This privacy notice explains how Lender Systems, Inc. (“Lender Systems”) use personal data generated by Lender Systems.

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Lender Systems provides technology and data to help companies maximize the ‘Internet of Things’ ecosystem with end-to-end solutions that span video and vehicle telematics, connected asset management devices and software platforms for applying analytics and machine learning.

 

Data generated by in-vehicle and video telematics services

 

Some of our technology services generate information relating to identifiable individuals (“personal data”), for example, when we provide vehicle telematics services to commercial fleet managers. In general, where this personal data is generated as part of a service we provide, we do not make any decisions about how this personal data is used. That is determined by our customers, and we act entirely under their instructions. If you work for an organisation that uses Lender Systems and want to know more about any personal data it generates about you, the best place to start is by asking your organisation for more information.

The one exception to this is that we sometimes use data generated by our customers’ use of Lender Systems (“Data”) for product improvement and development, and that information may include personal data. This notice explains how we use personal data in these circumstances. We only do this where we have permission from our customers to use Data for these purposes.

 

Data generated by portal users

 

Lender Systems manages access to and use of the Lender Systems portal (the “Application”) to view data generated by our in-vehicle and video telematics services. Lender Systems is the data controller of any personal data which arises out of use of the Application (“Application Data”).

 

What personal data do we process?

 

Our in-vehicle and video telematics services may collect the following types of information, which in some cases may be linked directly or indirectly to individuals:

• Driver identifiers such as vehicle number plate and driver name

• Device information and identifiers, e.g., IP address, cookie IDs, device type, advertising and app identifiers

• User login details, e.g., name, email, contact number, organisation details

• VIN and vehicle serial number

• Technology information, e.g., username, password, browsing activity, advertisements viewed, search terms, content viewed, logs

• Video footage of outside and inside vehicle data

• GPS location data

• Vehicle diagnostic data

• Telemetry, e.g., speed, direction of travel, location or event snapshot/photo

• Driver facial reactions and movements

• If any passengers are present, then such passenger video

 

Data generated by use of the Application

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If you wish to use the Application, we will ask for your business contact details, including name, organisation and email address. We use this personal data to issue and manage access credentials.

When you use the Application, we may collect, use and store information about your device and use of the Application, such as your user ID, IP address, how often you access the application, and the actions you take in the Application.

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What are the sources of personal data?

We collect personal data from the in-vehicle and video telematics services provided to our customers, where we have the permission of our customers to do this.

We also collect information from the use of the Application by our customers.

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What do we use personal data for?

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We use Data to help improve our services, for example, by allowing our artificial intelligence systems to get better at identifying certain types of safety events, or to develop new products and services. It’s not always possible, but where we can, we remove direct identifiers which make it possible to link data to individual drivers. We never use Data to make decisions about you as an identifiable individual — we’re only interested in the information in the context of our products/in what the information tells us about our products.

We use Application Data to manage user credentials and access the Application, to maintain security logs, and to understand how to make the  portal easier to use and navigate and improve.

 

For EU users

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Our lawful basis for using data is our legitimate interest in improving and developing our products and services.

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How and when Lender Systems discloses and shares your personal information

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We may share personal data within the Lender Systems Group or where:

• A Lender Systems Group company or substantially all of its assets are merged into or acquired by a third party, in which case your personal information may be transferred as part of the merger or acquisition;

• We are using vendors, service providers and consultants that need access to personal information in order to perform services for us, for example, hosting and IT service providers;

• We believe that your actions are inconsistent with our agreements or policies, that you have violated the law, or that disclosure is necessary to protect the rights, property, and safety of Lender Systems, our users, the public or others;

• Sharing with our lawyers and other professional advisors is necessary to obtain advice or otherwise protect and manage our business interests; and

• Sharing is otherwise permitted by applicable law, or where we are required by law to do so.

 

Data retention

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We retain your information for 12 months, unless a different period is specifically requested by or agreed with your organisation.

 

Data transfers

 

Data may be transferred to and stored by a third party at a destination inside or outside the European Economic Area.

If we transfer personal information to a third party, we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisational, contractual or other lawful mechanisms, such as standard contractual clauses. Please contact us if you would like more information about these safeguards.

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Your rights and how to exercise them

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If you are a resident in the European Economic Area or the UK, you may have certain rights in respect of your personal data, including:

• The right to object to and/or withdraw consent to the processing of your personal information;

• The right to object to decision-making by a computer, based on your personal information;

• The right to access and/or rectify your personal information; and

• The right to erase, restrict or receive a machine-readable copy of your personal information.

You can contact us about your rights at any time, and your request will be handled free of charge in a timely manner.

Within the EEA you also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns, we ask that you initially contact us at privacy@lendersystems.com so that we can investigate and hopefully resolve your concerns.

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Personal information we collect

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We collect various types of personal information, as explained in the “What personal data do we process?” section above. We collect this information for the business and commercial purposes described in the section above titled “What do we use personal data for?”

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Personal information we share

In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

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Your rights

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Subject to certain limitations, you, or your appropriately-verified authorized agent, have the right to request the following information from us:

• The categories of personal information we collect about you.

• The categories of sources from which your personal information is collected.

• The business purpose for collecting your personal information.

• The categories of third parties with whom we share your personal information.

• The specific pieces of personal information we have collected about you.

Additionally, subject to certain limitations, you have the right to request deletion of your personal information. We will not charge for this service.

We will not discriminate against you if you choose to exercise any of your rights under the California Consumer Privacy Act (CCPA).

If you are a resident of the State of California and wish to exercise your rights under the CCPA, contact us toll-free at (+1)9516932700 or email us at privacy@lendersystems.com. We will ask you to provide information related to your recent interactions with us to help us confirm your identity before we fulfill your request.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please email us at privacy@lendersystems.com.

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Changes to this Privacy Policy

 

This Privacy Policy may be amended by us at any time. Please check this page periodically to inform yourself of any changes. If we make any material changes, we will provide you with additional notice. If you have any questions, need further information about our privacy practices or would like to let us know that your details require updating, please write to us at:

 

Lender Systems, Inc.
43391 Business Park Dr., Suite C4

Temecula, CA 92590

USA