Policies

In4mo Oy (collectively referred to as “In4mo” “we,” or “us”) is part of the Solera group of companies. This Privacy Statement and Notice explains our policy concerning the collection and processing of personal data and describes privacy rights and how the law protects data subjects. We respect privacy and are committed to protecting your personal data.

Our websites and services are not intended for use by minors under the age of 16 and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with other notices we may provide on specific occasions when we are collecting or processing personal data so that you are fully aware of how and why we are using your data. For example, there are separate privacy notices for employees and job candidates. Those privacy notices supplement this policy.

CONTACT DETAILS

In4mo Oy,

Attn: Data Privacy Champion

Tekniikantie 12, 02150 Espoo,

Email : [email protected]

CHANGES. This Privacy Statement may be updated from time to time. We will provide the updated statement on our website and a summary of material changes. Please keep us informed if your personal data changes during your relationship with us. We realize that it is important that the personal data we hold about you is accurate and current.

THIRD-PARTY LINKS. Some of our websites and services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for how they process personal data. We encourage you to read the privacy notice of every website you visit.

The types of personal data we obtain about you depends on how you interact with us and our products and services. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, such as anonymous data. We follow the law in each applicable jurisdiction in determining what constitutes personal data. The following are the categories and specific types of personal data that you provide to us directly or that we collect automatically.

When you use our public websites such as the website where you accessed this policy: We may collect Internet or other technical and usage data including but not limited to IP address, browsing history, and referring websites. Some collection is through cookies. You may also choose to provide your contact information for us to communicate with you about our products and services.

When you use our products or services including websites that require a log-in:

We may collect, use, store, and transfer different kinds of data which we have grouped together as follows:

• Identification Data such as a name, alias, phone number, address, unique identifiers, account name, social security number, driver’s license number, passport number, or other similar identifiers.
• Financial Data such as bank account, credit card and debit card numbers, and other financial information.
• Commercial Transaction Information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Biometric Data such as photographs and physical characteristics.
• Technical and Usage Data such as internet protocol address, login data, browser type and version, data on devices used to access a website, service or application, browsing history, and search history. how you use our website or service.
• Geolocation Data such as latitude and longitude of your location.
• Sensing Information such as audio, electronic, visual, thermal, olfactory, or similar info.
• Employment Information such as work experience or profession
• Education Data such as information about schooling, training and professional certifications
• Inference Data such as information drawn from other information reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Medical Data such as information on health conditions and treatment.
• Marketing and Communications Data such as your preferences in receiving marketing from us and third parties and your communication preferences.

We also collect, use, and share data that is derived from personal data but does not identify a natural person. For example, we may aggregate Technical and Usage Data to calculate the percentage of users accessing a specific website feature or we may share data about vehicles as long as sharing such data does not identify a natural person.  However, if we combine or connect data that identifies a natural person, we treat the combined data as personal data which will be used in accordance with this privacy policy. More information may be provided with specific processing activities.

We collect Special Categories of Personal Data, such as precise geolocation, trade union membership, criminal conviction and offenses, race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, or political opinions, only where required to provide services or comply with a legal obligation. For example, special categories of data may be processed for recruitment or employee benefit services. More information will be provided in a Privacy Notice for the processing activity.

IF YOU FAIL TO PROVIDE PERSONAL DATA. Where we need to collect personal data by law, or under the terms of a contract we have with you and you do not provide that data, we may not be able to enter into or perform a contract with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Personal Information collected through our public websites such as the website where you accessed this policy: We will use the personal data we collect to administer our websites, for internal operations, data analysis and to improve our websites. We may also use personal information for direct marketing or other specific purposes made clear to you at the time you submit your personal information on our website. Our use of your Personal Information may be based on our legitimate interests to ensure network, information security, and business performance improvement. Our direct marketing purposes are based on your consent. We may also rely on our legitimate interests to improve business and marketing practices or contact you to offer similar Services or products that you may have bought from us, requested a demo, or negotiated with us.

Personal Information collected by our Products and Services including websites that require log-in: We will only use your personal data as permitted by law. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for a legitimate interest and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to marketing communications.. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA: We may provide additional notices to you of the purpose of and basis for collecting the data. In general, we collect information for purposes and on the bases shown below:

• Legitimate business interest means the interest of our business that does not override your interests or fundamental rights and freedoms. We make sure to consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or your employer are a party or to take steps at your request before entering into such a contract.
• Comply with a legal obligation means processing your data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

MARKETING COMMUNICATIONS: You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing. We will get your express opt-in consent where required by law.

CHANGE OF PURPOSE. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose that is compatible with the original purpose. For an explanation, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may process your personal data without your knowledge or consent as permitted by law.

We may share your personal data with:

• Other companies in the Solera group of companies who are involved in providing the service or product or provide IT and system administration services and information reporting.
• Our customers who are providing services to you.
• Our service providers who provide IT and system administration services or product support.
• Our professional advisers such as lawyers, bankers, auditors, and insurers.
• Government agencies, when required by law.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets or where seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need-to-know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Personal data may be transferred from the country where it was collected to other countries where Solera’s group of companies operate. This means, for instance, that personal data may be transferred from the EEA, UK, Switzerland, and Brazil to the United States, Mexico, and India for processing.  Any transfers will be in compliance with applicable law. We will be liable for onward transfers to third parties.

If the processing of your personal data is subject to data protection regulations concerning international transfers, we will ensure that any international or onward transfer is consistent with applicable law such as standard contractual clauses approved by an appropriate regulatory authority. We may also rely on an adequacy decision of the regulatory authority such as the European Commission confirming an adequate level of data protection in the jurisdiction of the party receiving the information.

We comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the Data Privacy Framework Principles with regard to the processing of personal data received from the European Union, the UK (and Gibraltar) and Switzerland. If there is any conflict between the terms in this privacy policy and the relevant Data Privacy Framework Principles, the Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, visit the U.S. Department of Commerce’s Data Privacy Framework website. The U.S. affiliates of Solera, namely Audatex North America, LLC, Claims Services Group, LLC, DealerSocket, LLC, Distribution Service Technologies, LLC, DMEautomotive LLC, eDriving Fleet LLC, eDriving LLC, eDriving Telematics LLC, Enservio, LLC, Explore Information Services, LLC, GTS Services, LLC, Hollander, LLC, HyperQuest, LLC, Identifix, LLC, LYNX Services, LLC, Mobile Productivity, LLC, Omnitracs, LLC, RedCap Technologies, LLC, Roadnet Technologies, Inc., SmartDrive Systems, Inc., Spireon, Inc., Title Technologies, LLC, Transportation Performance, LLC, XRS Corporation, also adhere to the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework.

We commit to resolve DPF Principles-related complaints about our collection and use of your personal data.   EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact us via our web form. You have an option to invoke binding arbitration by delivering notice to us and following the procedures and subject to conditions set forth in Annex I of the Data Privacy Framework Principles.

We commit to cooperate and comply respectively with the advice of the panel established by the EU Data Protection Authorities and the UK Information Commissioner’s Office and the Swiss Federal Data Protection and Information Commissioner with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

We will only retain your personal data for as long as is necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

You may opt not to disclose information to us. Some of your information, however, may be required in order to use our products or services.

MARKETING COMMUNICATIONS. You can ask us to stop sending you marketing messages at any time. Opting out of marketing messages will not affect our processing of your personal data for non-marketing purposes, such as providing a product or service to you, warranty registration, the product or service experience, or other transactions.

COOKIES. You can make choices about what cookies collect information on our websites. You may be able to set your browser to refuse all or some browser cookies. If you disable or refuse certain cookies, some parts of the website may become inaccessible or not function properly.

You may have certain rights available to you when it comes to your personal information. Below is a summary of those rights.

Data Subjects may, depending on applicable law, have some or all of the following rights:

• Right of access– You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and to know what data is being processed, the purpose of the processing, as well as the origin of such data and the communications made or planned for such data.
• Right to rectification- You have the right to obtain without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
• Right to erasure (‘right to be forgotten’)- You have the right to obtain the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay in some circumstances.
• Right to restriction of processing- You have the right to obtain restriction of processing.
• Right to data portability- You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.
• Right to object or to withdraw consent- You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you.
• Automated individual decision-making, including profiling- You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects.

To exercise your rights please apply directly through the link below in the “Rights Requests” section. If you believe that we have not processed your personal data in accordance with regulations, you can contact our Privacy Department at [email protected]. You are entitled to submit a complaint to the Data Protection Agency in your country, you can find a list of EU contacts here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.  The Information Commissioner’s Office can be reached at https://ico.org.uk/.

You may have rights under data protection laws in relation to your personal data. Contact us for more information.