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  1. Information about you and your Fleet.ph account – Name,email address, postal address, phone number, company name, customer and delivery information (such as scheduling information and delivery destination), and in some cases, your photograph. You provide this information to us directly during the account registration process.

  2. Vehicle information of drivers – Transportation method, vehicleyear, make, model, color, and license plate number. You provide this information to us directly when using our Platform.

  3. Driver behavioral information – We collect information abouthow you drive your vehicle. This includes time, location, bearing, speed, and accuracy. We collect this information automatically when you use our Platform.

  4. Geolocation information – Driver location is collected from theirdevice's native location service, which combines GPS, cell-tower, Wi-Fi, and other sensor data to accurately pinpoint a driver's latitude and longitude while the driver is "on-duty." We do not access, collect, or store location information from a driver's mobile device when they are off-duty or offline. We may collect other information such as application crash reports or application usage analytics for drivers who are not online for the express purpose of providing and improving our Platform. For example, if you engage the chat function as a driver while off-duty, we may collect and use application usage analytics for support purposes to understand the driver journey. We may remotely log in to the application, with your permission, to resolve an issue if our application crashes.

  5. Business contact information – We collect personal informationfrom individuals when we attend or host events, conferences, and other business meetings. This information includes business contact information such as name, email address, and phone number.

  6. Device information – IP address, device type, operating system,manufacturer, model and version number, and unique device identifiers such as your device ID, but not IMEI. We collect this information automatically when you use our Platform.

  7. Browser and usage information – Operating System (OS)running on your device, Internet Protocol (IP) address, access times, browser type, and language, and the website you visited before our Website. We also collect usage details, such as time, frequency, and use pattern. In some cases, we analyze information on specific end users such as the amount of time spent on the Platform. In other cases, we look at data in the aggregate. We use this information to optimize our Services. We collect this information automatically when you use our Platform.

    To learn about your information collection choices and to opt-out of data collection, see the “Your Choices” section below.

 

Information We Receive from Other Sources

 

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  1. Clients of our Services – Clients of our Platform may provideinformation about you when they submit content through our Platform. For example, you may be mentioned in a troubleshooting ticket opened by someone else. We also receive your email address from other users when they provide it to invite you to our Platform. Similarly, a dispatcher may provide your contact information when they designate you as a driver on their company’s account.

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  1. Client customers – We may receive personal data about you from one of our Client’s customers. We will only use this information for the purpose of providing our Services. For example, a recipient of a delivery may provide personal information about you when submitting a support ticket.

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  1. Other partners – We receive information from partners to helpus find potential customers and enhance our Platform with useful information. For example, information provided by our partners allows us to provide route optimization services, such as when we receive mapping and location information or spatial data analytics from Google Maps.

How We Use, Share, and Disclose Information 

We use collected information to:

 

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  1. Communicate with you – We may contact you to respond toyour inquiries, requests, and/or send important notices either via email, SMS, push notifications, and in-app notifications. This includes, for example, sending confirmations, invoices, technical notices, routing updates, security alerts, administrative messages, and providing you with updates about our Platform and new features. See “Your Choices” below to learn how to manage your communication preferences.

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  1. Provide customer support – We use your personal and Platformusage information to resolve support issues that may arise through your use of our Platform. CTO Global Services Inc employees are prohibited from viewing the content of data you import into your Fleet.ph account, except when necessary to resolve your support issues. Access is limited to the data required to resolve your support issues.

 

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  1. Deliver and improve our Services – We use your information todeliver and analyze how you use our Platform, develop new products and services, and improve functionality, quality, and user experience. For example, we track geolocation, driver behavior, and other information to facilitate route optimization and other features. This includes using aggregated, anonymized data to improve our Services.

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  1. Market our Services – We use your information to market ourPlatform. For example, we may send you an email notification about new product features. Additionally, we may use pseudonymized personal information collected on our website to better tailor marketing or website content, including to run or optimize our service, or for other purposes, such as internal research. To learn more about how we track and use your information, see the “Use of Cookies and Other Tracking Technologies” section below.

  2. Advertise – Our MobileApp does not contain or allow in-apptargeted advertising at this time. We also do not use push notifications or in-app notifications to display advertisements to our users.

  3. Store data – We store data on servers hosted by Google andDigitalOcean. We use appropriate technical, administrative, and physical measures to secure your data during storage.

 

We share information about you and your vehicle(s) with third parties only in the manner described below:

  1. Marketing and advertising – We do not sell information aboutyou to advertisers or other third parties. We do not currently share your information with third parties for marketing purposes, but if that changes we will obtain your consent first.

  2. Other users – If you register or access our Platform through aFleet.ph Client, certain information about you including your name, contact info, photograph, content and past use of your account may become accessible to that Client and other individuals with whom the Client shares access. If you are a Client managing a particular group of users within our Platform, we may share your contact information with current or past users, for the purpose of facilitating Services-related requests.

  3. Mergers and acquisitions – If your personal information istransferred to a party unaffiliated with CTO Global Services Inc as part of merger, acquisition, or sale of all or a portion of our assets, we will provide you with notice prior to transferring your personal information to the new entity. Notice will be provided directly through our Services.

  4. Legal purposes – We disclose your information when webelieve that disclosure is (1) reasonably necessary to comply with any applicable law, regulation, subpoena, legal process, or enforceable governmental request; (2) necessary to enforce the provisions of the Notice; (3) required to enforce our Terms of Service, including investigation of potential violations; or (4) necessary to protect against harm to the rights, property, or safety of CTO Global Services Inc, our users, or the public as required or permitted by law.

  5. External processing and Sub processors – We provide yourinformation to other third parties to help us with our business activities, products, and services. These companies are authorized to use your information only as necessary to provide these services or perform them on our behalf.

     

    We use the following sub-processors to operate our Services.