that you are visiting on the Site and may set cookies to enable the social media features to function properly.

Social media features and widgets are either hosted by the applicable third party social media website or hosted directly on the Site.

Your interactions with these social media features and widgets, as well as your interactions with the social media websites themselves, are governed by the privacy policies of the applicable social media websites.

We are not responsible for any use, misuse or unlawful use of the identifiable information that you choose to submit in those forums.

When you contact us, or when we contact you, we may receive and process any personal information that you provide us.

We may display personal testimonials of satisfied customers on the Site in addition to other endorsements. Only with your consent, we may choose to post your testimonial along with your name.

If you wish to update or delete your testimonial, you can contact us at: [email protected]

What Do We Do with Personal Information?

We use personal information to provide our Service and develop it, to maintain the Site and Service, make them better and protect us and the Service and Site from misuse and law violations

We use personal information that we collect and receive through the Service to provide the Service for various and diverse use-cases, such as:

  • insights and knowledge about the use of vehicles, traffic flow management, urban planning, parking management, automated road tolls, road infrastructure maintenance and improvement, car-design improvements;
  • data feedback for car research and development optimization, usage-based insurance, vehicle monitoring and theft protection, collision warning, real-time weather and hazard notifications;
  • automatic emergency calls, data for first responders and healthcare providers, driving skills improvement and education, real-time location-based promotion, on-demand energy services, usage insights, electrical vehicle infrastructure insights;
  • in-vehicle offering and targeted advertising, data analytics for store location and opening hours optimization, predictive maintenance services, reducing breakdown risks and downtime, roadside assistance and certified mechanics, vehicle performance status;
  • fleet management, driver safety and operations efficiency, performance data from actual users.

We further use personal information to enable the Service’s tools and features, including for automated processes and profiling, to study and analyze the functionality of the Site and Service, to provide support, to measure the Site and Service activity, to maintain the Service, to make it better, and to continue developing the Service.

If you provide Us your email address, we may use it to contact you when necessary, to provide information and notices about the Site and Service. We may choose to include commercial and marketing information.

We may use personal information for our following legitimate interests:

  • to enforce our terms, policies and legal agreements;
  • to comply with court orders and warrants, and assist law enforcement agencies;
  • to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Service;
  • to prevent cyber security attacks and any other unlawful or unauthorized use of your personal information and the Service;
  • to take any action in any legal dispute and proceeding;
  • for additional purposes that we may believe in good-faith to be within your reasonable expectation.

We commit to process personal information solely for the purposes described in this policy. To the extent relevant and possible, we will make efforts to maintain the information accurate, complete and up-to-date.

Cookies

We use cookies as part of your experience in the Site. We may use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies and cookies.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie.

Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”.

We may use both types of cookies. We may use both Persistent Cookies and Session Cookies to facilitate the use of the data’s features and tools.

Every browser allows you to manage your cookies preferences. Please bear in mind that disabling cookies may complicate or even prevent you from using some areas of our Site or perhaps certain features of our Site.

Sharing Personal Information with Others

We may share personal data with our marketplace partners, we may use service providers, for example, to send email messages.

We will share your personal information only subject to the terms of this policy, or subject to your prior consent.

We may transfer information as needed if we change our corporate structure, and we may share the information with our affiliate entities

We may share your personal information with Our marketplace partners (such as smart cities, automotive suppliers, insurance companies, safety and emergency service providers’ etc.).

We use service providers and may share information with them, including: analytics, data hosting, back-up, business intelligence services, customer relations, cyber security, mailing and other relevant services, to help us maintain, operate and improve the Site and Service and to fulfill the purposes of processing personal information, under the applicable law and this policy.

We may also share personal information with companies or organizations connected, or affiliated with us, such as subsidiaries, sister-companies and parent companies, with the express provision that their use of such information must comply with this policy.

We may report and share user personal information, if we believe that we are required to do so by law. We may need to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Additionally, a merger, acquisition or any other structural change may require us to transfer your personal information to another entity, provided that the receiving entity will comply with this policy.

Aggregated and Analytical Information

Aggregated data is not personal. We use it for legitimate business purposes and may use standard analytical tools

We may use standard analytics tools. The privacy practices of these tools are subject to their own privacy policies and they may use their own cookies to provide their services (for further information about cookies, please see the ‘Cookies’ section in this policy).

We use the standard analytics tools of Google Analytics and we may use additional or other analytics tools, from time to time. The privacy practices of these tools are subject to their own privacy policies.

You can review the Google Analytics Privacy Policy here: http://www.google.com/analytics/learn/privacy.html..

We may use anonymized, statistical and aggregated information and may share it with our partners and other third parties for legitimate business purposes.

The use of such data does not have an effect on your privacy, because we take considerable precautions to make sure that the data cannot be associated with you.

We will share your personal information only subject to the terms of this policy, or subject to your prior explicit consent.

Choice

You may opt-out of our mailing lists and terminate your use of the Site.

At any time, you may unsubscribe from our mailing lists or newsletters, by sending an opt-out request to: [email protected].

You may request otonomo to stop collecting and using any personal information about you.

At any time, you may object to the transfer of your personal data to a third party, other than to third parties who help us perform tasks as explained above under “Sharing Identifiable Information with Others“.

Our Service does not respond to Do Not Track (DNT) signals.

Our Service does not respond to Do Not Track (DNT) signals.

You may exercise your choice by contacting us at: [email protected]. Note in most cases, we do not maintain direct identifiers such as your name, license plate number, government issued IDs and telephone numbers.

We may need to ask you to provide us necessary details to authenticate your identity and to identify data related to you on our systems.

Some web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is an HTTP header field indicating your preference for tracking your activities on the Service or through cross-site user tracking. Our Service does not respond to DNT signals.

Your California Privacy Rights

If you are a California resident, you are entitled to your California privacy rights.

If you are a California resident, California Civil Code Section 1798.83 permits you to request in writing a list of the categories of personal information relating third parties to which We have disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes.

To make such a request, please contact us at: [email protected].

Accessing Your Personal Information

At any time, you can request access to your personal information and you may ask us to delete your personal information from the systems of the Site and Service.

At any time, you may contact us at: [email protected] and request access to the identifiable information that we keep about you. We may need to ask you to provide us certain credentials to make sure that you are who you claim to be.

Note in most cases, we do not maintain direct identifiers such as your name, license plate number, government issued IDs and telephone numbers.

We may need to ask you to provide us necessary details to authenticate your identity and to identify data related to you on our systems. After we delete your personal information, it may take some time until residual copies are deleted from our active servers and from our backup systems.

Our deletion of your personal information from our systems do not delete personal information which may have already been shared with third parties, as permitted under this Privacy Policy.

We may redact from the data which we will make available to you, any personal information related to others.

We may also delete your personal information, by removing any identifying information and transforming personal data that relates to you into anonymized data.

Your EU Data Subject Rights

You may exercise your EU data subject rights.

In addition to the right to access, amend and delete certain information, as described in the “Accessing Your Personal Information” chapter, if we process personal information related to you when you are in the EU, you may:

  • Contact us if you want to withdraw your consent to the processing of your personal information. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
  • Request to delete or restrict access to your personal information. We may postpone or deny your request if your personal information is in current use for providing our Service or to other legitimate purposes such as compliance with regulatory requirements.
  • If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold your personal information, in accordance with this Policy, will act accordingly.
  • You may ask to transfer your personal information in accordance with your right to data portability.
  • You may object to the processing of your personal information for direct marketing purposes.
  • You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
  • You have a right to lodge a complaint with a data protection supervisory authority.

Note in most cases, we do not maintain direct identifiers such as your name, license plate number, government issued IDs and telephone numbers. We may need to ask you to provide us necessary details to authenticate your identity and to identify data related to you on our systems.

We do periodical assessments of our data processing and privacy practices to make sure that we comply with this policy, to update the policy when needed, and to verify that the policy is displayed properly and is accessible.

If you have any concerns about the way we process your personal information, you are welcome to contact our privacy officer at: [email protected], or to write to us to: Otonomo Ltd., 16, Abba Even St., Herzlyia, Israel 4672534. We will look into your inquiry and make good-faith efforts to resolve any existing or potential dispute with you.

Data Retention

We retain data as needed, to provide the service and for legitimate and lawful purposes

We retain data as needed to provide the Service and Site and for legitimate and lawful purposes, as well as pursuant to legal requirements under the applicable law.

We will make efforts to guarantee that personal information is kept for no longer than is necessary for the purposes for which the personal information is processed.

In any case, as long as we use your personal information to provide our Service, we will keep the information about you, unless we are required by law to delete it, or if we accept your request to delete the information, pursuant to applicable laws, or if we decide to remove it at our discretion.

If we retain your personal information for any legitimate business purpose other than to provide the Service, we will make efforts to limit the access to the personal information and the retention time period to minimum.

We may keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.

Transfer of Data Outside your Territory

We may store and process information in various sites throughout the globe, including in sites operated and maintained by cloud based service providers

We may store and process information in various sites throughout the globe, including in sites operated and maintained by cloud based service providers.

If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you provide us your express and unambiguous consent to such transfer.

Our transfer of personal information to Israel is made in accordance with the EU Commission decision 2011/61/EU of January 31, 2011, on the adequate protection of personal data by the State of Israel with regard to automated processing of personal data.

Our recipients of the Marketplace information may be established in various territories.

To the extent necessary under EU privacy laws and regulations, we will implement data onward transfer instruments, such as the Controller to Processor SCCs, the Controller to Processor SCCs, the Privacy Shield Framework and a statement of compliance with the Privacy Shield Principles, and such other lawful instruments to transfer personal information, as may be available from time to time.

Information Security

We implement systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information

We and our hosting services implement systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

These measures provide sound industry standard security. However, although we make efforts to protect your privacy, we cannot guarantee that the Service will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Marketplace Privacy Commitments

All marketplace partners our committed to your privacy and security

Please read the otonomo Marketplace Privacy and Security Statement at: https://otonomo.io/privacy-security-statement, for further details about the commitments to privacy that otonomo and the Marketplace Partners substantially make as part of their contractual engagements.

Changes to this Privacy Policy

We may update our policy from time to time after giving proper notice.

From time to time, we may update this policy. If the updates have minor if any consequences, they will take effect 7 days after we post a notice on the Site. Substantial changes will be effective 30 days after our notice was initially posted.

Until the new policy takes effect, you can choose not to accept it and terminate your use of the Site. Continuing to use the Site after the new policy takes effect means that you agree to the new policy.

Note that if we need to adapt the policy to new legal requirements, the new policy will become effective immediately or as required.

Contact Us

Please contact our Privacy Officer at: mailto:[email protected] for further information

If you have any inquiries or questions about this policy, please contact our Privacy Officer at: [email protected] for further information.

Last updated: February 3, 2018.

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