Below is the content from HMS website, need to Canadianized further:
Collection of Personal Information and Sensitive Personal Information
(this section pertains to HMS only, may be deleted, if not created clickable link to showcase table instead of sharing it below)
In the last 12 months, we have collected the following categories of personal information about you based on your specific transactions and interactions with us using the Services. For each category of information, the categories of third parties and service providers to whom we have disclosed the information in the last 12 months are referenced by a letter that coincides with the letter in the list of categories of service providers and third parties that follows soon after this table.
INSERT A TABLE HERE INSTEAD, IF WE ARE TO ADD.
|Category||Examples||Disclosed in Last 12 Months To||Sold or Shared in Last 12 Months to||Retention Period|
|Personal Identifiers||Name, alias, date of birth, fleet name, fleet code.||A, B, C, D, E, F, G, H, I||Duration of our relationship with you plus 10 years|
|Contact Information||Home, postal or mailing address, email address, home phone number, cell phone number.||A, B, C, D, E, G, H, I||Duration of our relationship with you plus 10 years|
|Correspondence||Records and copies of your correspondence if you contact us.||Duration of our relationship with you plus 10 years|
|Protected Classifications||Sex, gender.||C, D, H, I||Duration of our relationship with you plus 10 years|
|Geolocation Data||IP address and/or GPS location, latitude & longitude.||B, D, E, G, H, I|
|Portal and Mobile App Access and Usage Information||Username and password, account history, usage history, file access logs, and user access level.||D, H, I||Duration of our relationship with you plus 10 years|
|Vehicle Information||Your vehicle information number (VIN) which identifies information such as the model, year, and engine type of your Hino Truck, ownership start date, DTU date, ownership end date.||A, B, C, D, E, G, H, I||Indefinitely|
|Driving Data||Data about the operation and performance of your Hino Truck such as odometer reading, engine speed, vehicle speed, engine coolant temperature, engine operating time, engine idle time, distance traveled, fuel used, fuel economy, engine operating time, engine idle time, distance traveled, fuel used, fuel economy, hard breaking count, sharp acceleration count, excess speed duration, throttle position, accessory/PTO fuel usage, diagnostic trouble codes and diagnostic information and other similar information about the operation and performance of your Hino Truck||A, B, C, D, E, G, H, I||Indefinitely|
Of the above categories of Personal Information, the following are categories of Sensitive Personal Information the Company we may collect from you:
- Account Information (your Company account log-in, in combination with any required security or access code, password, or credentials allowing access to the account)
- Protected Classifications (sex, gender)
- Geolocation Data (IP address and/or GPS location, latitude & longitude)
Personal information does not include:
- Publicly available information from government records.
- Information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer, independent contractor, or applicant, or from widely distributed media.
- Information made available by a person to whom the consumer, independent contractor, or applicant has disclosed the information if the consumer, independent contractor, or applicant has not restricted the information to a specific audience.
- Deidentified or aggregated information.
We may collect your personal information from the following sources:
- You the consumer or your company when you use the Services and voluntarily submit information through the Portal and Mobile App
- Our employees and contractors, when you interact with them using the Portal and Mobile App
- Dealers when you interact with them to sign-up or register for the Portal and Mobile App
- We utilize cookies and web beacons to automatically collect information about users of the Portal
- Hardware and software which allows you as the owner, lessee, or operator of a Hino Truck to receive services available through the Hino connected vehicle offerings
- Company systems, networks, software applications, and databases you log into or use with the Services, Portal, and Mobile App
- Other information you may be required to provide as a condition to downloading, installing, or using the Mobile App
We may disclose your personal information to/with the following categories of service providers, contractors, or third parties:
- Product manufacturers/administrators
- Government agencies
- Data analytics vendors
- Security and risk management vendors
- Corporate customers
- Original equipment manufacturers (OEM) (suppliers and makers of the products / vehicles we sell or lease to our customers)
- Our subsidiaries and affiliates
- Contractors, Service Providers, Dealers, and other third parties we use to support the Services, Portal, and Mobile App
- Third-Party telematics providers from whom you receive services in connection with the long-distance transmission of computerized information of your Hino Truck
- A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Information held by us is among the assets transferred
We may collect your personal information for the following business purposes:
- To fulfill or meet the purpose for which you provided the information.
- To provide warranty coverage on products and services.
- To provide and communicate recall notifications to customers.
- To schedule, manage and keep track of customer appointments.
- To maintain records of when customers decline a service or sale.
- To respond to consumer inquiries, including requests for information, customer support, phone calls, and emails.
- To improve user experience of the Services, Portal, and Mobile App.
- To detect security incidents.
- To debug, identify, and repair errors that impair existing intended functionality of the Services, Portal, and Mobile App.
- To protect against malicious or illegal activity and prosecute those responsible.
- To verify and respond to consumer requests.
- To prevent identify theft.
- To comply with any court order, law, or legal process, including to respond to any governmental or regulatory request
- To enforce our rights arising from any contracts entered into between you and us
- To the extent we believe disclosure is necessary or appropriate to protect the right, property, or safety of us, our customers, or others
We may disclose your personal information for the following business purposes as numbered above:
1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14 and 15.
We do not and will not use or disclose your sensitive personal information for purposes other than the following:
- To perform the services reasonably expected by an average employee consumer or company who requests those services.
- transmitted personal information.
- To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
- To ensure the physical safety of natural persons.
- For short-term, transient use.
- To perform services on behalf of the Company.
- To verify or maintain the quality or safety of a product, service or device that is owned, manufactured, manufactured for, or controlled by the Company, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the Company.
- For purposes that do not involve inferring characteristics about the consumers or companies using the Service, Portal, and Mobile App.
Retention of Personal Information
We will retain each category of personal information in accordance with our established data retention schedule as indicated above. In deciding how long to retain each category of personal information that we collect, we consider many criteria, including, but not limited to: the business purposes for which the Personal Information was collected; relevant federal, state and local recordkeeping laws; applicable statutes of limitations for claims to which the information may be relevant; and legal preservation of evidence obligations.
We apply our data retention procedures on an annual basis to determine if the business purposes for collecting the personal information, and legal reasons for retaining the personal information, have both expired. If so, we will purge the information in a secure manner.
Third Party Vendors
We may use other companies and individuals to perform certain functions on our behalf. Examples include administering e-mail services and running special promotions. Such parties only have access to the personal information needed to perform these functions and may not use or store the information for any other purpose. Subscribers or site visitors will never receive unsolicited e-mail messages from vendors working on our behalf.
In the event we sell or transfer a particular portion of its business assets, information of consumers, contractors and applicants may be one of the business assets transferred as part of the transaction. If substantially all of our assets are acquired, information of consumers, contractors and applicants may be transferred as part of the acquisition.
Compliance with Law and Safety
We may disclose specific personal and/or sensitive personal information based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect our employees or the public.
The personal data record created through your registration with our Portal and Mobile App can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties.
Children Under the Age of 16
We do not knowingly sell or share the personal information of consumers under 16 years of age.
How We Protect the Information that We Collect
The protection of the information that we collect about users of the Service, Portal, or Mobile App is of the utmost importance to us and we take every reasonable measure to ensure that protection, including:
- We keep automatically collected data and voluntarily collected data separate at all times.
- We use internal encryption on all data stores that house voluntarily captured data.
- We use commercially reasonable tools and techniques to protect against unauthorized access to our systems.
- We restrict access to private information to those who need such access in the course of their duties for us.
We do not target, market to, or offer our products or services to consumers outside of Canada. You agree not to submit your personally identifiable information through the website if you reside outside Canada. If we become aware that a person residing inside the European Economic Area, European Union, Great Britain, or Switzerland has submitted their personal information to us, we will delete it.
You can submit any of the above types of consumer requests through any of the 2 options below:
- Submit a request via email at email@example.com.
- Call our privacy toll-free line at (866) 774-2773.
Consent to Terms and Conditions
Consumers With Disabilities
This policy is in a form that is accessible to consumers with disabilities.
Questions About the Policy
**This policy was last updated December 21, 2022.