This privacy policy (“Policy”) applies to those instances where, with respect to personal data collected from you, Geotab Inc. (together with its affiliates, collectively, “Geotab” or “we”, “our”) is the “controller” and does not apply where Geotab is a “processor” of personal data or to the privacy practices of any third party under any circumstances. This Policy applies to all Geotab entities except where a Geotab affiliate has published its own separate privacy policy.
As used in this Policy, the terms “controller” and “processor” have the definitions given to those terms in the EU General Data Protection Regulation and “personal data” means any information that relates to an identified or identifiable individual or as otherwise defined by an applicable data protection law or regulation. The concepts of “controller” and “processor” are analogous to the concepts of “business” and “service provider”, respectively, under the California Consumer Privacy Act and other applicable data protection laws that use similar terminology.
In the context of Geotab’s business activities and its products, Geotab is a “controller” where it determines the purpose(s) for which personal data is collected and the means for which it is used as outlined in this Policy.
Geotab is a “processor” where it processes personal data on behalf of end customers of Geotab’s products and services. Accordingly, if you are looking for information about personal data collected from you in connection with Geotab’s products and services, please refer to the relevant controller’s privacy policy. The relevant controller may, for example, be your employer if they are an end user of Geotab products and services. In addition, please refer to Geotab’s Product Privacy Notice which outlines Geotab’s processing practices where it processes your personal data at the instruction of the applicable controller.
In its capacity as a controller, Geotab uses certain personal data that it collects or that you provide directly when you interact with Geotab as outlined below.
Means | Description | What Personal Data Does Geotab Collect? | How Does Geotab Use the Personal Data? |
Website and Forms | Any website that Geotab operates and which displays or links to this Policy, such as www.geotab.com, to the extent you interact with it, such as accessing a white paper, commenting on a blogpost, or participating in surveys, contests, or promotions. | Depends on the nature of your interaction with Geotab’s website, but may include name, address, job title, email address and any other personal data you choose to include in your comments. | To facilitate your interaction with the Geotab website and present the website and its content to you. To provide you with information, products, or services that you request from us. |
Geotab Marketplace | Geotab Marketplace provides access to customized applications, solutions and other add-ons through mobile apps, third party integrations, business services, and other products. | To offer a product or service on the Marketplace, a Marketplace Partner representative must create an account and provide certain personal data such as name, address, phone number and email address. | To facilitate the listing of your product or solution on the Marketplace, if you are a Marketplace Partner. |
Direct Marketing | Marketing activities to promote Geotab’s products and services. | Personal information you choose to provide when you interact with Geotab at an event, through a survey or other means, including the following:
| Sending Promotional Communications: Including emails, text messages, postal mail, and social media messages, about our products, services, promotions, events, and news that may be of interest to you. Personalizing Marketing Content: Tailor our marketing messages and advertisements to better suit your preferences and interests, based on the information we have collected about you. Conducting Market Research: Gather feedback and insights about our products, services, and marketing efforts to improve our offerings and customer satisfaction. Analyzing Marketing Campaigns: Evaluate the effectiveness of our marketing campaigns and strategies to enhance future marketing efforts. |
Geotab ITS | The Geotab ITS service uses aggregated and anonymized data, and datasets derived therefrom, to allow customers to make informed decisions for safer, more sustainable and efficient transportation systems. Customers access ITS data through the Altitude software platform. | Personal data required to create an Altitude account, such as name, address, phone number, business title and email address. | To facilitate account creation in Altitude and your use of the Geotab ITS platform generally. |
Inquiries | Responding to your inquiries and conducting Geotab’s business operations. | If you contact us via the “Contact Us” form on the Geotab webpage or other means, you may be requested to provide certain personal data such as your name, email address, phone number and job title. | Responding to your inquiry. |
Operations | Conducting Geotab’s business operations. | Geotab employs video cameras for security purposes at its office locations. If you visit one of our office locations, Geotab may capture your image through a security camera. | Ensuring the security of our premises and operations. Any images of you will not be stored for more than 7 days or any shorter period required by applicable law. |
Additionally, Geotab may use your personal data to investigate and prevent fraudulent transactions, unauthorized access to the Geotab solution, and other illegal activities.
Geotab may also use personal data for any other purpose for which we have obtained your consent or where permitted or required by applicable law.
Where required by law, we or, if applicable, our service provider, will obtain your consent before using your personal data for direct marketing purposes, whether express or implied. You have the right to opt-out of receiving direct marketing communications from Geotab at any time, and you can do so by clicking the "unsubscribe" link in any marketing email you receive from us, following the instructions provided in any other type of marketing communication you receive from us, or otherwise contacting us directly at marketing@geotab.com. Geotab sells its products in part through a network of authorized sales partners and we may share your personal data with these sales partners for direct marketing purposes.
Geotab employs or may in the future employ data systems, software, hardware, applications, tools, or utilities that operate in whole or in part using artificial intelligence (collectively, “AI Systems”). These AI Systems may leverage advanced AI systems capable of generating content (which is new or novel), rather than simply analyzing or acting on existing data (i.e. “generative” AI).
When you engage with an AI System, we may use your personal data as follows:
Any personal data processed by an AI System is handled in accordance with our broader privacy practices, as outlined in this Policy. Geotab is committed to responsible use of AI, being the development, deployment, supply and use of AI Systems in a way that upholds the principles of trustworthiness, accountability, and equity through the AI lifecycle and value chain. In particular:
Geotab collects, stores and uses personal data about its employees and former employees in accordance with the Geotab HR Data Acceptable Use Policy. In addition to the HR Data Acceptable Use Policy, employees may receive additional privacy notices depending on their jurisdiction of residence in accordance with applicable data protection laws.
Geotab’s legal basis for processing the personal data it collects and/or receives from you depends on the context in which it is provided:
Geotab, or its authorized service providers and/or subprocessors, may anonymize or de-identify your personal data to ensure that it no longer qualifies as personal data. Once anonymized or de-identified, your data will be used strictly for statistical, research, or operational purposes. Anonymization and de-identification processes are performed in such a way that the data can no longer be used to identify you directly or indirectly. Once your personal data has been anonymized or de-identified, it cannot be reversed, and it will no longer be subject to the same privacy protections under applicable laws.
For the avoidance of doubt, this Policy does not apply to the collection, use or processing of your personal data by third parties. For example, the Geotab website and marketing communications sent by Geotab may contain links to other websites that are operated by third parties. This Policy does not apply to those websites and Geotab recommends that you review the privacy policies and statements of any third-party websites to properly understand their information practices.
In addition, if you acquire, subscribe to, or download an application advertised on Geotab Marketplace, please refer to the privacy documentation and practices of the applicable Marketplace Partner. By using any Geotab Marketplace application, you acknowledge that your personal data may be processed and/or stored outside of the MyGeotab application and the Geotab environment by a third party.
Geotab may engage third-party service providers to process personal data on its behalf ("Subprocessors"). Subprocessors are selected based on their ability to provide the necessary safeguards and security measures to protect personal data in compliance with applicable data protection laws. Before engaging any Subprocessor, Geotab conducts a thorough assessment to ensure they comply with applicable privacy laws. We maintain an updated list of Subprocessors and their functions, which is available upon request. Geotab ensures that any Subprocessor it engages only processes personal data in line with Geotab’s documented instructions and implements appropriate technical and organizational measures to ensure the security of personal data.
Geotab may disclose the personal data that we collect or you provide as described in this Policy in the circumstances described below:
Geotab primarily stores personal data on servers located in North America, Europe and Asia, but may also utilize servers located in other regions from time to time for load balancing and other purposes. Accordingly, your personal data may be transferred to a country where the data protection laws do not provide a level of protection equivalent to the laws in your jurisdiction. However, when Geotab transfers your personal data, we do so in compliance with applicable data protection laws by ensuring your personal data is afforded an adequate level of protection using the following means, where appropriate:
Geotab will retain your personal data for as long as needed to fulfill the purposes for which the personal data was provided or collected. Geotab will delete or anonymize your personal data when we no longer have a legitimate interest in retaining it or otherwise in compliance with applicable data protection laws. If it is no longer reasonably possible to delete your personal data because, for example, it has been archived, Geotab will securely store the personal data and isolate it from further processing until deletion or anonymization is possible.
Geotab has established appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Under applicable data protection laws, you have certain rights regarding your personal data. Your rights and how you can exercise them are outlined below. Geotab is committed to respecting and facilitating these rights.
To exercise any of your rights please contact us using our Data Subject Request Form. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We aim to respond to all legitimate requests within one month. However, it may take us longer if your request is complex or if you have made multiple requests. In this case, we will notify you and keep you updated.
Geotab does not sell your personal information for monetary compensation. However, privacy laws, including California Privacy Laws, the Colorado Privacy Act, the Virginia Consumer Data Protection Act, the Connecticut Data Privacy Act, the Utah Consumer Privacy Act and the Nevada Privacy Law broadly define "sale" to include other types of data sharing, such as sharing personal information with third parties in exchange for valuable consideration (for example, the use of third-party advertising cookies). For more information, please refer to our Cookie Policy. You can submit an opt-out request by using our Data Subject Request Form. Once we receive your opt-out request, we will process it as soon as possible, but no later than 15 days from the date we receive the request. If you are an authorized agent submitting an opt-out request on behalf of a California resident, please include proof of your authorization to act on behalf of that resident. We may request additional information to verify your identity and authorization.
We do not sell the personal information of minors under 16 years of age without affirmative authorization. Geotab does not collect, and therefore does not use, disclose, sell or share, any “sensitive personal information” as defined by California Privacy Laws in its capacity as a controller.
Our products, services and website are not directed toward minors under the age of 16. If you are under the age of 16, do not submit any personal data to Geotab. If you have reason to believe that Geotab may have been sent the personal data of a minor under the age of 16, contact us at legal@geotab.com and we will use reasonable efforts to delete such information. If we otherwise learn that we have collected personal data of a minor under 16 we will take steps to delete such information from our records as soon as possible.
If Geotab makes any changes to this Policy, we will post an updated policy on our website. You should periodically review the Geotab website for any updates. The updated Policy will become effective as of the date stated in the Policy.
If you have questions about this Policy or about Geotab’s privacy practices, you can contact us by email at legal@geotab.com or at:
Geotab Inc.
Attn: Chief Privacy Officer
2440 Winston Park Dr.
Oakville, Ontario, Canada L6H 7V2
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. Translations of this Policy into language in which we offer our products and services can be provided upon request.