Datenschutz-Bestimmungen

25 Nov 2020

This Privacy Policy explains how we TELTONIKA group companies (UAB “TELTONIKA IoT GROUP”, UAB TELTONIKA TELEMATICS, UAB TELTONIKA NETWORKS, UAB TELTONIKA TELEMEDIC, UAB “TELTONIKA EMS” collectively, “Teltonika”, “we”, “us”, and “our”) collects, uses, shares, and protects personal data, and what privacy rights you have.

This Privacy Policy applies to all natural persons who use, have used, have expressed an intention to use the Teltonika products or services, or are otherwise related to us and (or) our services. This Privacy Policy also applies to employees and representatives of Teltonika’s clients.

This Privacy Policy applies to personal data of natural persons, it does not apply to legal persons data. The Privacy Policy is made public on Teltonika’s website.

This Privacy Policy applies to processing of your personal data collected during your use of the following websites and systems:

Specific categories of personal data and actions taken with respect to your personal data may differ depending on which website or system you use, but Teltonika will not process personal data beyond the scope described in this Privacy Policy.

1. DATA CONTROLLER

Teltonika group companies are joint controllers of your data. Please find the details of each company belonging to Teltonika and their contact details in our website at Teltonika’s contacts page.

2. INFORMATION WE COLLECT AND HOW WE USE IT

2.1. Information we collect automatically through Teltonika website or our emails

When you visit our website or interact with our emails, we use cookies to collect certain information automatically from your browser through the use of cookies and pixels from tools such as Google Analytics and Google Ads. Our use of cookies is discussed in more detail in our cookies policy which is available here.

The information we collect automatically includes:

We use this information for conducting analytical and profiling activities, which include improving the efficiency of our internal processes and procedures and overall quality of the products and services that we provide, and creating customer profiles to prepare relevant products and services. Legal basis for collecting this information is our legitimate interest to improve our offerings. Where we use cookies to collect and process this information, legal basis is your consent.

2.2. Direct marketing

We use your email which you provide when subscribing to our newsletter or when you send us an enquiry for the purpose of sending you our updates, offers and other marketing material. We may also ask you to complete a customer survey or send other messages related to our business.

Legal basis to use your email for this purpose is your consent, when you provide your email address by subscribing to our newsletter, or our legitimate interest to expand our business and inform our customers about news related to Teltonika, when you provide your email to us for using our services.

You may disagree with such use of your email at any time by clicking “unsubscribe” in the message you receive from us.

Teltonika’s focus is the B2B market, but we must collect personal data of employees or representatives of our clients.

If you act in the capacity of an employee or a representative of our client (or a potential client) and communicate with us or otherwise have relations with us, we may process your contact and other details such as first name, last name, job title, organization, phone number, email address, payment identifiers, and any other personal information you provide to us in your communication (alone or in combination with other data we source) for various purposes relating to our business activities, such as:

We may collect personal information about you (e.g., your position, specialty and publications) from publicly-available resources and combine it with personal data we have collected about you, to enhance our customer profile of you in support of our sales and marketing activities.

Depending on the specific actions we take during use of your personal data, processing of your personal data is based on one of the following legal bases, i.e.:

2.4. Provision of our services

When you use our services, the data controller of your personal data is generally your employer or other entity which is using our products and services. In these cases, we generally act as the data processor in accordance with the data processing agreement concluded as part of our agreement with the customer regarding provision of service.

However, there are certain limited types of personal data which we process in the capacity of a data controller. When you use our product service platforms, we may automatically collect or receive certain information about your device and usage of the service. We use cookies and other tracking technologies to collect some of this information. The personal data we collect may include:

We use the aforementioned personal data in order to enable you to use our services and functionality of Teltonika products and systems. We may also use the personal data to conduct usage analysis, implement improvements, and make business decisions. The personal data may also be used to provide you with service support and ensure stability of our service.

The legal bases we rely on to process data for the above mentioned purposes are necessity to perform contract (when we seek to ensure availability and functionality of our services) and our legitimate interests to improve our services (when we conduct usage analysis).

2.5. Crowd-support forum

When you register and use our Crowd-support forum available at website of any Teltonika group company, in addition to automatically collected data, we will collect and process your username, e-mail address, password, and other data you provide to us, such as the duration of membership, type of membership, your name, location, personal site, activity data and any other data you voluntarily provide.

If you post questions on the Crowd-support forum or answer other users’ questions and provide any personal data in such questions or answers, we will process any such personal data you voluntarily provide.

The legal bases to process this data are the necessity to perform contract, i.e. to carry out our obligation to provide you with functionality of the Crowd-support forum, and our legitimate interest to ensure collection of relevant activity data in order to secure availability of the Crowd-support forum, and to generally manage it, and improve it.

Your username and non-private activity data as well as the questions and answers you post on the Crowd-support forum will be available publicly and may be accessed by other registered and non-registered users of the Crowd-support forum.

3. HOW WE SHARE YOUR INFORMATION

3.1. Analytics

Teltonika uses third-party web analytics services on our website, such as Google Analytics and Lucky Orange. These analytics services may collect information about your activities on our sites to help us analyse how visitors use our website, improve usability and customer experience. You can opt-out of Google Analytics by installing Google’s browser add-on. Lucky Orange may record mouse clicks, mouse movements and scrolling activity, keystroke information that you voluntarily enter on our Sites. You can choose to disable the Lucky Orange Service, to do so please read section 6 of Lucky Orange privacy policy.

3.2. Email communication

We use MailChimp mailing system for our email marketing. Whenever you enter data in our Teltonika website to subscribe to our newsletter, the information is stored in MailChimp servers in the United States, so your information may be transferred to, stored, or processed in the United States (see also section 4 of this Privacy Policy).

With the assistance of the MailChimp cookies, we can analyse the performance of our newsletter campaigns. MailChimp will capture data about your interactions with our emails, such as which links you click within an email. It does by automatically placing single-pixel gifs, also known as web beacons, in every email. For more detailed information please read MailChimp cookies statement.

3.3. Subcontractors

Teltonika shares your personal data with other partners when services are provided by partners authorized by Teltonika. For example, before sending your order from Teltonika, we must share your information with our logistics provider to arrange shipment.

Your personal data may also in some cases be shared with various types of professional providing services to us, such as auditors, lawyers, financial consultants and other service providers.

3.4. Corporate transactions

If we are participating in a corporate transaction such an acquisition or a sale or are otherwise involved in any capacity in any such transaction, your personal data may be shared with entities involved in the transaction, including sellers, buyers, or other investors, as well as consultants related to the relevant transactions.

In addition, as a global company, we may share your personal data with Teltonika’s affiliates and subsidiaries, divisions, and groups worldwide.

In response to a legal request, if we have a good-faith belief that the response is required by law, we may share your personal data with public authorities, courts, legal officers, government entities, law enforcement agencies etc.

4. INTERNATIONAL TRANSFERS

Teltonika operates globally, which means personal data may be stored and processed in any country where we or our service providers have facilities. By providing personal data to Teltonika for any of the purposes stated in section 2 of this Privacy Policy, you acknowledge that your personal data may be transferred to or stored outside EU or the EEA countries. Such countries may have data protection rules that are different and less protective than those of your country.

Teltonika will transfer personal data outside the EU or the EEA countries where appropriate safeguards are in place or otherwise in accordance with applicable law.

Generally, we only transfer personal data outside EU or the EEA where the recipient territory has been determined to provide an adequate level of protection or if we have a contract in place that is based on standard contractual clauses and (or) other documents approved in accordance with the GDPR.

You have a right to contact us in order to receive more information about the safeguards we put in place when transferring data to third countries.

5. HOW LONG WE KEEP YOUR DATA

We retain personal data where we have an ongoing legitimate business or legal need to do so, and our retention periods will vary depending on the type of data involved. The criteria used to determine our retention periods generally include:

Some types of personal data have a set retention period, i.e.:

6. YOUR RIGHTS

As the data subject, you have the right to:

7. CHANGES TO THIS PRIVACY POLICY

We review our Privacy Policy regularly and we will place any updates on this web page. You are required to acquaint yourself with any changes to it.

8. CONTACT DETAILS

If you have any privacy-related questions, complaints, or issues, and want to contact Teltonika Data Protection Officer (DPO), please send an email to privacy@teltonika.lt. When submitting a request, please identify yourself and specify your request.

You can also contact us by writing to this address:

UAB Teltonika Geležinio Vilko str. 18A, LT-08104, Vilnius, Lithuania