Privacy Policy

1. Introduction

This Privacy Policy of Zenduit Inc. (“Zenduit”) explains what personal information is collected when you are using Zenduit websites, products, and services. If you are using our services on behalf of a legal entity, you claim that you are authorized by the respective legal entity for the use of our Services. We may update this Privacy Policy from time to time and we will inform you
about any such updates if you are in our mailing list. We encourage you to review this Privacy Policy from time to time. You can oppose the Processing of your Personal Information or request more information regarding the Processing of your Personal Information at any time.

2. Definitions

• “Personal Information” means any information which is related to an identified or identifiable natural person. This includes information in any form, such as age, name, email, address, driver’s license, etc.;
• “Processing” means any operation or set of operations that is performed on Personal Information, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
• “Services” means websites, applications, software-as-a-service, mobile applications, and add-ons provided or operated by Zenduit.

3. Policy Application

This Privacy Policy applies to:

• Zenduit website visitors;
• Customers, who entered into agreements with Zenduit (including through Terms of Service or EULA);
• End users: (1) those who are using our Services (for example Customer’s employees); or (2) whose Personal Information we Process on behalf of our Customers (for example vehicle drivers);
• Resellers of Zenduit products;
• Job applicants.

4. Personal Information that we collect

Depending on the Services used, we may collect the following Personal Information:

• Identity information: name, surname, personal details, education, experience, CV, driver identity, and driver license numbers.
• Contact information: phone number, email, company name, position, company industry, company address, fleet size, address, state/province.
• Login credentials: username and password.
• Payment data: credit/debit card information, billing information, payment account, and payment history.
• Technical data: IP address, hardware use data, software use data, device identifiers, device settings, location.
• Statistics data: web pages visited, time when web pages were visited.
• Vehicle data: vehicle identification number, GPS location data, video of vehicle location, and video recorded inside the vehicle cabin.

We collect Personal Information through our websites, applications, and software regulated by Zenduit Terms of Service and End User License Agreement.

5. How do we use Personal Information

We use Personal Information for the following purposes:

• To perform our contractual obligations with you.
• To inform you about our new products and special offers.
• To provide you with our Services and a better user experience.
• To provide you with support and answer your questions.
• To Process employment applications.
• For our legitimate interests/purposes that a reasonable person would consider appropriate in the circumstance.

6. How we protect Personal Information

We take all necessary steps to safeguard and protect your Personal Information. All information transmitted and received by us through our Services is encrypted with the help of software that uses Secure Sockets Layer (SSL). We will put reasonable efforts to maintain the security of and to prevent misuse, loss, unauthorized access, and modification of Personal Information. We do not store Personal Information on devices like USB or CD. All our personnel and contractors are subject to confidentiality agreements. Only authorized personnel have access to Personal Information on a need-to-have basis.

We do not and will not sell or rent Personal Information collected by us to third parties in the ordinary course of business.

7. Transfers of Personal Information

Personal Information is Processed at our operating offices and in any other places where the parties involved in the Processing are located. Zenduit stores Personal Information on cloud servers located in North America and may store data on cloud servers located in other countries from time to time. We may transfer Personal Information as part of our business operations, such as in the sale of business assets, mergers, acquisitions, or reorganization.

8. Sharing of Personal Information

We may share Personal Information with the following third parties:

• Service Providers: These providers may have access to Personal Information only on a need-to-know basis while performing tasks for us or on our behalf.
• Law enforcement agencies and related organizations: When obliged to execute law enforcement requests or requests from courts or agencies, or when we reasonably believe it is required to comply with applicable regulations and laws.
• Internal sharing: Within our group of companies.

9. Access or corrections to personal information

Individuals have the right to access or correct their Personal Information under the Personal Information Protection and Electronic Documents Act (PIPEDA). If you require your Personal Information to be removed from our systems, please contact us at support@zenduit.com.

10. Updating and Removing Personal Information

Personal Information associated with your account may be removed or updated through account preferences. If you require your Personal Information to be removed from our systems, please contact us at support@zenduit.com. Each request will be Processed within 30 calendar days from the date of filing.

11. Processing of children’s Personal Information

We do not knowingly Process any Personal Information from persons under 18 years of age. If you learn or believe that anyone younger than 18 has provided us with Personal Information, please contact us at support@zenduit.com so that we can use reasonable efforts to remove such information.

12. Retention

We will store Personal Information for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy and our contract with you. We will also retain and use Personal Information as necessary to comply with legal obligations, resolve disputes, and enforce agreements.

13. Third-party links

Our websites and Services may contain links to other websites, services, and web addresses. This privacy policy applies only to our websites and Services, not those external websites, services, and web addresses that we link to.

14. SPECIFIC TERMS

14.1. European Economic Area General Data Protection Regulation 2018 (GDPR) based terms

INTRODUCTION. Zenduit Inc., with a registered address at 102-2680 Matheson Blvd East, Mississauga, ON L4W 0A5, Canada shall be considered the data owner and data controller when you contact us. However, when it comes to collecting and Processing Service data or vehicle data, we will act solely as data Processors acting according to our customers’ instructions. In such cases, our customers will act as data controllers, and any requests from data subjects will be redirected to them.

We acknowledge the privacy of natural persons and make efforts to protect them against any unlawful Processing by applying relevant technical and organizational measures to protect the Personal Information of natural persons in accordance with the effective legislation. Although we will make efforts to ensure safe Processing, we cannot guarantee it to be 100% secure and
risk-free.

LEGAL BASIS. Zenduit will Process Personal Information:

1. On the basis of consent collected by us;
2. On the basis of consent to your data controller;
3. 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;
4. Where we have a legal obligation to collect and Process Personal Information and are the controller in respect of such data;
5. Or where the Processing is necessary to protect your vital interests.

RIGHTS OF DATA SUBJECTS UNDER GDPR. EEA-based data subjects are provided with the following rights under GDPR:

• Right to rectification: The data subject shall have the right to obtain from the controller the rectification of inaccurate personal data without undue delay.
• Right to restriction of Processing: The data subject shall have the right to obtain from the controller restriction of processing where one of the provisions set out in Art. 18 GDPR applies.

Right of access: The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed.

• Right to erasure: The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay where one of the provisions set out in Art. 17 GDPR applies.
• Right to object to Processing: The data subject shall have the right to object to the processing of personal data concerning him or her on grounds relating to his or her particular situation.
• Right to data portability: The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The data subject shall have the right to lodge a complaint with a supervisory authority.

EXECUTION OF RIGHTS. Upon request filed pursuant to GDPR requirements, we will provide the information free of charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. The request will be reviewed and addressed within one month of its filing, and the data subject will be informed of any delays.

14.2. California-specific terms based on the California Consumer Privacy Act (CCPA)

This section applies only to consumers based in California, who are subject to the California Consumer Privacy Act (“CCPA”).

PERSONAL INFORMATION HANDLING. Full description of Processed Personal Information is provided in Section 4 of this Privacy Policy. The purposes for which we collect this information are described in Section 5 of this Privacy Policy. The categories of third parties to whom we “disclose” this Personal Information for a business purpose are described in Section 8 of this Privacy Policy. We collect Personal Information from California-based customers’ drivers of vehicles, employees, or other customer-related parties. Zenduit is a business under CCPA and we do not sell Personal Information that we collect. Zenduit may share Personal Information with third parties which are authorized service providers, resellers, or affiliated businesses.

EXECUTION OF RIGHTS. According to CCPA California consumers have the following rights:

• Disclosure of Personal Information: You are entitled to receive information about categories of sources for Personal Information we collected about you and Personal Information we collected about you (also called a data portability request).
• Right to request deletion of Personal Information: You have the right to request the deletion of Personal Information that we collect or maintain about you.
• Right to opt-out of sale of Personal Information: You can request us not to sell your Personal Information. We do not and will not sell your Personal Information.
• Right to non-discrimination: California consumers will not receive any discriminatory treatment when exercising one of their privacy rights.

15. Contact us

If you have any questions or concerns about our Privacy Policy or terms specified herein, please contact us by using the following means:

• Email: support@zenduit.com
• Address: Zenduit Inc., 102-2680 Matheson Blvd East, Mississauga, ON L4W 0A5, Canada