Revisions to this Driver Privacy Policy (version 1.16)

As our products and services develop, we may update this Privacy Notice. You should refer back to this website (Driver Privacy Notice) from time to time to view the latest Driver Privacy Notice.

Receiving updates to this Driver Privacy Policy

If you would like to receive an email notification whenever this policy is updated, click the link below and complete the form.

Quick Overview

If you’re reading this Driver Privacy Notice, then you most likely have a Trakm8 or RoadHawk telematics device or dashcam fitted in your vehicle.

Typically, this is because you drive a company vehicle of some description or because it is a requirement of your insurance policy. There may also be some instances where a Trakm8 device is in a car that you’ve leased or hired, or you may even have chosen to put the device in your own vehicle for your own benefit.

Where the telematics device is a requirement of your insurance, then the Insurance Company will be the Trakm8 Customer and you will be the End User.
Where the telematics device is fitted on behalf of your Employer, then your Employer will be the Trakm8 Customer and you will be the End User.
Where the telematics device is fitted to a vehicle you have leased or hired, then the Lease or Hire Company will be the Trakm8 Customer and you will be the End User.
Where you have chosen to fit a device into your own vehicle for your own benefit, then you will be both the Trakm8 Customer and the End User.

The Trakm8 Customer has contracted Trakm8 to deliver our Telematics Service which involves Trakm8 tracking your journeys and collecting various other information from your vehicle which we will then make available to the Trakm8 Customer.

Depending on how the Trakm8 Customer has set up the system, you may also have access to this information as the End User.

To find out about how Trakm8 Customers use the Telematic Data we provide and for what purposes, then you should speak with them directly for more details.

What Data does Trakm8 collect?

In simple terms, Trakm8 may obtain your Personal Information directly from yourself or the Trakm8 Customer, from our Telematics Devices, and via our web-based portals and Apps .

The Trakm8 Customer will typically provide us with certain information in order to set up our service. This is typically basic contact information relating to drivers such as your name, email address and mobile phone number. We will also receive information relating to the vehicle such as make, model and registration.

If we are performing the installation, we will also collect information such as your name, vehicle details and the location, date and time at which the installation will be performed. This data will be shared with our Installation Partners to allow them to manage and undertake the installation.

Once fitted, our telematics devices allow us to collect various journey information such as date, time, GPS location and speed. We may also collect other data such as acceleration, braking and cornering information which allows us to create a Driver Behaviour Score for your driving.

We will collect data relating to any impact or collision that you might experience and may also collect diagnostic data which helps us to alert our Customers and/or End Users of opportunities for preventative maintenance.

.It is important that you are aware that, once a Telematics Device is installed in your vehicle, data will be collected every time you use your vehicle.

It is also important that you ensure any other person allowed to drive or use the vehicle (referred to as Nominated Driver or Associated Person) is informed that a Telematics Device is present in the vehicle and that data will be collected.

Nominated Drivers or Associated Persons should be advised of this policy and should be provided with a copy or information on how they may access and read this notice.

Further detail of the types and categories of information that we collect can be found later in this Driver Privacy Notice (Privacy Notice – Detailed Information)

What do we do with the data?

When we collect Telematics Data from your vehicle, the primary purpose is to provide that data to the Trakm8 Customer so that they can use it for their own purposes.

We may also use the Telematics Data for our own Research and Development purposes but we will remove any identifying information such as names or vehicle registrations before we do that.

Depending on who the Trakm8 Customer is, they will use the Telematics Data for different purposes. For example:

Insurance companies generally use the Telematics Data to understand how you drive which then helps them to make sure that you are on the most appropriate policy. It also helps them manage your policy during its term. They may also use the data to support any claims that are made or to contest claims made against you.
Employers generally use the Telematics Data to manage their fleet in some way. This may be as simple as using the Telematics Data to monitor Business and Private mileage for expense purposes or it may involve a more detailed tracking of vehicle location in order to optimise fleet vehicle use and use the optimum delivery routes and schedules.
Lease / Hire Companies generally use the Telematics Data to monitor mileage and to receive alerts when vehicles should be serviced and maintained.

To find out details about how Trakm8 Customers use the Telematics Data we provide to them and for what purposes, then you will need to speak with them directly.

Who do we share your data with?

As mentioned above, we will share some of your Personal Information and Telematics Data with the Trakm8 Customer who is the organisation that has contracted Trakm8 to deliver the Telematics Service.

We will also share Telematics Data with other organisations who help us to deliver our Telematics Service. These organisations are referred to as Processors and are only permitted to use your Personal Information and Telematics Data for the delivery of the Telematics Service to the Trakm8 Customer(s).

Processors may include our Installation Partners (where a device requires a professional installation) or may be other Service Providers such as Amazon Web Services or our Out of Hours Support provider.

Further detail of all Processors that we use for the delivery of our Telematics Services can be found here: Trakm8 Telematic service provision processors.

In addition, there may be limited instances where we also share your Personal Information and Telematics Data with:

companies that the Trakm8 Customer has instructed us to share Telematics Data with;
companies assisting us in our support and troubleshooting activities;
companies assisting us in our marketing, advertising and promotional activities;
third party payment processors in relation to credit/debit card payments;
fraud prevention agencies if false or inaccurate information is provided to us as part of your use of our services or otherwise, and fraud is identified or suspected;
credit reference agencies, fraud prevention agencies, payment processors, suppliers of technical and support services, insurers, logistics providers, manufacturers and cloud service providers, debt collectors, our legal and other professional advisors, including auditors;
if we are under a duty to disclose or share your Personal Information and Telematics Data in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers; and
when we restructure or sell our business or its assets or are subject to a merger or re-organisation.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Your Rights – Controlling your Personal and Telematics Information

Under Data Protection Legislation, you have the right to:

Request a copy of the Personal Information and Telematics Data that we hold about you;
Request details of any other party we share that data with;
Request that we correct your Personal Information when it is incorrect, out of date or incomplete;
Request that we erase your Personal Information
Request that we restrict the processing of your Personal Information
Request a copy of your Personal Information in order to reuse for your own purposes across different services.
Object to the processing of your Personal Information
Request that we stop using your Personal Information for direct marketing communications.
Request that we stop any consent-based processing of your Personal Information after you withdraw that consent.

Making and Dealing with Requests

Any requests relating to this Telematics Service and your Telematics data will be handled jointly between Trakm8 and the Trakm8 Customer.

Requests relating to your Personal Information and Telematics Data should be made to the Trakm8 Customer in the first instance – details of how to do that will be included in the relevant Privacy Notice provided by the Trakm8 Customer.

For those Customers who are directly contracted with Trakm8, please send your request directly to Trakm8 using the details set out below.

Your right to withdraw consent.

In the rare circumstance that Trakm8 are processing your Personal Information and Telematics Data on the basis of your consent, then you have the right to change your mind at any time and withdraw that consent.

Withdrawal of consent should be communicated directly with the Trakm8 Customer who will assess and inform Trakm8 of the outcome of that assessment.

Right to Erasure

You may request that your Personal Information and Telematics Data is deleted. This is known as a Request for Erasure and such requests should be made directly to the Trakm8 Customer.

Please be aware that the Right to Erasure is not an absolute right and it may be decided that your Personal Information and Telematics Data cannot be deleted as it is needed for a genuine reason.

If the Trakm8 Customer decides they cannot delete your Personal Information and Telematics Data, they should explain that decision to you and why they decided the information needed to be retained.

Right to have your data corrected

Should there be an error in your Personal Information, then you may request that the data is corrected. This typically applies where there is an error in your name, other personal details or in your vehicle information. It does not typically apply to the Telematics Data itself as that has been collected directly from your vehicle and the Trakm8 Telematics device.

As with other requests, requests to rectify or correct your Personal Information should be submitted to the Trakm8 Customer to assess and action.

Checking your identity

To protect the confidentiality of your information, we may ask you to verify your identity before proceeding with any request you make under this Privacy Notice or with any Support Request that you make.

Trakm8 will normally accept the following forms of ID as proof of identity: a copy of your driving licence, passport, national ID card or in some instances photographic ID cards issued by your employer.

We may also request that the Trakm8 Customer assists us in verifying your identity.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

How to Contact Us

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

There is more detailed information here: Privacy Notice – Detailed Information

If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:

Email us at: Privacy@trakm8.com

Or write to us at:

Data Protection Officer

Trakm8

Roman Park

Roman Way

Coleshill

West Midlands

B46 1HG

Contacting the Regulator

If you feel that your Personal Information has not been handled correctly or you are unhappy with the Trakm8 Customer’s (or Trakm8’s) response to any requests you have made regarding the use of your Personal Information, then you have the right to lodge a complaint with the Information Commissioner’s Office.

The Information Commissioner’s Office can be contacted via telephone on 0303 123 1113 or online at www.ico.org.uk/concerns

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

Privacy Notice – Detailed Information

Registered Office

Trakm8’s registered office is:

4 Roman Park, Roman Way, Coleshill, West Midlands, B46 1HG

Company number 04415597

Trakm8 Controller / Processor status

Depending on the specific contractual agreement in place with our Customer, Trakm8 may operate as either a Controller and/or a Processor under Data Protection Legislation.

The Trakm8 Customer will always be a Controller under Data Protection Legislation.

How and when we obtain your Personal Information

Trakm8 may obtain your Personal Information directly from yourself or the Trakm8 Customer, from our Telematics Devices, and via our web-based portals and Apps.

It is important that you are aware that, once a Telematics Device is installed in your vehicle, data will be collected every time you use your vehicle.

Nominated Drivers or Associated Persons should be advised of this policy and should be provided with a copy or information on how they may access and read this notice.

Initial Registration for Service

When you or the Trakm8 Customer registers for our telematics service, we will typically collect such Personal Information as may be required to set up and deliver that service.

This will typically be a basic level of information such as:

Driver(s) name
Contact details (telephone, email, address)
Vehicle registration(s)
Vehicle make, model and year.
Proof of identity

In addition, we may collect information relating to the Trakm8 Customer which may include such Personal Information as:

Trakm8 Customer name
Trakm8 Customer address
Trakm8 Customer billing information such as billing address, bank account and sort code
Administrator details (name, contact details etc.)
Driver details (name, contact details, allocated vehicle etc.)
Insurance policy number

Note that this information may be collected directly from End Users or may be provided to Trakm8 by the Trakm8 Customer.

Installation of Telematics Devices

Where the Telematics Device requires professional installation, we will collect Personal Information from yourself or the Trakm8 Customer to allow for the installation to take place.

This information may include such items as:

Contact Name and Details (telephone number, email, address etc.)
Vehicle Registration
Installation site or address

We typically share this information with our Installation Partners, so they are able to install the device in an efficient and effective manner.

A full list of our Installation Partners may be located on our website: Trakm8 Installation Partners

Use of Telematics Device

Once the Telematics Device has been installed and activated, it will record and analyse Telematics Data relating to the vehicle to which it has been fitted. It is important that you are aware that, once a Telematics Device is installed in your vehicle, Telematics Data will be collected every time you use your vehicle.

The Telematics Data collected by the Telematics Device will depend on the services being supplied and the type of device that has been fitted but may include:

Dashcam Data
- Image Data
- Audio Data
- GPS positions
Telematics Data consisting of:
- Journey data
  - GPS Location (Journey start / journey end positions / GPS waypoints)
  - Speed
  - Date
  - Time
  - Acceleration/deceleration rates
  - Cornering data
- Diagnostic Data
  - On Board Diagnostic Data –all raw, unprocessed data available at a Vehicle or plant’s J1962 diagnostic socket (as specified under the European On-Board Diagnostic standards)
  - Diagnostic Data – refined data which is derived from the On-Board Diagnostic Data
FNOL Data – first notification of loss whereby an alert is generated following a suspected crash event and the relevant Dashcam and/or Telematics Data is preserved for later use.
Driver Profile Data – the scoring output from the Trakm8’s driver profiling algorithm based on Telematics Data and defined system thresholds.

This Telematics Data is processed and stored on Trakm8 servers and will be shared with the Trakm8 Customer. The extent of the Telematics Data that is processed will depend on the extent of the Services we are providing to the Trakm8 Customer,

To find out details about how Trakm8 Customers use the Telematics Data we provide to them and for what purposes, then you will need to speak with them directly.

When you use one of the Trakm8 apps

When you access a Trakm8 App via a mobile device, we will process data about your device as well as your device location and settings.

Device location is required for the ‘Find my Car’ function – location data processed for this purpose is used locally by the App and is not transferred from the device.

Device location is also required to support the Incident Reporting function and to assist in Bluetooth and/or Wi-Fi connectivity.

Granting permission to use Location Data is necessary for the Apps to operate correctly.

We may also collect Personal Information that you enter into the App such as the type of journey (e.g. Business or Private) or when you correct or update Vehicle details. This information will be passed on to the Trakm8 Customer as part of the Services we are providing to them.

To find out details about how Trakm8 Customers use the Telematics Data we provide to them and for what purposes, then you will need to speak with them directly.

Insight AI Assistant

Note that the Insight AI Assistant is available for Insight Enterprise level customers only.

No Personal Data is shared with the Open.AI service and no submitted data will be used by the Open.AI model for training the underlying AI model. OpenAI will retain submitted data for a maximum of thirty (30) days, after which it will be deleted.

Transfers of data to the US will take place using the UK International Data Transfer Addendum to the EU Commission Standard Contractual Clauses.

Road Speed Database and Intervention Module

Our road speed database and intervention module provides an additional level of confidence that speeding events generated by the system are valid.

We do this by manually reviewing speeding events against our Road Speed Database to ensure that the correct speed limits are being applied.

As part of this service, we may share your data with our Service Partners in order to deliver the service.

Where we do share speeding data with our Service Provider, we will remove or mask any personal data fields that are not strictly required to validate the speeding event.

Use of Route Optimisation

When you use our Optimisation services, we will collect relevant information to allow an optimised route to be calculated. The exact information to be processed will depend on the extent of the Services we are providing to the Trakm8 Customer, but may include information such as:

Driver Data (allocated Vehicle, start/finish times, working hours etc.)
Vehicle Data (registration, make, model, capacity, weight limits etc.)
Delivery or Order Data (order number, delivery address, planned dates/times, weights/size of delivery etc.)
Depot Data (depot name, location, opening hours etc.)

We will use this information to calculate optimised routes based on the size and capabilities of the Trakm8 Customer fleet and to help ensure that vehicles & drivers across the complete operation are utilised to make delivery or service schedules as efficient as possible.

If you also utilise our Electronic Point of Delivery (EPOD) services, we may also collect:

Customer signature
Proof of delivery photos

What data do we collect when you use our Support Services?

Where you contact our Customer and Technical Support teams for any reason, we will collect such information as may be required to deal with and respond to your enquiries.

This information may include such items as:

Driver Name(s)
Administrator Name and Details (e.g. telephone number, email)
Organisation Name and Details (name, address etc.)
Vehicle Registration(s)
Details of the Support enquiry

Where you contact us using our Out of Hours support service, they will collect the data to share with us.

How and why we use your Personal Information

We use your Personal Information for the following purposes:

For account set-up and administration, billing and payments
For device installation(s) / de-installation(s) / Service Calls
For performing our contract(s) and delivering the service(s)
For essential communications such as password resets and service notifications
For providing technical and customer support
For internal R&D to enhance our products and services.

Note, that Trakm8 may aggregate and anonymise location and/or driving behaviour for statistical or business purposes. All aggregated and anonymised Data is the property of the Trakm8 where it does not constitute Personal Data.

Essential Communications

From time to time, we will need to send Essential communications relating to our service. These will be delivered to registered users either via email or SMS using the email address or mobile contact details that you or the Trakm8 Customer provided as part of the initial registration.

Essential communications might include reminders to install your device, password resets, service notifications of planned maintenance or reminders to return your device once the service is terminated.

It is not possible to opt-out of these communications as they are essential to the service being offered.

Those users nominated as Administrators will also receive additional emails intended to assist in ensuring that the system is correctly set up and configured.

Profiling – Driver Behaviour Profiles / Scores

Trakm8 systems allow Driver Behaviour to be analysed and scores to be generated based on recorded Telematics Data and other publicly available data such as speed limits. The calculation of Driver Behaviour Scores may be a form of profiling under Data Protection legislation.

Driver Behaviour Scores are calculated using a combination of recorded Telematics Device data, speed limit or similar data and system thresholds that may be defined within our systems by the Trakm8 Customer. These thresholds typically relate to legal speed limits (speeding events), acceleration rates (harsh acceleration events), deceleration rates (harsh breaking events) or other driving behaviours (such as harsh cornering).

Trakm8 does not use the Driver Behaviour Scores for any form of automated decision making.

Where we are contracted to calculate Driver Behaviour Scores, these will be passed directly from Trakm8 to the Trakm8 Customer for their subsequent processing and use.

Trakm8 does not control or define the use of Driver Behaviour Score Data by the Trakm8 Customer and you should contact the Trakm8 Customer directly for further information on their use of this Data.

Enquiries relating to Driver Behaviours Scores and whether / how it is used by the Trakm8 Customer should be directed to the Trakm8 Customer in the first instance.

Lawful Basis

Trakm8 and its partners will collect, process and use personal data collected by the Telematics Device and will pass this information to the Trakm8 Customer on the basis of our Legitimate Interests of providing the Telematics Services.

Trakm8’s Legitimate Interests include:

to run, grow and develop our business;
to administer our contracts with our customers;
to make and receive payments.
to provide goods and services to our customers;
to provide support for our goods and services;
marketing, market research and business development.
to prevent fraud or other criminal activity

Please note that the Trakm8 Customer will have determined their own, separate lawful basis for their collection, processing and use of Personal Information and the subsequent collection, processing and use of the Personal Information provided by Trakm8.

Enquiries relating to the Trakm8 Customer’s lawful basis for processing Personal Information should be directed to the relevant individual within the Trakm8 Customer’s organisation responsible for data protection and/or fleet related matters.

Retention Period

Typically, Trakm8’s retention periods for Telematics Data are determined by reference to Trakm8’s own retention policies or otherwise defined by the Trakm8 Customer as part of the contractual agreement and in order to reflect the Trakm8 Customer’s legal and organisational requirements.

To find out details about the retention periods for your data, you should contact the Trakm8 Customer and speak with them directly.

The length of time Trakm8 retains Personal Information will depend on the purposes for which it collects and uses it, or as required to comply with applicable laws, or to establish, exercise or defend our legal rights. However, Trakm8 only keeps your Personal Information for as long as is necessary for the purposes for which the Personal Information is used, processed or required.

Trakm8 may retain Personal Information for a longer period where it deems it necessary to reflect its own legal and organisational requirements. For example, Trakm8 may need to retain elements of your Personal Information for 7 years in case of any investigation by the tax authorities.

Further information on Trakm8’s retention periods for specific items of information can be obtained by contacting the Trakm8 Customer’s Data Protection Officer.

International Transfers

Where your Personal Information or Telematics Data is transferred, or potentially made available outside of the UK/EEA, we undertake due diligence on the entity accessing or receiving your Personal Information to ensure that they have put in place appropriate technical and organisational measures to protect and secure your Personal Information.

If we do transfer your information outside the UK/EEA we will take appropriate steps to protect that information, which include:

transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Secretary of State and/or the European Commission
transferring your personal data to recipients who are registered with the EU-US Data Privacy Framework and/or the UK Extension to the EU/US Data Privacy Framework
entering into an agreement with the recipient, which includes the UK international data transfer addendum and/or standard contractual clauses that the UK Secretary of State and/or the European Commission has determined offer adequate protection for your information.
entering into an agreement with the recipient who have Binding Corporate Rules (BCR) in place that have been approved by the UK Secretary of State/ICO or an EU competent Supervisory authority.

Trakm8 Telematic service provision processors

Trakm8 uses the 3rd Party companies below for delivery of our telematics services. There are some instances where this may include the processing of End User Personal and Telematics Information or the ability to access End User Personal and Telematics Information.

Trakm8 ensures that each of these processors is subject to contractual obligations ensuring that appropriate technical and organisational measures are in place to ensure any processing of End User Personal and Telematics Information is protected to the standards required by applicable data protection laws.

Where Trakm8 act as a Processor for our Customer, the 3rd Parties below act as sub-processors and will only process Customer Personal information in accordance with Trakm8 Customer instructions (as communicated by Trakm8).

Processor / Sub-Processor	Applicable Service(s)	Subject matter	Nature and purpose of processing	Location(s) of processing	External links for additional information relating to security
Action 365	Road Speed Database and Intervention Module	Personal Information contained within Speeding Events	Use of Road Speed Database for validation of speeding events	UK	N/A
AWS	All services	Personal Information contained within Telematics Data	Infrastructure Provider providing hosting services, storage and network services	Ireland	Compliance Programs – Amazon Web Services (AWS) GDPR – Amazon Web Services (AWS)
AWS (DR site)	All services	Personal Information contained within Telematics Data	Infrastructure Provider providing hosting services, storage and network services	Germany	Compliance Programs – Amazon Web Services (AWS) GDPR – Amazon Web Services (AWS)
Daisy	All services	Personal Information contained within Telematics Data	Hosting / network	UK	Best Practice Certifications and Compliance \| Daisy UK
Esendex	All services	IMEI of device (can be linked to driver)	Sending of SMS service messages to devices	UK	https://www.esendex.co.uk/information-security-statement/ FAQs \| Esendex UK
Esendex	All services	Personal Information necessary for delivery of SMS messages Personal Information contained within SMS message(s)	Sending of SMS service messages to End Users (if required / contracted)	UK	https://www.esendex.co.uk/information-security-statement/ FAQs \| Esendex UK
Exponential-E	All services	Personal Information contained within Telematics Data	Network service provision	UK	Our Accreditations & Awards (exponential-e.com)
Installation Partners List of Trakm8 approved Installation Partners	Installation Services	Personal Information required for completion of device installation	Device installation services	UK / EU	N/A
OpenAI OpCo LLC	Insight AI Assistant	Insight AI Assistant features and reports	Generative AI features available to Insight Enterprise level customers only	USA	Security \| OpenAI
OOH Contact Centre	Customer Support Services	Personal Information contained within support requests such as contact details	Provision of out of hours service to provide 24/7 support	UK	N/A
Proximity DC	All services	Personal Information contained within Telematics Data	Hosting / network	UK	Manufacturing & Production Data Centres \| Proximity Data Centres
Salesforce	Managing installs Managing devices Managing Support Services	Personal Information required for installation of devices. Personal Information contained within Support cases	Provision of SAAS CRM system and APIs	Sweden	GDPR \| Salesforce Compliance Salesforce Security
SendGrid (Twilio)	Sending of Service-related reports via email	Personal Information required for email delivery and Personal Information and Telematic Data contained within System reports	Routing and transmission of emails	Ireland / USA	Security \| SendGrid Security Overview \| Twilio

Version 1.16 Date: October 2024