Privacy Notice

Last Updated: January 2025

Important Information About MetraFleet

MetraFleet and its affiliates (collectively referred to as "MetraFleet", "we", "us") takes its data protection and privacy responsibilities seriously and is committed to respecting privacy. This Privacy Notice explains how we collect, use and share personal information in the course of our business activities.

How to Contact Us

The MetraFleet entity responsible for your personal information will be the member of MetraFleet that originally collects information from or about you. This will be explained at the point at which your personal information is first collected by that MetraFleet entity, for example where you or the business you work for engages us to provide a service or where we engage you to provide a service to us.

Any questions about this Privacy Notice can be sent to privacy@metrafleet.com.

If you no longer wish to receive any marketing material, you can unsubscribe by emailing unsubscribe@metrafleet.com.

We may amend this notice from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this notice.

You might find external links to third party websites on our website. This privacy notice does not apply to your use of a third party site.

Personal Information We Collect and When and Why We Use It

We collect information about you if you:

• Register with or use one of our website(s) or online services
• Purchase one of our services
• Make an information request
• Work with us as a business partner
• Are identified as a potential customer or business partner

If You Use Our Websites or Online Services

On our website, personal information (such as your name, address, telephone number, or email address) is collected when you voluntarily submit it through a website form, such as during a request for information about our services.

Other information that may also constitute personal information (such as your browser type, operating system, IP address, domain name, number of times you visited the website, dates you visited the website, and the amount of time you spent viewing the website) may be collected via cookies and other tracking technologies (such as transparent GIF files). Aggregate information (such as how many times visitors log onto the website) may also be collected.

The business uses third-party services to collect standard internet log information and details of visitor behaviour patterns. We do not make, and do not allow third parties to make, any attempt to find out the identities of those visiting our website. We use the information to report on visitor numbers, and to make improvements to our service. Information is only collected if visitors opt in, restrictions are in place to protect this data from becoming identifiable.

If You Purchase Our Products or Services

Where you purchase or receive our services, we may collect:

• Basic identification and contact information (such as your name, address, telephone number, and email address) in order to fulfil your order, provide our services and manage your account
• Financial information (such as bank account information, tax registration information, billing details) in order to manage and process payments you make to us
• Information held by credit reference agencies and fraud prevention agencies, in order to assess your application for the use of our services
• Information about your use of our products and services and your satisfaction with them, in order to continuously improve the products and services that we provide to you
• In relation to certain of our products and services, location based information

If You Work With Us as a Business Partner

Where you are engaged by us to provide goods or services to MetraFleet, we may collect:

• Basic identification and contact information (such as your name, address, telephone number, and email address) in order to fulfil your order, provide our services and manage your account
• Financial information (such as bank account information, tax registration information, billing details) in order to manage and process payments you make to us
• Information held by credit reference agencies and fraud prevention agencies, in order to assess your application for the use of our services

If You Are Identified as a Potential Customer or Business Partner

We collect information directly, from other members of the MetraFleet group, and from other third party lead providers about organisations who we feel might like to hear from us or receive our products and services. In those circumstances, we may collect basic identification and contact information (such as your name, address, telephone number, and email address) in order to market our goods and services to you. We will only do so in accordance with your preferences and/or as described in this privacy notice.

SMS Text Messaging

If you opt in to receive SMS text messages from MetraFleet, we collect your phone number and use it to send you fleet alerts and notifications. Regarding SMS:

• Message frequency varies based on your notification settings
• Message and data rates may apply
• Reply STOP to opt out at any time
• Reply HELP for assistance
• We do not sell or share your phone number with third parties for marketing purposes

The Legal Basis for Using Your Personal Information

We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

• You have provided your consent to us using the personal information (for example in relation to our electronic direct marketing activities)
• Our use of your personal information is in our legitimate interest as a commercial organisation (for example where we look to market our services to potential business customers, or in order to make improvements to our products and services) - in these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the Legal Rights section below
• Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (for example your basic contact information and billing information required to make/take payments)
• Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example where we are required to disclose personal information to a court or tax authority)

We may use Artificial Intelligence (AI) to help us provide you with a requested product or service. If we use AI, we'll do so responsibly, and where necessary, we'll disclose that the content is generated by AI.

Sharing Personal Information

We share your information in the manner and for the purposes described below:

• Within MetraFleet, where such disclosure is necessary to provide you with our services, offer our products and services or to manage our business
• With third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems
• With credit reference agencies and organisations working to prevent fraud in financial services
• With our regulators, and relevant supervisory authorities, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies
• We may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our business partners, affiliates or advertisers
• If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets

Direct Marketing, Profiling and Automated Decision Making

How We Use Personal Information to Keep You Up to Date

We may use personal information to let you know about MetraFleet products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

How You Can Manage Your Marketing Preferences

To protect privacy rights and to ensure you have control over how we manage marketing with you:

• We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you
• You can ask us to stop direct marketing at any time - you can ask us to stop sending email marketing by following the 'unsubscribe' link you will find on all the email marketing messages we send you. Alternatively, you can contact us via the link provided at the top of this document. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email)
• You can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser

We recommend you routinely review the preference settings within your MetraFleet account.

Automated Decision Making

We may carry out automated decision making in the following areas:

• Credit rating checks
• Driver behaviour via vehicle telematic information

International Data Transfers

MetraFleet operates on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the EU/EEA. MetraFleet will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.

To this end:

• We ensure transfers within MetraFleet will be covered by agreements entered into by members of MetraFleet which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within MetraFleet
• Where we transfer your personal information outside MetraFleet or to third parties who help provide our products and services, impact assessments will be conducted, and we obtain contractual commitments from them to protect your personal information
• Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information is disclosed

How We Protect and Store Your Information

Security

We have implemented and maintained appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned. Measures we take include placing confidentiality requirements on our staff members and service providers; destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected.

Storage

We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Your Rights (GDPR)

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information:

• Right to access: You have a right to request that we provide you with a copy of your personal information that we hold
• Right to rectify: You have a right to request that we rectify inaccurate personal information
• Right to erase: You can request that we erase your personal information in limited circumstances
• Right to restrict processing: You can ask us to restrict your personal information in certain circumstances
• Right to data portability: You can ask us to provide your personal information in a structured, commonly used, machine-readable format
• Right to object: You can object to any processing of your personal information which has our legitimate interests as its legal basis
• Right to object to direct marketing: You can request that we change the manner in which we contact you for marketing purposes
• Right to lodge a complaint: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

Contact Us

The primary point of contact for all issues arising from this privacy notice is our Data Protection Officer. The Data Protection Officer can be contacted via:

privacy@metrafleet.com

If you have any questions or concerns regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.