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Privacy policy

Effective Date: March 7, 2022

This Privacy Policy describes how Nexar Inc. and its affiliates and subsidiaries (including Nexar Ltd.) (collectively, “Nexar”, “we”, “us” or “our”) collects, stores, uses, and shares personal data of individuals ("you", or “your”) when you interact with us through one of the following channels:

  1. Your use of our websites (such as https://getnexar.com/ and its subdomains), online ads and content, emails or other communications under our control (collectively, the "Site"),
  2. Your use of our mobile applications (the “App”) or one of our dashboard cameras (“Nexar Beam”, “Nexar Pro”, or “Nexar One”, collectively, our “Cameras”),
  3. or other interaction when placing purchases or otherwise use our online platform via the Site (the "Platform", and together with the Site, App and Cameras – the "Services").

When providing our Services we may process different categories of your personal data depending on your interaction with our Services. Such categories include: individuals that create an account with our Services, either independently or on behalf of our corporate customers or as part of a fleet or a team of drivers (“Users”); individuals that provide us with information through or otherwise interact with the Site (“Visitors”), and; prospective customers, partners and, participants from our events and webinars we may hold (“Prospects”).

Specifically, this Privacy Policy describes our practices regarding:

  1. Data Collection
  2. Data Uses
  3. Data Location
  4. Data Retention
  5. Data Sharing
  6. Cookies and Data Collection Technologies
  7. Communications
  8. Data Security
  9. Data Subject Rights
  10. Roles and Responsibilities
  11. Additional Information and Contact Details

Please read this Privacy Policy and make sure that you fully understand and accept it. If you object to this Policy, please discontinue and avoid using our Services.

You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined in Section 5 below), please avoid any interaction with us or any use of our Services.

1. Data Collection

We collect, generate, or receive personal data regarding our Visitors, Users, and Prospects so that we can provide our Services. Personal data is typically collected and generated through your interaction with our Services, through automatic means, directly from you or from other third-parties. To the extent that such data concerns a non-human entity (e.g., the bank account of a company or business), we will not regard it as “personal data” and this Privacy Policy shall not apply to it.

Specifically, we collect the following categories of data:

(a) Usage Data (about our Users and Visitors)

When you visit, interact with, or use our Services (including communications such as e-mail or text messages sent to you via our Services) we may collect certain technical data about you. We collect or generate such Usage Data either independently or with the help of our Service Providers (as detailed in Section 5 below), including through the use of "cookies" and other tracking technologies (as further detailed in Section 6 below).

Such Usage Data may consist of connectivity, technical and aggregated usage data, such as your ride start and end locations; IP addresses, wireless networks, cell towers and Wi-Fi access points; non-identifying data regarding a device, operating system and browser; activity, communication and performance logs; issues and bugs; and user activity on our Services. Furthermore, frames and videos of interest relating to traffic conditions will be gathered and shared amongst users to help them plan their routes, as well as on our Citystream service, aimed to provide more transparency and knowledge sharing on real-time road conditions.

(b) User Data

If you are a User and sign up for our Services you may be required to provide us with your personal details, such as name, email address, phone number and password (which will be stored in a hashed format). You may also provide us additional information concerning your insurance provider and insurance plan, information on fleet users (as further detailed below and in Section 5), as well as any other data you choose to provide when using the Services, communicate with us for support or other reasons, create or join a team within the App, or when you interact with other team members (as further detailed in Section 5 below). If you choose to make any purchase via our Services, you may also provide us with your billing and shipping details and preferences.

Depending on your usage of the Services, User Data may also include the following:

  • Data received from connected accounts: to the extent you have integrated supported third-party “Single Sign-On” services (e.g., Google or Okta), you may log-in to our Services through such services, in which case we will receive your name, e-mail, user ID, and any other information you choose to share with us via your account on such third-party services.
  • Data received from insurance companies and mobility platforms: in some locations, users may choose to provide us with certain information concerning their insurers and their insurance plans, or have their insurer provide this information directly to us. This may include details regarding the user's plan, characteristics, and the user’s insurance identifiers.
  • Data received from members of your team: if you use the Services to create or join a team of drivers using our App, and interact with those other users through the Services, we may receive additional data from you and other members of this team, through such interactions.
  • Data received from fleet managers and users: you may use the Services to create a fleet of drivers using our App or join a fleet of drivers using our App that is managed by a separate entity or individual (such as your employer) (“Fleet Manager”). When you interact with other drivers of the fleet while using the Services, we may receive additional data from you and other members of this fleet. Please note that if you are using the Services through a fleet that is managed by your Fleet Manager, some portions of your personal data will be processed by us as a data processor on behalf of such Fleet Manager. This may include User Data such as your name, email, and unique fleet identifier assigned to you by the Fleet Manager, as well as other User Content (collectively “Fleet Data”). The Fleet Manager assumes the role of data controller with respect to Fleet Data. For more information about Fleet Data or the role of fleet managers as “data controller”, please see Section 10 below or contact your Fleet Manager directly.
  • You may delete such recordings via the App or the Platform. You must avoid uploading any recordings which may have been made in violation of the laws or regulations applicable in your jurisdiction. For example, in some states it might be illegal to record your passengers or other individuals in public spaces (such as on the street), without their knowledge or consent. We will not be liable or responsible in case you use our Services to make and publish such prohibited recordings.
  • Collision reports: if you submit or otherwise make available to us any recordings concerning traffic incidents, collisions, road conditions or violations, we may analyze such recordings and produce reports, which may be shared with you, your insurer or other third-parties (subject to your authorization) in accordance with Section 5 below. Should you contact us to generate a collision report, you may also provide us with details such as the location and time of the collision, photos, license plates involved, as well as involved parties’ insurance companies and policy numbers. Should you choose to submit such a report to your insurance company through the App, we will be collecting the data to monitor the performance of such a submission.

(c) User Content

When using the Services Nexar will automatically collect User Content Which may include sensor data, location, GNSS location data, data obtained from your device’s gyroscope and accelerometer sensors, and App user ID. Additionally you may also choose to provide us with User Content in accordance with our Terms of Service, and such User Content includes personal data (such as recordings and images captured via the Camera), we may use the personal data included in such User Content for the purposes set forth in Section 2(b) below.

User Content may include images of persons captured via the recordings, license plates, or otherwise personal data recorded via the Camera. However, when we collect images of persons, we make sure that such images are being anonymized, in such a manner that prevents the identification of the individual.

(d) CRM, Visitor & Prospect Data

Personal data relating to our Prospects and Visitors, which we collect or receive automatically when you interact with our Services, ads, communications or other content under our control. Such data may also be provided to us voluntarily by you such through the Contact Us form through the Services. We may also receive CRM, Visitor & Prospect Data from other sources. For example, if you participate in an event, conference or webinar that we sponsor or participate in, we may receive your personal data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or Service Providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities.

2. Data Uses

We process personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services, e.g., in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our customers, users, visitors, prospects, ourselves and our Services (“Legitimate Interests”).

If you reside or are using the Services in a territory governed by privacy laws under which "consent" is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by or via the Services, or due to nature of such processing) (“Consent”), your acceptance of our Terms of Service and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of Consent. If you wish to revoke such Consent, please contact us at privacy@getnexar.com.

Specifically, where we act as ‘data controllers’, we use personal data for the following purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

(a) User Data

To provide, facilitate, operate, and enhance our Services(Performance of Contract; Legitimate Interests)
To provide assistance and support, to test and monitor the Services, or diagnose and fix technological problems(Performance of Contract; Legitimate Interests)
To personalize our Services, including by recognizing individuals and remembering their information when they return to our Services, and to provide further localization and personalization capabilities(Performance of Contract; Legitimate Interests; Consent)
To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties.(Performance of Contract; Legitimate Interests)
To authenticate the identity of our Users, and to allow them to access and use our Services(Performance of Contract; Legitimate Interests)
To contact you with general or personalized service-related messages, as well as promotional messages that may be of a specific interest to you(Performance of Contract; Legitimate Interests; Consent)
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity(Performance of Contract; Legitimate Interests; Legal Obligation)
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose(Legitimate Interests)
To enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties(Legitimate Interests, Legal Obligation)
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards(Performance of Contract; Legitimate Interests; Legal Obligation)
For any other lawful purpose, or other purpose that you consent to(Legal Obligation; Consent)

(b) User Content

To provide, facilitate, operate, and enhance our Services(Performance of Contract; Legitimate Interests)
To provide assistance and support, to test and monitor the Services, or diagnose and fix technological problems(Performance of Contract; Legitimate Interests)
To personalize our Services, including by recognizing individuals and remembering their information when they return to our Services, and to provide further localization and personalization capabilities. (Performance of Contract; Legitimate Interests; Consent)
To train and improve our AI and computer vision algorithms, and to further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties.(Performance of Contract; Legitimate Interests)
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity(Performance of Contract; Legitimate Interests; Legal Obligation)
To create aggregated data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose(Legitimate Interests)
To enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties(Legitimate Interests, Legal Obligation)
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards(Performance of Contract; Legitimate Interests; Legal Obligation)
For any other lawful purpose, or other purpose that you consent to (Legal Obligation; Consent)

(c) Usage Data and CRM, Visitor & Prospect Data

To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners(Legitimate Interests; Consent)
To gain a better understanding on how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others’ user experience and the value they can generate from using our Services, so we could continue improving our products, offerings and the overall performance of our Services (Legitimate Interests)
To contact you with general or personalized service-related messages, as well as promotional messages that may be of a specific interest to you(Performance of Contract; Legitimate Interests; Consent)
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity(Performance of Contract; Legitimate Interests; Legal Obligation)
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose (Legitimate Interests)
To enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties(Legitimate Interests, Legal Obligation)
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards(Performance of Contract; Legitimate Interests; Legal Obligation)
For any other lawful purpose, or other purpose that you consent to(Legal Obligation; Consent)

Please note that we do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).

3. Data Location

We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States, Canada, Europe, Japan, Australia and the United Kingdom, Israel and other locations depending on where you are using our Services and as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Nexar is committed to protect personal data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

Nexar and its subsidiaries are headquartered in Israel which is recognized to be offering an adequate level of protection for the personal data of UK and EEA residents by the European Commission and the UK Information Commissioner’s Office (ICO). We transfer personal data from the EEA and the UK to Israel on this basis. For data transfers from the EEA or UK to countries that are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission. You can obtain a copy by contacting us via privacy@getnexar.com.

4. Data Retention

We retain personal data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, as necessary for allowing our Users' insurers to meet their own obligations or legitimate needs, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at privacy@getnexar.com.

5. Data Sharing

Legal Compliance: in exceptional circumstances we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so and solely to the extent that we believe is strictly necessary to comply, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.

Service Providers: we may engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), data analytics services, mapping services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, billing and payment processing services, e-mail and SMS distribution and monitoring services, session or activity recording services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, support and customer relation management systems, and our business, legal, financial and compliance advisors (collectively, "Service Providers"). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.

We use Shopify as our e-commerce platform. This platform allows us to sell our products online and simplify your user experience. When you access or place an order with Nexar through the online shop, Shopify collects your information, for example for risk and fraud screening. Therefore, whilst Nexar makes use of Shopify, please refer to Shopify’s Privacy Policy.

Insurance Companies and Mobility Platforms: we may notify your selected insurer or integrated mobility platform of probable road collisions involving you and/or third-parties and share with it any related recordings, data and reports by one of two ways: (a) in accordance with the instructions of your insurer, in cases where your use of our Services is part of your agreement with your insurer, and you have granted your insurer authorization to receive such recordings or reports from us; or (b) in the event you have authorized Nexar to do so automatically by either providing Nexar with your insurer and policy details through the App (in which case the “Report to Insurer” feature on the App will become active automatically) or by manually turning “on” the “Report to Insurer” feature on your App (provided that you have previously shared your insurer and policy details with Nexar through the App).

Teams and Fleets: the Services allow you to create and join teams or fleets of drivers using the App. For example, you may create a team consisting of your family members or friends, or a fleet consisting of drivers at your workplace, who are each using the App individually on their mobile device, so that you may interact with each other, share drive recordings or collision reports with each other, etc. Your data will be shared with other members of the teams or fleets you create or join, in accordance with the sharing settings of such team or fleet (which are managed either by each user, or by the team owner or Fleet Manager). We advise you to review the sharing settings for each team you create or are invited to, and adjust your sharing activities accordingly. Fleet Managers gain access and visibility into their fleet’s users’ location data, ride videos (live or post ride), and alerts concerning incidents during the ride. Fleet Managers may also appoint additional administrators for their fleet, who will also gain access and visibility to all or some of this data, depending on the privileges set by the fleet manager. For more information about the role of fleet managers as “data controller” of their fleet users’ data, please see Section 10 below.

Third-Party Websites and Services: our Services may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third-party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites and third-party services. We do not receive or store your passwords for any of these third-party services.

Protecting Rights and Safety: we may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Nexar, any of our users or any members of the general public.

Nexar Subsidiaries and Affiliated Companies; Change of Control: we may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Nexar or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant and/or a potential investment, personal data may be shared with the parties involved in such an event. If we believe that such an event might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

For the avoidance of doubt, Nexar may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

6. Cookies and Data Collection Technologies

We and our Service Providers use “cookies” and other technologies for performance, tracking, analytics and personalization purposes. We may share non-identifiable/aggregated extracts of such information with our partners for our legitimate business purposes.

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 use both types. We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.

Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services. To learn more about our cookie practices, please visit our Cookie Policy.

We use Google Analytics to collect information about the use of our Services. Google Analytics collects information such as how often users visit the Services, which pages they visit when they do so, and which other sites they used prior to coming to our Services. We do not merge the information collected through the use of Google Analytics with personally identifiable data. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt-out of these analytics services is available here.

Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

7. Communications

We engage in service and promotional communications, through e-mail, phone, SMS and notifications.

Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset instructions, etc. You can typically control your communications and notifications settings from your Nexar user profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).

Notifications and Promotional Communications: we may send you notifications concerning messages and other updates in your user account (such as messages concerning collision reports, road conditions etc.). We may also send you notifications about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. SMS, phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify Nexar at any time by sending an e-mail to: privacy@getnexar.com, changing your communications preferences in your user profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

8. Data Security

We and our hosting services implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, confirmed also by Nexar’s ISO/IEC 27001 and 27018 certifications. However, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties.

9. Data Subject Rights

If you wish to exercise your privacy rights under any applicable law, including (to the extent applicable) the EU or UK General Data Protection Regulation (GDPR or UK GDPR, respectively) or the California Consumer Privacy Act (CCPA), such as the right to request access to, and rectification or erasure of your personal data held with Nexar, or to port such personal data, please log into the Platform, and select either the “Export” or “Delete” options in your account dashboard settings.

If you wish to exercise your right to restrict or object to such personal data’s processing, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at: privacy@getnexar.com. If you are an individual subject to the GDPR/UK GDPR, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.

Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.

10. Roles and Responsibilities

Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

By default, Nexar is the “data controller” of User Data, Usage Data, personal data included in User Content, and CRM, Visitor & Prospect Data. With respect to such data, we assume the responsibilities of the data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, to the extent our Service Providers process such data, the relevant Service Provider will assume the role of “data processor”.

When Nexar provides the Services to a fleet, Nexar is the “data processor” of Fleet Data. With respect to such data, the respective Fleet Manager assumes the responsibilities of data controller, and as such directs and instructs us how and for what purposes to process such data.

Accordingly, when Nexar processes Fleet Data as a data processor, it will do so strictly in accordance with the relevant Fleet Manager’s reasonable instructions and as further stipulated in our Data Processing Addendum or other commercial agreements we have entered into with such Fleet Manager. The Fleet Manager, as controller of such data, will be responsible for meeting any legal requirements applicable to data controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).

For the avoidance of doubt, each Fleet Manager is solely responsible for providing adequate notice to their users – including sufficient reference to the processing of their personal data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.

11. Additional Information and Contact Details

Updates and amendments: we may update and amend this Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Sites, Platform and/or Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: while our Sites, Platform and/or Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Sites, Platform and/or Services for the website or application of such third-parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Sites, Platform and/or Services.

Our Services are not designed to attract children under the age of 16: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Sites, Platform and/or Services, we will attempt to prohibit and block such use and will make all efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at privacy@getnexar.com.

Questions, concerns or complaints: if you have any comments or questions about this Privacy Policy or if you have any concerns regarding your privacy, please contact us at privacy@getnexar.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.

EU and UK Representative: We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact in the EU and UK. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/13925556347