Privacy Policy - Modernizing School Bus Transportation

Effective January 1, 2020

In this Privacy Policy (“Policy”), we, VACE Company Limited (VACE), our subsidiaries, and our parent. (collectively “VACE,” “we”, “us”, or “our”), provide information about how we collect, use, process, and transfer personal data. We are a global organization sharing the data we manage across businesses (legal entities), business processes, and information systems around the world. Therefore, for this Policy, we use the term “personal data” broadly to cover the many privacy and data protection laws applicable to us; “personal data” means information related to an identified natural person, or that could reasonably be used (by itself or in combination with other data reasonably available) to identify a natural person. It does not include data where the identity has been removed (anonymized data).

Scope

This Policy applies to our websites, products, services, software, or applications (“apps”) on which we post a direct link to this Policy or refer to within this Policy (collectively the “Services”). This Policy covers only data collected through the Services and not any other data collection or processing, including, without limitation, data collection practices of other services that maintain their own, separate privacy policies. Occasionally, we refer to this Policy in relation to surveys and special-purpose web pages, for example, our Careers web pages; under such circumstances, this Policy applies as modified in the particular notice or consent request (e.g., with respect to types of data collected or purposes of collection).

Types of Data and Collection Methods

We collect a variety of personal data through the means described below. You have choices about the data we collect. When you are asked to provide data to us, you may choose not to. But if you decline to provide data, your ability to use the applicable Services may be diminished or restricted.

Data you submit. We collect your name, email address(es), mailing address(es), and telephone number(s).

Cookies. We use cookies, to collect data about your use of our websites or apps. A cookie is a small text file that is stored on the hard drive of your computer or device when you access the site. We use cookies to help operate our sites and Services, including to: (a) remember you so you don’t have to enter the same information when you return to the site, (b) provide you with customized content or offers on the site; (c) develop aggregate statistics to help monitor site performance, conduct research, improve our content and Services, and (d) help protect the security of our sites and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our Services or websites you visit.

Software and apps: We create a variety of software and apps that may help improve performance and security of our Services, or offer other benefits.

Third Party Sources and Links: We may also obtain personal data from third party sources such as data brokers, social networks, other partners, or public sources. Our website may contain links to third-party websites. Each of these third parties may have its own privacy policy. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

ZiiP Bus, ZiiP Home: Our ZiiP Bus and ZiiP Home mobile applications (“apps”) are available to staff and parents in schools that have contracted with. When the apps are downloaded to your smartphone, tablet or computer, information is collected about you such as name, email address and the student’s name, address, school system ID, bus stop name, school and grade. Information that identifies the bus stop location and student’s school allows parents to determine the time of arrival of the bus at the student’s bus stop or school through geolocation tracking of the student’s school bus or transportation vehicle.

Collection Purposes, Use of Data

We collect and process personal data about you with your consent and/or as necessary to provide the Services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests. The purposes for which we collect and use data include:

To respond to the request that you sent us such as your request for information, or your request to purchase or subscribe to a Service;
To provide, manage, maintain, and secure the Services you request;
To operate and improve our business, including to administer, protect, and improve our Services and our systems, to develop new products and services, and for other internal business purposes;
To better understand the preferences of the users of our Services, compile aggregated statistics about usage of our Services, and help personalize your experience of our website and Services;
To provide you with information about our technologies, Service releases, news, and other communications; and
Any other use we describe in this Policy or at the point where we collect the data.

To achieve these purposes, and to the extent permitted by applicable law, we may combine the various types of data that we collect from different sources.

Where We Store and Process Data

We store and process data in the Singapore and on servers around the world, including, without limitation, the European Economic Area. Wherever we store or process personal data pursuant to this Policy, we take measures to ensure that the data is processed in accordance with this Policy and in compliance with applicable law.

California Residents and the California Consumer Privacy Act

Under the California Consumer Privacy Act (“CCPA”), California residents have certain rights regarding their personal information such as:

The Right to Know – the right to know the specific pieces of personal information we collect, sell to third parties and disclose for business purposes, upon your request
The Right to Delete – the right to delete personal information you provide to us
The Right to Opt-Out – the right to opt out of our sale of personal information to third parties
The Right to Notice at Collection – you have the right to notice of the categories of personal information collected from you and how they are used
The Right to Be Free from Discrimination – you have the right not to be discriminated against based on exercise of your rights under the CCPA

Categories of personal information under the CCPA that may be collected by us for LoJack branded Services, including in the last 12 months:

Categories of information collected	Sources – how this information is collected	How we use the information collected from sources	Services that use the information that is collected	Who we disclose the category to for business purposes	Who we may sell collected information to
Name and personal identifiers, like your physical and email address	You and possibly the dealership where vehicle was purchased	To provide our Services to you, to communicate with you, and to improve our Services	SureDrive and LoJack Stolen Vehicle Recovery System	We share this data with our service providers, including those that you instruct us to send this information to	We don’t sell this category of information
Other information about you, like phone number	You and possibly the dealership where vehicle was purchased	To provide our Services to you, to communicate with you, and to improve our Services	SureDrive and LoJack Stolen Vehicle Recovery System	We share this data with our service providers, including those that you instruct us to send this information to	We don’t sell this category of information
Commercial information, like records of products purchased and vehicle information (make, model, year, and VIN)	You and possibly the dealership where vehicle was purchased	To provide our Services to you, to communicate with you and to improve our Services	SureDrive and LoJack Stolen Vehicle Recovery System	We share this data with our service providers and other business partners	We may sell VINs to data service providers for commercial purposes. We don’t sell other commercial information
Internet or other electronic network activity, like account password	You	To provide our Services to you, improve our Services and to understand the preferences of our users, compile aggregated statistics about usage of our Services, and enhance our users’ experience of our website and Services	SureDrive	We don’t share this information	We don’t sell this category of information
Geolocation	From the SureDrive device installed in your vehicle	To provide our Services to you and to compile aggregated statistics about usage of our Services	SureDrive	We share this data with service providers, including those that you instruct us to send this information to	We don’t sell this category of information

Categories of personal information under the CCPA that may be collected by us for our branded Services, including in the last 12 months:

Categories of information collected	Sources – how this information is collected	How we use the information from sources	Services that use the information collected	Who we disclose the category for business purposes	Who we may sell collected information to
Name and personal identifiers, like your physical and email address and student ID	Parent in a school district that subscribes to the service and the school district that subscribes to the Service	To provide our Services	Here Comes the Bus	We share this data with service providers	We don’t sell this category of information
Other information about you, like phone number, bus stop name, and school and grade of student	Parent in a school district that subscribes to the service and the school district that subscribes to the Service	To provide our Services	Here Comes the Bus	We share this data with service providers	We don’t sell this category of information
Internet or other electronic network activity, like account password	Parent in a school district that subscribes to the service	To provide our Services, and enhance our users’ experience of our website and Services	Here Comes the Bus	We share this data with service providers	We don’t sell this category of information

Disclosures of Personal Data

We access your personal data within ZiiP. We may also offer training or other services to the employees and workers of our business customers. In such cases, we may share data relating to the use of our training and other services with the identified business customers for their business use. We may also share your data as required by law or in the interest of protecting or exercising our or others’ legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings. We may share or transfer your data in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business. Finally, we may also share your personal data where you have granted us permission.

Your Choices

Opt-In/Out. We offer you the ability to opt-in or opt-out of data collection, use, or sharing. If you wish to opt-out, please contact us as described in the Contact Us section below.
Access. If you would like to access your personal data that we maintain, or the personal data you have submitted is no longer accurate, current, or complete, and you wish to update it, please contact us as described in the Contact Us section below. If you need to correct your personal data, we reserve the right to use data obtained previously to verify your identity.
Do Not Track. We do not currently respond to “Do Not Track” (“DNT”) signals sent by web browsers. A uniform standard has not yet been adopted to determine how DNT signals should be interpreted and what actions should be taken by websites and third parties that receive them. However, you may use a variety of other means of controlling data collection and use, including cookie controls in your browser settings and the personalized advertising controls described in the Cookies section above.

Retention

We retain personal data while your account is active, or as needed to provide you Services. We will delete personal data within a reasonable time after the data is no longer necessary for the business purpose for which it was collected. We will, however, retain and use personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

Transmissions over the Internet are never 100% secure or error-free. However, we take reasonable steps to protect your data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. It is your responsibility to safeguard your passwords and User IDs and to notify us using one of the Contact methods listed below if you ever suspect that your password or User ID for one of our Services has been compromised. You are solely responsible for any unauthorized use of our Services conducted via your password and User ID.

Children’s Privacy

Our Services are not directed at children under the age of 13. We do not intentionally or knowingly collect personally-identifiable information from children under 13. If you are under 13, please do not provide any personal data to us.

Amendments

We reserve the right to change, modify, add, or remove portions of this Policy at any time, but will alert you that changes have been made by indicating on the Policy the date it was last updated. If we change the Policy in a material way, we will provide appropriate online notice to you at least 30 days in advance and/or obtain your express consent as required by law. When you visit our websites or use our Services, you are accepting the current version of this Policy. We recommend that users revisit this Policy on occasion to learn of any changes.

Contact Us

To contact us, send us an email at [email protected]