Motor Tracker Privacy Policy
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Spanish：https://ztedevices.com/en-gl/legal/motor-tracker-es/
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This policy applies only to Motor Tracker products or services of ZTE Corporation
Last updated in: 8th Nov of 2019
If you have any questions, comments, or suggestions, please contact us through the following means:
E-mail: [email protected]
Company Name: ZTE Corporation
Registered Address: No. 55, Hi-tech Road South, Shenzhen, P.R.China
ZTE understands the importance of personal information to you, and will make every effort to ensure the security and reliability of your personal information. We are committed to maintaining your trust in us and abiding by the following principles to protect your personal information: consistency of authority and responsibility, clear purpose, selection of consent, minimum sufficiency, security, subject participation, openness and transparency. Meanwhile, ZTE promises to take appropriate security measures to protect your personal information in accordance with well-established security standards in the industry.
Please read and understand this Privacy Policy carefully before using our products or services.
This policy helps you understand the following:
1. How do we collect and use your personal information?
2. How do we use Cookies and similar technologies?
3. How do we share, transfer, and disclose your personal information?
4. How do we protect your personal information?
5. Your rights
6. How do we process the personal information of children?
7. How is your personal information transferred around the world?
8. How is this policy updated?
9. In what ways can you contact us?
I. How do we collect and use your personal information?
Personal information refers to the information that is recorded electronically or in other ways and that can be used independently or in conjunction with other information to identify a specific natural person or reflect the activities of a specific natural person. ZTE will collect and use your personal information only for the following purposes described in this policy:
（1） Business function 1: Registration as a user.
To create an account, you will need to provide the following information: your phone number ,create username and password .
(2) Business function 2: Motorbike equipment tracking, travel and location information are saved.
In order to provide motorbike location tracking, driving record and travel record function, you need to provide the Motorbike’s nick name, photo, brand, model, Ex-factory date, number plate, VIN code .the above information is optional except the nick name. After you switch on the device,the related information of the Motorbike which equipped with a Motor Tracker, including Rapid accelerate,Harsh brake,Sharp turn,Driving tired,Over speed,Vibration after ignition off,Suspected collision,suspected rollover,Towed,low battery,GeoFence in/out,ignition,ignition off,trip route, location,and IMEI/IMSI number of the Motor Tracker will be collected and saved,. And when you check the location and trip route information about the Motorbike on your App,the location data of your mobile phone will be collected after the App obtain your permission..
The information above will be stored within the territory of the European Union.If you unbind the device, we will not upload the above information to the server.
Storage period: We will delete all the information about the app accounts that have not logged in within one year, including all the information about your personal account, vehicles under your account, and bound devices. If your Motor Tracker is not been used for more than one year, we will delete all relevant information about this device
In the case of normal account usage, your information will continue to be stored.You can also delete your personal account by using the account with menu More->Account&security->Account cancellation. All the information of your personal account and the Motorbike information under the account and all the information records reported by the bound devices will be deleted.
3. Business Function 3 ：Push Function
In order to ensure that the application can receive notification messages , we will use Firebase Cloud Messaging to implement the push message function, which will use Instance IDs of your mobile phone. to determine which devices to deliver messages to. When you delete your personal account,we’ll make an API call to delete the Instance ID. After the call, data is removed from live and backup systems within 180 days.You can check the Firebase privacy to learn more:https://firebase.google.com/support/privacy/
If we want to use the information for other purposes not specified in this policy, we will seek your approval in advance. If we want to use the information collected for specific purposes for other purposes, we will seek your approval in advance.
II. How do we use Cookies and similar technologies?
We don’t use Cookies or similar technologies.
III. How do we share, transfer and disclose your personal information?
To ensure the security of your personal information, we shall follow the minimization principle and share, transfer, or disclose your personal information in accordance with applicable laws and requirements.
For the companies, organizations, and individuals that share personal information with us, we will take organizational and technical measures in accordance with the local laws and regulations, and require them to process personal information in accordance with our security standards, this policy, and related confidentiality and security measures.
1. Sharing
We only share your personal information in the following cases:
(1) After obtaining your explicit consent, we will probably share your personal information with other parties in future.
(2) We may share your personal information in accordance with laws and regulations or mandatory requirements of government authorities.
2. Transfer
We will not transfer your personal information to any company, organization or individual except in the following cases:
(1) Transfer with express consent: After obtaining your express consent, we will transfer your personal information to other parties.
(2) If personal information transfer is involved in a merger, acquisition, or bankruptcy liquidation, we will require new companies or organizations that hold your personal information to continue to be subject to this privacy policy. Otherwise, we will require the companies or organizations to re-request authorization from you.
3. Public Disclosure
We will disclose your personal information only in the following cases:
(1) With your express consent.
(2) Disclosure based on law: We may disclose your personal information in case of law, legal procedure, litigation, or mandatory requirements of government authorities.
IV. How do we protect your personal information?
1. We have used the security protection measures that comply with industry standards to protect the personal information provided by you against unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonable and feasible measures to protect your personal information.
SSL encryption is used for protecting the data exchange between your device and a “service”. We also provide the safe browsing mode of https for the portal website. We use encryption technologies to ensure data confidentiality. We use trusted protection mechanisms to prevent data from being maliciously attacked. We will deploy access control mechanisms to ensure that only authorized personnel can access personal information. In addition, we will hold the training course on security and privacy protection to enhance employees’ awareness of the importance of personal information protection.
2. Our data security capabilities:
We have been committed to protecting your personal information security.
We have taken various security measures, such as access control system, monitoring system, encryption, anonymization or pseudonymisation, employee training and so forth, to protect your personal information from unauthorized access, use, disclosure, modification, damage or loss and other forms of illegal processing.
We have developed a business continuity plan to ensure that services can be provided continuously. Our information security policies and procedures are designed in strict accordance with international standards, and reviewed and updated regularly, and the effectiveness of the security management architecture and measures is ensured through regular third party security audits. ZTE Corporation and some of its subsidiaries have passed the ISO 27001 information security certification, and can effectively protect your personal information. In case of personal information leakage, we will initiate an emergency plan, take effective measures to prevent the situation from getting worse, and notify the relevant supervisory authority and you in a timely manner.
3. We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We will retain your personal information only for the period required to achieve the objectives specified in this policy, unless the retention period needs to be extended or is permitted by law.
4. The Internet is not absolutely secure, and most communications, such as emails and instant messaging, are not encrypted. We strongly recommend that you do not send personal information through such means. Please use a complicated password to help us ensure the security of your account.
5. We shall regularly update and publicize the contents related to reporting such as security risks , personal information security impact assessments and so forth . If we affect your personal information rights in security assessment reports, we will actively disclose security risks. You can obtain detailed report contents in the following way:
E-mail: [email protected]
6. The Internet environment is not 100 percent secure. We will do our best to ensure or guarantee the security of any information you send us. If our physical, technical or management protection facilities are damaged, which results in unauthorized access, public disclosure, tampering or damage that affects your legal rights and interests, we shall assume the corresponding legal responsibilities.
7. After an unfortunate personal information security incident occurs, complying with the requirements stipulated by law,we will inform you in a timely manner of the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for voluntarily preventing and reducing risks, and remedial measures for you. We will inform you of the incident by email, letter, telephone or pushing notification in a timely manner. If it is difficult to inform the subjects of personal information one by one, we will release the notice in a reasonable and effective manner.
In addition, we will actively report the handling of personal information security incidents in accordance with the requirements of the regulatory department.
V. Your rights
In accordance with personal information protection laws, regulations, standards, and common practices in other countries and regions, we guarantee that you have the following rights over your personal information:
1. Access to your personal information
You have the right to access your personal information, except for exceptions as required by laws and regulations. If you want to exercise data access rights, you can access the data by yourself in the following ways:
Account information – If you want to access or edit your account’s personal information and payment information, change your password, add security information, or close your account, you can access app menu More->Account&security to perform such operations.
If you cannot access this personal information through these links/methods, you can send an e-mail to [email protected]. We will respond to your access request within 30 days. As long as we do not need to make too many efforts, we will provide you with other personal information generated when you use our products or services.
2. Correct your personal information
When you find that your personal information processed by us is incorrect, you have the right to request us to correct it. You can apply for a correction through the methods listed in “(1) Access to your personal information”. If you cannot correct this personal information through the above links, you can email [email protected] at any time and we will reply to your request within 30 days.
3. Delete your personal information
You can submit a request for deleting personal information in the following cases:
(1) If our processing of personal information violates laws and regulations.
(2) If we collect or use your information without your consent.
(3) If our processing of personal information violates an agreement with you.
(4) If you no longer use our products or services, or your account is canceled.
(5) If we no longer provide products or services for you.
If we decide to respond to your deletion request, we will also notify the entities that obtain your personal information from us and require them to delete your personal information in a timely manner, unless otherwise specified in the laws and regulations, or these entities obtain your independent authorization. After you delete information from our service, we may not immediately delete the corresponding information in the backup system, but we will delete the information during the backup update.
4. Change the scope of your authorization
Each business function can be implemented only after some basic personal information (refer to the first part in this policy) is obtained. You may grant or withdraw your authorization at any time for the collection and use of additional personal information.
You can perform the following operations by yourself:
Clear data at the menu of your mobile phone settings->apps->Motor Tracker->storage->clear data
If you cannot access this personal information through these links/methods, you can send an e-mail to [email protected]. We will respond to your access request within 30 days.
After you withdraw your consent, we will not process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.
5. Personal information subjects cancel accounts.
You can cancel your previous account at any time. You can perform the following operations by yourself:
Cancel at the APP menu “More->Account&security->Account cancellation”
After your account is canceled, we will stop providing you with products or services and delete your personal information as required by you, unless otherwise specified by laws and regulations.
6. Restrain Automatic decision-making of the information system
In some business functions, we may make decisions only based on non-manual automatic decision-making mechanisms such as information systems and algorithms. If these decisions have a significant impact on your legal rights and interests, you have the right to ask us for an explanation, and we will provide appropriate relief methods.
7. Respond to your above requests
To ensure security, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request, and we will respond within 30 days.
In principle, we do not charge for your reasonable requests, but we will charge for repeated requests that exceed a reasonable limit. We may reject requests that repeat unreasonably, require excessive technical means (for example, development of a new system or a fundamental change of current practice), and bring risks to other people’s legitimate rights and interests or that are extremely impractical (for example, involving information stored on the backup tape).
We will not be able to respond to your request in accordance with laws and regulations if:
(1) The case is directly related to national security and national defense security.
(2) The case is directly related to public safety, public health, and major public interests.
(3) The case is directly related to any criminal investigation, prosecution, trial, and execution of a judgment .
(4) There is sufficient evidence that you have subjective malice or abuse of rights.
(5) Responding to your request will cause serious damage to the legal rights and interests of yours or other individuals’ and organizations’.
(6) Business secrets are involved.
VI. How do we process the personal information of children?
Our products, websites, and services are mainly for adults. Without the consent of parents or guardians, children are not allowed to create their own user accounts.
If the personal information of children is collected with the consent of their parents, we will only use or disclose this information with the permit of law,the express consent of parents or guardians or the necessary protection of children.
Although local laws and customs define children differently, we regard anyone under 16 as a child.
If we find that we have collected personal information of children without obtaining confirmed parental consent, we will try to delete the information as soon as possible.
VII. How your personal information is transferred around the world?
In principle, the personal information we collect and generate in the European Union will be stored within the territory of the European Union.the Firebase Cloud Messaging we used will collect Instance IDs of your device. If the storage and/or processing of Customer Personal Data involves transfers of Customer Personal Data out of the EEA, and the European Data Protection Legislation applies to the transfers of such data, Google will ensure that:
a.the parent company of the Google group, Google LLC, remains self-certified under Privacy Shield on behalf of itself and its wholly-owned U.S. subsidiaries; and
b.the scope of Google LLC’s Privacy Shield certification includes Customer Personal Data.
Because we provide products or services through resources and servers around the world, this means that, with your authorization, your personal information may be transferred to an overseas jurisdiction of the country or area in which the products or services used by you are, or may be accessed from these jurisdictions.
There may be different data protection laws or even no laws in such jurisdictions. In such cases, we will ensure that your personal information is protected properly as it is protected in the European Union. For data transferred from the EU to outside the EU (if any), we do so by signing the Standard Contractual Clauses approved by the European Commission. We guarantee that all cross-border transmission of your personal data will be carried out base on your knowledge and ensure compliance with this policy and the applicable local legal requirements , such as signing a data protection agreement or data transfer agreement, etc. You can contact Data Protection Compliance Dept. of ZTE Corporation by mail [email protected] to obtain the corresponding transfer agreement text. We will use HTTPS/SSH encryption to secure the cross-border transfer of data.
VIII. How is this policy updated?
Our privacy policy may changes.
Without your express consent, we will not reduce your rights under this privacy policy.
We will release any changes to this policy on this page. For major changes, we will also provide more noticeable notifications (including notifications for some services, which will be sent via email to describe the specific changes in the privacy policy).
Major changes mentioned in this policy include but are not limited to the following situations:
1. Our service model has significantly changed. For example, the purpose of processing personal information, the type of processed personal information, and the mode of using the personal information.
2. Major changes have taken place in the ownership structure and organizational structure. Such as changes in owners caused by business adjustment or bankruptcy or mergers and acquisitions.
3. The major objects of personal information sharing, transfer, or public disclosure are changed.
4. Your right to participate in the processing of personal information and the way you exercise it have changed significantly.
5. Our responsible department for personal information security, contact method, or complaint channel have changed.
6. The personal information security impact assessment report indicates a high risk.
We will also archive the old version of this policy for your reference.
IX. In what ways can you contact us?
We have established a special personal information protection department – Data Protection Compliance Dept.. If you have any questions, comments, or suggestions on this privacy policy, please feel free to send an email to us at [email protected], which will be replied within 30 days.
In addition, you can send letters to the Data Protection Compliance Dept. of ZTE headquarters
To: Data Protection Compliance Dept. of ZTE Corporation
Address: 26/F, R&D Building, No. 55, Hi-Tech Road South, Shenzhen, China (Post Code: 518057)
If you are unsatisfied with our response, especially when our personal information processing activities have damaged your legal rights and interests, you can seek solutions through the following external channels:
For contact information about personal information supervisory authority in other areas, you can consult the local government.