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What Personal Information do we collect?
- We collect information regarding Drivers, Additional Drivers, Reimbursement Drivers and/or Fleet Contacts from, and on behalf of, our Clients. Such information includes: name, employee ID, contact information, vehicle information and insurance information. Depending on the Services provided to a Client, we may also collect information required to perform motor vehicle checks (e.g., drivers’ license numbers, dates of birth, motor vehicle reports) and/or vehicle telematics data and GPS information. In some cases, we may collect medical information and/or information regarding functional abilities where needed to upfit a vehicle to accommodate a medical condition or restrictions. All of this information is used for the purposes described in this Policy or as permitted by law.
- We collect information that you provide to us directly, when you contact us via mail, email or telephone, or when you sign up for our newsletter or other marketing communications, including your name, contact information, and the content of your communications. Without limiting the above, calls made to our customer call center are recorded.
Why do we collect Personal Information and how is it used?
- The information that we collect from and on behalf of Clients is used for the purposes of providing, evaluating and improving our Services or for other legal and internal business purposes as disclosed in this policy.
- We use the information that you provide to us for the purposes of responding to your communications and/or sending our newsletter or other marketing communications.
- The data that is collected automatically when you visit our website is used to operate, maintain, evaluate and improve the site, send push notifications, improve customer services, and enhance your experience when visiting our site. We may also use IP addresses when we believe it is necessary to enforce compliance with our website’s terms and conditions or to protect our service, site, users and/or others and/or our property.
Is Personal Information shared or disclosed?
- The information that we collect from and on behalf of Clients is shared with our Clients. In particular, any information that we collect or otherwise process about a Client’s Drivers, Additional Drivers, Reimbursement Drivers and/or Fleet Contacts will be shared with such Client.
- We share information with our Service Providers, including those that provide the following services: driver safety training, call center services, motor vehicle record check services, data analytics and research services, and document disposal.
- We may disclose certain information to other third parties that provide services related to our Services, including vehicle transportation companies, towing companies, registration services (including tag agents), fueling stations, electric vehicle related services (including electric vehicle charging-related providers), upfitters, roadside assistance providers, telematics services, vehicle dealerships, and payment processors, as well as maintenance, warranty and repair providers.
- Wheels shares Personal Information amongst affiliates, in its discretion, to accomplish the purposes for which such information is collected.
- We also disclose Personal Information to governmental agencies, for the purpose of registering vehicles and/or obtaining motor vehicle reports.
- We may otherwise disclose Personal Information as permitted or required by applicable law, including (without limitation) as permitted to maintain the security of our website, Services, rights and property; or to respond to legitimate inquiries by law enforcement or similar government actors.
- Clients and other third parties to which we disclose your Personal Information will collect, use, store, protect, transmit, disclose and otherwise process such Personal Information in accordance with their own policies, procedures, and practices, which may differ from those of Wheels. Furthermore, Clients may use the Personal Information about you that we share with them to make decisions about you, including regarding your continued employment or participation in the Client’s fleet program. We are not responsible for the acts, omissions or decisions of Clients or other third parties that receive information we disclose to them.
- Although we take steps to safeguard the Personal Information under our control, “perfect security” does not exist. In particular, we cannot guarantee the security of information communicated to us online or via email. It is possible that third parties may unlawfully intercept or access such information.
- We use service providers in other countries, and so your information may be transferred to, or stored in such other countries and accessible to foreign courts, law enforcement and national security authorities.
- You can contact us with questions, complaints or to access, update or rectify your Personal Information, or exercise any other rights you may have pursuant to applicable laws.
- If you are located in Alberta, you may contact our Office of Privacy Counsel at firstname.lastname@example.org or by phone at (224) 383-1800 with any questions regarding the collection, use, disclosure or storage of Personal Information by our service providers and affiliates outside Canada, or to obtain access to written information about our policies and practices with respect to such service providers and affiliates outside Canada.
Wheels, LLC and its subsidiaries including Wheels Leasing Canada Ltd. (collectively “Wheels,” “we” and sometimes “us”) share your concerns about the security of your Personal Information and our use of such information. We want you to know about the kinds of information we obtain about you from you and/or your company, the ways in which we use this information, who has access to your information, how you can limit our collection of, access to, and/or use or disclosure of this information, and how you can access, correct and update this information.
This Policy addresses information we collect that can be reasonably related to you as an identifiable individual (“Personal Information”). This includes if there is a serious possibility that you could be identified through the use of the information, whether alone or in combination with other information. This Policy does not cover information where there is no serious possibility that you could be identified through the use of such information.
Wheels collects and uses Personal Information of Drivers, Additional Drivers, Reimbursement Drivers and/or Fleet Contacts solely to perform Services to our Clients. The scope of Personal Information provided by you or your company on your behalf to Wheels may include your name; employee ID; personal or business mobile phone number; and personal or business e-mail address. If a vehicle is garaged or registered to your home address, this information may also be provided to Wheels. If your personal vehicle is used for business and participates in the Services, your vehicle’s license plate number and vehicle identification number (VIN), along with details about your personal auto insurance declaration will also be collected by Wheels. As described below, Wheels may also collect certain sensitive information related to physical conditions.
Other information about you may be obtained, stored and used as a result of delivering Services. This information may be made available to a limited number of authorized users at the Client consistent with our relationship with the Client. For example:
- If the Client participates in the Wheels Motor Vehicle Record (MVR) program, your driver’s license number and state/province, as well as your date of birth, will also be collected as required in order to process MVR requests. In such case, your motor vehicle record will also be collected and stored by us, and shared with the Client. For the MVR program, your consent will be obtained as required by each jurisdiction from which such records are being requested.
- If a Client participates in connected vehicle Services, telematics data (e.g., vehicle health data, vehicle location data, driving behavior data) associated with a vehicle will be collected and stored in association with that vehicle. This GPS and other telematics information is used to support delivery of fleet management and other Services for the Client, and will be accessible to the Client.
Wheels will collect driver’s license information, insurance information, and other pertinent information from a driver involved in an accident. When available, we collect the name, address, contact, driver’s license and insurance information for any other parties involved in the accident. We will also indicate injury and/or fatalities of a driver or passenger, or other parties, when applicable. In addition to the above, if a driver contacts our call center for any reason, their call will be recorded.
Wheels does not collect or store personal financial account numbers or other financial information about individuals.
Wheels and our service providers may also collect or be provided with Personal Information about you in a variety of circumstances in the course of providing our Services. This includes Personal Information that you knowingly provide to us directly, as well as Personal Information that we legally receive from third parties.
Wheels also collects name, contact information and other information that you provide, for the purposes of providing marketing communications and responding to your communications. In addition, our website automatically collects certain data via cookies and other tracking technologies, as described below under “Cookies, Tracking and Analytics.”
The Personal Information that we collect is accessible to employees and contractors, based both within and outside of the United States and Canada, that provide business product development, systems support, and/or supplemental staffing services, and who have a legitimate need to access such information in order to perform their duties and provide Services to you and/or the Clients.
We, both directly and through our service providers or third parties, occasionally collect Personal Information that constitutes sensitive information. For example, data about your physical conditions is regarded as sensitive. If you ask us to accommodate a disability (e.g., such as requesting hand controls, or if there is an accident and we need to work with insurance and claims management companies relating to any injury you may incur), then incidental to providing Services, we may need to process and use such information about your physical conditions solely to provide the Services. Depending upon applicable law, we may be unable to process such sensitive information without your consent and will therefore ask for your express consent at the point of collection of such information where required by law.
Use of Information
We use the Personal Information we collect for the purposes of: (1) performing our fleet management services (this includes our normal course of managing our business; see “Fleet Management Services”), (2) for marketing purposes and to communicate with you (see “Marketing & Other Communications”), and (3) to track usage of and improve our website (see “Cookies, Tracking and Analytics”), each as further described below. We may also use Personal Information for other purposes with your consent, or without consent where required or permitted by applicable law.
(1) Fleet Management Services
We work with companies (each a “Client” or the “Clients”) who may lease vehicles from us, or obtain services from us related to vehicles used in the course of their businesses. These vehicles may be provided to you as an individual driver (“Driver”) in order to permit you to perform duties as an employee or independent contractor of the Client (or in a similar role), and you may potentially be authorized to use the vehicle for personal use. Members of the household of a Driver (“Additional Drivers”), may also be permitted to drive the Driver’s vehicle. Further, you may be authorized to use your own personal vehicle for business purposes, and Wheels may be engaged by the Client to provide certain maintenance and/or other services related to your personally owned vehicle (“Reimbursement Drivers”). Other individuals (“Fleet Contacts”) affiliated with each Client may participate in the management of the vehicles for such Client. Wheels collects, accesses, uses, maintains, discloses and otherwise processes information regarding these vehicles along with information about Drivers, Additional Drivers, Reimbursement Drivers and Fleet Contacts in order to provide requested services.
Wheels services include performing motor vehicle checks on Drivers, Additional Drivers and Reimbursement Drivers; as well as a variety of services related to facilitating and administering transactions related to the acquisition, maintenance and management of Clients’ vehicles, or the safety and support of drivers, as well as providing analytical information and consultative advice to optimize the operation of each Client’s vehicle fleet (collectively, the “Services”).
In addition to the normal provision of our Services, we also use Personal Information in the normal course of our business for reasons related to Wheels management of its own business. For example, we use Personal Information for meeting legal, security, processing and regulatory requirements; protecting against fraud, suspicious or other illegal activities; and compiling statistics for analysis of our websites, the Services, and our business.
Finally, we use Personal Information as required by valid legal processes, such as responding to subpoenas, warrants, regulatory investigations, and similar such legally compelling reasons.
(2) Marketing & Other Communications
Independent of the Services, you may subscribe to, or otherwise be enrolled to receive, marketing communications from Wheels. We may use this information to communicate with you, which may include, but not be limited to, providing newsletters, product literature or invitations to events. Wheels does not include third-party advertising tracking technology in our web sites or our electronic marketing communications.
If you prefer not to receive any marketing communication from Wheels anymore, you may send us an e-mail message addressed to email@example.com or call our Marketing Associate at (847) 544-4100 and request that we not send you any more marketing communications. Please allow up to ten business days for us to make the requested change. You can also opt-out of receiving marketing messages by clicking the unsubscribe link included in each of our messages. Of course, you can “opt-in” to get back on our mailing list to receive marketing communications at any time by contacting us as described above. Please note that if you opt-out of marketing messages, you will still receive service alerts and other notifications of factual information related to the delivery of our Services.
In addition to the above, we may also use your Personal Information to communicate with you, including to respond to any inquiries that you submit to Wheels.
(3) Cookies, Tracking, and Analytics
As you navigate a website, we may also collect information through the use of commonly-used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on a website (such as the web pages viewed and the links clicked).
Session cookies: These are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
Persistent cookies: A persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
First-party cookies: The function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between Wheels’ servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
Third-party cookies: The function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the third-party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.
The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, the websites are not compatible with DNT.
For information on all of these categories of cookies, and for more information generally on cookies please refer to www.aboutcookies.org.
We use generally cookies as follows:
Functionality. These cookies allow our websites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a website or Service may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access our website. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested. These cookies do not gather any information about you that could be used for advertising or remember where you have been on the internet.
Performance. These cookies collect information about how visitors use our website, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to a website, all of which enables us to see how visitors use a website in order to improve the way that the website works. The information these cookies collect is normally anonymous and is used to improve how our website work. However, some of these cookies may include Personal Information.
A website may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of a website and interaction with e-mails from Wheels. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon. We use web beacons to operate and improve the websites and e-mail communications. We may use information from web beacons in combination with other data we have about our clients to provide you with information about us or affiliated companies.
When you visit our websites, we collect your Internet Protocol (“IP”) addresses to track and aggregate non-Personal Information. For example, we use IP addresses to monitor the regions from which users navigate the websites. IP addresses will be stored in such a way so that you cannot be identified from the IP address.
Disclosures of Information
When we provide Services to a Client, we will disclose Personal Information to such Client regarding its Drivers, Additional Drivers, Reimbursement Drivers and Fleet Contacts. Any and all information we collect about a Client’s Drivers, Additional Drivers, Reimbursement Drivers and Fleet Contacts may be shared with such Client, including (without limitation) motor vehicle reports, call recordings, requests for access to Personal Information, as well as information regarding the use of our Services by Drivers, Additional Drivers, Reimbursement Drivers and Fleet Contacts (including but not limited to reporting and analyses requested by our Clients as provided by Wheels).
Without limiting the above, as part of the Services, we provide web sites to be accessed by Clients and Fleet Contacts (the website known as “FleetView”), and Drivers, Reimbursement Drivers and others (the website known as “DriverView”), in order to assist the Client with administering the Client’s fleet vehicle program and to assist Drivers and Reimbursement Drivers in performing certain tasks more efficiently. In order to use these sites, a user needs to be authorized by the Client either as a Fleet Contact to manage vehicles, as a Driver or Reimbursement Driver. Each Client is responsible for determining a fleet policy that addresses delivery of Services, use of Personal Information, and other vehicle related information.
Whether Clients communicate policies directly or through us to Drivers, Additional Drivers, Reimbursement Drivers and Fleet Contacts, Wheels is not responsible for the actions or omissions of such Clients, including for any use or disclosure of Personal Information (or failure to protect Personal Information) that Wheels shares with such Clients. Clients are also responsible for providing such notices and obtaining such consents as are necessary for Wheels to access, use, disclose and otherwise process Personal Information in order to provide them with Wheels Services (except where otherwise specifically agreed between Wheels and the Client). Information that is disclosed to a Client will be handled in accordance with that Client’s privacy and data protection policies, procedures and practices, which may differ from those of Wheels. Clients may also further disclose Personal Information that they receive from Wheels to third parties at the Client’s discretion. Individuals that have any questions regarding how their information will be handled by their employer or other third party that owns or leases the vehicle that they operate should review the relevant Client’s privacy policies and/or contact the Client directly.
(2) Service providers
Wheels discloses Personal Information to the following service providers for the purposes of allowing them to provide services to Wheels:
- Name and/or e-mail address may be shared with training providers to schedule on-line safety training courses;
- Name, address, phone number and email address may be shared with our subcontractors in connection with the overflow and after-hours call center services that they provide to Wheels, and such subcontractors may also collect additional information directly from callers (including call recordings);
- Name, address, drivers’ license number and province of issuance, and date of birth is shared with motor vehicle record check service providers, as needed for such third parties to provide their services;
- Information may be shared with our parent company and affiliates in the regular course of conducting business; and
- Personal information that we collect may be shared with service providers for other business purposes, such as analytics, data processing, cloud hosting, data storage, research, document disposal, and other operational purposes.
In addition, some Service Providers may collect Personal Information directly from individuals in the course of providing their services.
Service Providers are only permitted by Wheels to use Personal Information that we share with them (or they collect on our behalf) for the purposes of providing their services and other lawful purposes authorized by Wheels.
(3) Third Parties that provide related services
Wheels discloses Personal Information to certain third parties that provide services related to Wheels Services, as follows:
- Name, phone number, email address, location and/or home address may be shared with vehicle transportation companies, towing companies, fueling stations, electric vehicle services, (including electric vehicle charging providers), or roadside assistance providers to facilitate emergency services, or delivery or pick-up of a vehicle;
- Name and email address is shared with payment processors, and such third parties also collect financial information directly from individuals including bank and credit card information;
- Telematics data (i.e., vehicle health data, vehicle location data, driving behavior data) is shared with, or collected by, telematics service providers in connection with providing their services;
- Name, phone number, address and driver’s license number may be shared with service providers (including tag agents) to facilitate registration of vehicles;
- Name, phone number and/or e-mail address may be shared with a vehicle dealership and/or maintenance, warranty service or repair providers to facilitate scheduling service or to pick up or drop off a Client or Driver’s vehicle directly with the provider;
- Name, phone number, address and information regarding required vehicle modifications may be shared with vehicle upfitters for the purposes of modifying and customizing vehicles.
Information is provided to such third parties in accordance with applicable laws. Such information will be handled in accordance with the third party’s privacy and data protection policies, procedures and practices, which may differ from those of Wheels. We are not responsible for the actions or omissions of such third parties, including for any use or disclosure of your Personal Information (or failure to protect your Personal Information) by such third parties. If you have any questions regarding how your information is handled by any third party, you should review the relevant third party’s privacy policies and/or contact them directly.
(4) Other Disclosures
We may also disclose Personal Information to third-parties as necessary to deliver the Services. Such disclosures may include the following:
- Name and home address may be shared with state/province, county/municipality or provincial agencies for purposes of registering a Client vehicle;
- Name, address, driver’s license number and date of birth may be shared with state/province or county/municipal agencies, or with an authorized service bureau, for the purpose of obtaining motor vehicle records (where applicable);
- Information may be shared with third parties, including IP addresses and internal web tracking data, may be shared with third party security firms as part of our security operations to maintain the security of our website, services, rights and property;
- Information may also be shared with third parties as otherwise disclosed at the time of collection or use or at such other appropriate times.
We may also disclose Personal Information when otherwise permitted or required by law, including (without limitation) in connection with the sale of all or part of our business (subject to compliance with any legal requirements or restrictions) or when we have a good-faith belief that such disclosure is legally required or otherwise necessary and/or permitted to protect our rights, manage our business, protect your safety or the safety of others, investigate fraud, or comply with a current judicial proceeding, a court order or legal process.
Access and Your Choices
You may request to access, review, change, rectify or update the Personal Information we maintain about you, and/or you may request that we transfer your Personal Information to a third party. You may initiate any such request by sending an e-mail message to the Office of Privacy Counsel at firstname.lastname@example.org, or by phone to (224) 383-1800, or in writing to Wheels, Attn: Privacy Inquiries, at 666 Garland Place, Des Plaines, Illinois 60016. We will respond to such requests in accordance with legal requirements in the applicable jurisdiction(s). Please note that nothing herein shall confer upon you any rights or entitlements that you do not otherwise have pursuant to the laws in the jurisdiction where you are located. In particular, without limitation, in some cases you may be directed to submit your access request to the applicable Client (instead of Wheels), where required or appropriate pursuant to applicable law.
Please note, we will not fulfill any requests for access, review, rectification, modification, or updating if we are not required or permitted to do so by applicable law, which may include circumstances where such actions could 1) violate the privacy or intellectual property rights of third parties, or 2) cause Wheels to violate any applicable law, regulation, or related obligation.
Without limiting the above, upon request we will provide you with information that we maintain about you for marketing purposes, subject to any permitted or required exceptions under applicable law. You may access this information by writing to Wheels, Attn: Marketing at 666 Garland Place, Des Plaines, Illinois 60016. For security reasons, we will not provide you with this information online. Upon request and after appropriate verification, we will offer you the ability to have any inaccuracies corrected in the marketing information we maintain. You may have this information corrected by contacting us in the manner provided above.
We may request information from you in order to authenticate your request and/or confirm your identity.
You may choose not to provide us with your Personal Information. However, there are certain aspects of our relationships with Clients that require us to maintain certain accurate and current Personal Information about you in order for us to provide the Services. If you elect not to provide your Personal Information to us or request that your Personal Information not be used by us, this may result in disadvantages to you. For example, it may limit the extent to which we can provide certain Services to you and/or the Client. In consideration of those limits, and since Personal Information is collected and retained on behalf of our Clients, Wheels will notify the Client of any request by one of its Drivers, Additional Drivers, Reimbursement Drivers or Fleet Contacts.
We use a variety of security safeguards, including encryption and other security practices and procedures. We use commercially reasonable physical, technical and organizational controls designed to protect the Personal Information submitted to us. Due to the nature of the Internet and related technology, we cannot guarantee the security of your Personal Information and Wheels expressly disclaims any such obligation. Any information you transmit to us is at your own risk.
In the event of a security incident involving the unauthorized access, use, disclosure or loss of your Personal Information or any other breach of the protection of your Personal Information that poses a serious risk of harm, we will notify you if required to do so pursuant to applicable law.
Data Retention, Destruction & International Transfers
We will retain and use your information for the duration of the use of the Services and as necessary to comply with our legal obligations, resolve disputes, establish or exercise legal claims, and enforce or comply with our agreements. Information is stored and accessed at various locations, and cloud services and cloud storage may be utilized.
Once the purpose for which it was collected or used has been fulfilled and we no longer need your Personal Information, subject to any statutory retention period or contractual obligations, we will destroy your Personal Information (or de-identify your Personal Information and continue to use it for legitimate purposes, where permitted by applicable laws).
All data centers which store information are located in the United States. Accordingly, even if you are located outside the United States, your Personal Information may be accessible to courts, law enforcement and national authorities in the United States.
You may contact us in writing, as set out below, in order to:
- Ask questions or express concerns about this policy, our privacy practices, and/or our collection and handling of your Personal Information;
- Request to access, correct, rectify or update your Personal Information, or exercise any other rights you may have under applicable laws; and/or
- Withdraw consent to continued use and disclosure of Personal Information, subject to any legal restrictions and reasonable notice.
In addition, if you are located in Alberta, you may contact our Office of Privacy Counsel at email@example.com or by phone at (224) 383-1800 with any questions regarding the collection, use, disclosure or storage of Personal Information by our service providers and affiliates outside Canada, or to obtain access to written information about our policies and practices with respect to such service providers and affiliates outside Canada.
We undertake to respond to your request with diligence, and generally within 30 days from the date of receipt of your written request (or such longer period as may be permitted by applicable law).
For Fleet Management Services: Contact us via e-mail message addressed to Office of Privacy Counsel at firstname.lastname@example.org, by phone call to at (224) 383-1800, or in writing to Wheels, Attn: Office of Privacy Counsel, at 666 Garland Place, Des Plaines, Illinois 60016.
For Marketing Communications: Contact us via e-mail message addressed to our Marketing Associate at email@example.com or by phone call to (847).544.4100
For other assistance: Contact us in writing to Office of Privacy CounselatWheels by email to firstname.lastname@example.org, in writing to 666 Garland Place, Des Plaines, IL 60016 or by phone call to (224) 383-1800.