個人情報保護方針

2021-08-13

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 https://teltonika-iot-group.com/.

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

• Crowd support forums;
• any website of any Teltonika group company;
• networking device monitoring and management system (RMS https://wiki.teltonika-networks.com/view/RMS);
• tachograph files management and storage system (WEB Tacho https://teltonika-gps.com/product/tachograph-web/);
• remote firmware and configuration update system (FOTA Web https://teltonika-gps.com/product/fota-web/);
• fleet monitoring and fleet management system (TAVL WEB https://teltonika-gps.com/product/tavl-web/);
• query support management system (VIP HelpDesk https://viphelpdesk.teltonika.lt/);
• other IoT related network management, connectivity services, security services, router operating systems, and other related services, including any Platform APIs or SDKs, provided by Teltonika through the Internet as described at Teltonika Wiki Knowledge Base or as otherwise documented and made available to Customer upon request by Teltonika

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 https://teltonika-iot-group.com/about-us/contacts/.

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 https://teltonika-iot-group.com/ 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:

• persistent identifiers (IP addresses, browser type, Internet Service Provider (ISP), referrer URL, exit pages, operating system, date/time stamp);
• usage data (information how you interact with our web page);
• approximate location (e.g., nearest city or town);
• log data (our web servers keep log file that record data each time a device access them).

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 when you use our services.

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

2.3. Management of client relationships and related processing

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:

• to enter into a sales or service contract with you or the organization for which you work;
• to communicate with you in relation to the contract we have entered into with you or with the organization for which you work;
• to bill and collect money owed to us by you (or the client you represent). This includes sending you emails, invoices, receipts and alerting you if we need to clarify information about payments;
• to follow up after correspondence (live chat, email or phone inquiries);
• to communicate with you about our products and provide customer support;
• to verify financial transactions and undertake compliance screening checks;
• to cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal data;
• to protect personal property or ensure safety, and pursue remedies available to us and limiting our damages;
• to share content of your communication with our customer services representatives to ensure we deliver high-quality service, assist in the training and development of Teltonika representatives, and generally improve our customer service to you.

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.:

• when processing is necessary for the performance of a contract or in order to take steps at prior to entering into a contract;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is necessary for the purposes of the legitimate interests pursued by us or a third party. Most commonly, we process personal data to pursue legitimate interests of improving, maintaining, providing, and enhancing our technology, products, and services, and ensuring the security of the products and services, as well as supporting our marketing activities;
• when you give us your consent.

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:

• account log-in credentials (such as your email address, username and password);
• user experience data (user interaction with the system, such as your visited pages or mouse movements);
• device information (your IP address, your operating system, your browser ID, and other information about your system and connection);
• log data (our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP addresses and your activity in the service (such as the date/time stamps associated with your usage, viewed pages and files, searches and other actions you take);
• movement data;
• other service-related data.

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. 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. Google Analytics may record clicks, mouse movements and scrolling activity, other activities that you voluntarily complete on our Sites. You can learn more about the data collected by Google’s tools here. Also, you can opt-out of Google Analytics by installing Google’s browser add-on.

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.

3.5. For legal reasons

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:

• the length of time we have an ongoing relationship with you (for example, for as long as you have an account with us or keep using our services);
• whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them).

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

• data collected via website analytics will be stored up to 26 months;
• cookies are usually valid for up to 24 months. You may delete them anytime;
• we will use your email for marketing for up to 12 months after your last reaction to our communication;
• we may keep Customer‘s data associated with the use of Service for up to 12 months.

In some cases, personal data may be stored for a longer period if storage of personal data is required in order to protect our or any third parties’ legitimate interests, e.g. in case of a legal dispute.

6. YOUR RIGHTS

As the data subject, you have the right to:

• obtain confirmation as to whether or not personal data concerning is are being processed, and, where that is the case, access to the personal data;
• request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
• request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
• object to processing your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
• withdraw your consent;
• request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it;
• request the transfer of your personal information to another party in certain formats, if practicable;
• make a complaint to a supervisory body. If you are domiciled in the EU and you think your privacy rights were breached, you may lodge a complaint with the data protection authority of the country of your domicile. You may find the list and contact details of EU data protection authorities here - http://ec.europa.eu/newsroom/article29/document.cfm?action=display&doc_id=50061.

7. CHANGES TO THIS PRIVACY POLICY

We review our Privacy Policy regularly and we will place any updates on this web page: https://teltonika-iot-group.com/privacy-policy/. 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