Privacy policy
Effective Date: March 20, 2024
This Privacy Policy describes how Nexar Inc. and its affiliates and subsidiaries (including Nexar Ltd.) (collectively, “Nexar”, “we”, “us” or “our”) collect, store, use, and disclose personal data of individuals ("you", or “your”) who interact with us through one of the following channels:
- Our websites (such as https://getnexar.com/ and its subdomains), online ads and content, emails or other communications under our control (collectively, the "Site"),
- Our mobile applications (the “App”) or one of our dashboard cameras (collectively, our “Cameras”).
- Or other interactions when placing purchases or otherwise using our online platform via the Site (the "Platform", and together with the Site, App and Cameras – the "Services").
When providing our Services, we may process personal data about different categories of individuals, depending on their interaction with our Services. Such categories include: individuals who create an account with our Services, either independently or on behalf of our corporate customers or as part of a fleet or a team of drivers (“Users”); individuals who provide us with information through the Site or otherwise interact with the Site (“Visitors”), and prospective customers, partners and participants from our events and webinars we may hold (“Prospects”).
Specifically, this Privacy Policy describes our practices regarding:
- Data Collection
- Data Uses
- Data Location
- Data Retention
- Data Disclosure
- Cookies and Data Collection Technologies
- Communications
- Data Security
- Data Subject Rights
- Roles and Responsibilities
- Additional Information and Contact Details
Please read this Privacy Policy and make sure that you fully understand and accept it. If you object to this Policy, please discontinue and avoid using our Services.
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined in Section 5 below), please avoid any interaction with us or any use of our Services.
1. Data Collection
We collect, generate, or receive personal data regarding our Visitors, Users, and Prospects so that we can provide our Services. Personal data is typically collected and generated through your interaction with our Services, through automatic means, directly from you or third-parties. To the extent that such data concerns a non-human entity (e.g., the bank account of a company or business), we will not regard it as “personal data” and this Privacy Policy shall not apply to it.
Specifically, we collect the following categories of data:
(a) Usage Data (about our Users and Visitors)
When you use our Services we may collect certain technical data about you. We collect or generate Usage Data either independently or with the help of our Service Providers (as detailed in Section 5 below), including through the use of "cookies" and other tracking technologies (as further detailed in Section 6 below).
Usage Data includes connectivity, technical and aggregated information, such as your ride start and end locations; IP addresses, wireless networks, cell towers and Wi-Fi access points; non-identifying data regarding a device, operating system and browser; activity, communication and performance logs; issues and bugs; and user activity on our Services.
(b) User Data
User Data may include the following sub-categories (depending on how you use the Services):
- Your Account Information: when you sign up for our Services you provide us with your contact details and password (which will be stored in a hashed format). To the extent you have integrated supported third-party “Single Sign-On” services (e.g., Google or Okta), you may log-in to our Services through such third-party services, in which case we will receive your name, e-mail, user ID, and any other information you choose to share with us via your account on such third-party services.
- Billing and Shipping Information: If you choose to make any purchase via our Services, you may also provide us with your billing and shipping details and preferences.
- Personal Data Received from Insurance Companies and Mobility Platforms: In some locations, Users may choose to provide us with certain information concerning their insurers and their insurance plans, or have their insurer or mobility platform (e.g., Uber, if the User is an Uber driver) provide this information directly to us. This means that we may collect or receive and process data such as the Vehicle Identification Number (VIN), policy ID, claim ID, driver details and identifier, and information about your insurance broker or agent.
- Fleet Data: Our App can be used to create a fleet of drivers or join a fleet that is managed by a separate entity or individual (such as your employer) (“Fleet” and “Fleet Manager”, respectively). If you are a Fleet User, we will collect details about you such as your name, email, and unique fleet identifier assigned to you by your Fleet Manager. Additionally, when you communicate with us (e.g., for support), or interact with other drivers of the Fleet through the Services, we may receive additional data from you and other members of this Fleet.
- Collision Reports: If you submit or otherwise make available to us any recordings concerning traffic incidents, collisions, road conditions, or violations, we may analyze such recordings and produce reports, which may be shared with you, your insurer or other third-parties (subject to your authorization) in accordance with Section 5 below. Should you contact us to generate a collision report, you may also provide us with details such as the location and time of the collision, photos, license plates involved, as well as involved parties’ insurance companies and policy numbers. Should you choose to submit such a report to your insurance company through the App, we will be collecting the data to monitor the performance of such a submission.
(c) User Content
User Content is information generated by the User when using our Services and includes information collected by the Camera used by the User. User Content includes images and videos, sensor data, location, GNSS location data, data obtained from your device’s gyroscope and accelerometer sensors, and App user ID. Please note that when Nexar provides Services to a Fleet, Nexar will process User Content as a data processor on behalf of the respective Fleet Manager. For more information on our data processing role, please refer to Section 10 below.
(d) Public Content
Anonymized Images and videos of interest relating to traffic and road conditions, which will be gathered and shared amongst Users and on our CityStream products to improve their safety and driving experience. These images may have persons, license plates, and other personal information recorded via the Camera (e.g., papers that are being left on the dashboard, parking cards, etc.). To prevent the identification of individuals in such content (including by us), we make sure to anonymize all those identifiable elements. Such anonymization is performed on the device, even before the information is sent to Nexar. Please note that we may use anonymized Public Content as a part of our Citystream service, subject to your consent. You may opt-out of contributing anonymized Public Data anytime via the App’s settings menu. Also, you or any data subject can perform a Takedown Request of Public Data for a particular location as long as it is demonstrated the right to request the content removal.
(e) Training Data
Considering our company mission to contribute to a safer and more efficient driving experience, it is of utmost importance that we continuously develop our Vision AI algorithms, which are used to perform object detection and image classification that produce relevant information for our products. A critical requirement of this development process is the need for a small fraction of the images collected by the Cameras used by our Users. These images serve as Training Data and are instrumental not only in enhancing existing Services but also in pioneering new features designed to improve driving conditions.
The Training Data comprises images captured by both in-cabin and road-facing Cameras:
- In-Cabin Images and Videos: These are used to develop our safety-related events detection algorithms, such as distracted driving, by analyzing the behavior of drivers and passengers within the vehicle. Such images and videos may include personal data.
- Road-Facing Camera Images: These images are crucial for identifying a wide range of road assets and work zones, and assessing overall road conditions. They may capture third-party data subjects, such as pedestrians and other vehicle drivers. License plates and other potentially identifiable details may be also captured.
This data also plays a crucial role in the ongoing development and refinement of state-of-the-art anonymization techniques to ensure the privacy of our Users and any other data subject.
Despite the inclusion of non-anonymized content, we uphold the highest standards of data security and privacy:
- Limited Access: Access to Training Data is strictly confined to the team members directly involved in the AI development process.
- Robust Security Measures: We employ advanced encryption and stringent access controls to safeguard against unauthorized access to the data.
- Retention Policy: The Training Data is retained exclusively for a limited period of time for the training purposes for which it was collected, ensuring it is not used beyond its intended scope. For more information, see Section 4.
- Lifecycle: The Training Data closely mirrors the lifecycle of personal data. When a User decides to delete their rides or deactivate their account, we ensure that the corresponding Training Data is also deleted from our systems.
(f) CRM, Visitor & Prospect Data
Personal data relating to our Prospects and Visitors, which we automatically collect or receive from you when you interact with our Services, ads, communications or other content under our control (e.g., through the Contact Us on our Site or App). We may also receive CRM, Visitor & Prospect Data from other sources. For example, if you participate in an event, conference or webinar that we sponsor or participate in, we may receive your contact details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from the event organizers. We may also receive your contact and professional details from our business partners or Service Providers, and through the use of tools and channels commonly used for connecting companies and individuals to explore potential business and employment opportunities.
For the purposes of the California Consumer Privacy Act (“CCPA”), in the past 12 months, we have collected the following categories of personal information: Identifiers; Internet or other electronic network activity information; Customer records information, Audio, electronic, visual, thermal, olfactory, or similar information; Inferences from personal information collected, and geolocation information. We do not use or disclose Sensitive Personal Information as defined in the CCPA.
We have collected such personal information from the following sources:
- Automatically, when you visit the Site
- Users and Fleet Managers
- Insurers and Mobility Platforms
- Service Providers
2. Data Uses
We process personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services, e.g., in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Users, Visitors, Prospects, ourselves and our Services (“Legitimate Interests”).
If you reside or are using the Services in a territory governed by privacy laws under which "consent" is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by or via the Services, or due to nature of such processing) (“Consent”), your acceptance of our Terms of Service and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of Consent. If you wish to revoke such Consent, please contact us at privacy@getnexar.com.
Specifically, where we act as ‘data controllers’, we use personal data for the following business and commercial purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
Usage Data, User Data, User Content | |
To provide, facilitate, operate, and enhance our Services. |
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To provide assistance and support, to test and monitor the Services, or to diagnose and fix technological problems. |
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To personalize our Services, including by recognizing individuals and remembering their information when they return to our Services, and to provide localization and personalization capabilities. |
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To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties. |
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To authenticate the identity of our Users, and to allow them to access and use our Services. |
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To contact you with general or personalized service-related messages, as well as promotional messages that may be of specific interest to you. |
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To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity. |
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To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose. |
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To enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties. |
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To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards. |
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Public Data | |
To perform on-device anonymization to remove any identifying or identifiable information for the purposes of using such anonymized Public Data in connection with our Citystream service and products. |
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Training Data | |
We use Training Data for the following purposes: To train and improve our AI and computer vision algorithms and ensure their effectiveness and reliability across various scenarios; to enhance and develop new features designed to improve driving conditions; and to further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties. We also use Training Data to develop and refine state-of-the-art anonymization techniques to ensure the privacy of our Users and any other data subject. |
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CRM, Visitor & Prospect Data | |
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners. |
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To gain a better understanding on how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others’ user experience and the value they can generate from using our Services, so we could continue improving our products, offerings and the overall performance of our Services. |
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To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity. |
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To contact you with promotional messages that may be of specific interest to you. |
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To facilitate our engagement with our marketing affiliates and perform our contracts with them. |
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To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose. |
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To enforce our Terms of Service, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties. |
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To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards. |
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Please note that we do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
3. Data Location
We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States, Canada, Europe, Japan, Australia and the United Kingdom, Israel and other locations depending on where you are using our Services and as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
While privacy laws may vary between jurisdictions, Nexar is committed to protecting personal data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
Nexar and its subsidiaries are headquartered in Israel which is recognized to be offering an adequate level of protection for the personal data of UK and EEA residents by the European Commission and the UK Information Commissioner’s Office (ICO). We transfer personal data from the EEA and the UK to Israel on this basis. For data transfers from the EEA or UK to countries that are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission. You can obtain a copy by contacting us via privacy@getnexar.com.
4. Data Retention
We retain personal data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, as necessary for allowing our Users' insurers to meet their own obligations or legitimate needs, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy. Without derogating from the foregoing, the retention of Training Data is limited to the lifecycle of the Personal Data of the User to which it relates. Consequently, if a User requests to delete their Personal Data held with us, we will also delete the User’s respective Training Data.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at privacy@getnexar.com.
5. Data Disclosure
Legal Compliance: in exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant, or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so and solely to the extent that we believe is strictly necessary to comply, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Service Providers: we may engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), data analytics services, mapping services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, billing and payment processing services, e-mail and SMS distribution and monitoring services, session or activity recording services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, support and customer relation management systems, and our business, legal, financial and compliance advisors (collectively, "Service Providers"). These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
We use Shopify as our e-commerce platform. This platform allows us to sell our products online and simplify your user experience. When you access or place an order with Nexar through the online shop, Shopify collects your information, for example for risk and fraud screening. Therefore, whilst Nexar makes use of Shopify, please refer to Shopify’s Privacy Policy.
Insurance Companies and Mobility Platforms: we may notify your selected insurer or integrated mobility platform of probable road collisions involving you and/or third-parties and share with it any related recordings, data and reports by one of two ways: (a) in accordance with the instructions of your insurer, in cases where your use of our Services is part of your agreement with your insurer, and you have granted your insurer authorization to receive such recordings or reports from us; or (b) in the event you have authorized Nexar to do so automatically by either providing Nexar with your insurer and policy details through the App (in which case the “Report to Insurer” feature on the App will become active automatically) or by manually turning “on” the “Report to Insurer” feature on your App (provided that you have previously shared your insurer and policy details with Nexar through the App).
Teams and Fleets: the Services allow you to create and join teams or fleets of drivers using the App. For example, you may create a team consisting of your family members or friends, or a fleet consisting of drivers at your workplace, who are each using the App individually on their mobile device, so that you may interact with each other, share drive recordings or collision reports with each other, etc. Your data will be shared with other members of the teams or fleets you create or join, in accordance with the sharing settings of such team or fleet (which are managed either by each user, or by the team owner or Fleet Manager). We advise you to review the sharing settings for each team you create or are invited to, and adjust your sharing activities accordingly. Fleet Managers gain access and visibility into their fleet’s users’ location data, ride videos (live or post ride), and alerts concerning incidents during the ride. Fleet Managers may also appoint additional administrators for their fleet, who will also gain access and visibility to all or some of this data, depending on the privileges set by the fleet manager. For more information about the role of fleet managers as “data controller” of their fleet users’ data, please see Section 10 below.
Third-Party Websites and Services: our Services may include links to third-party websites, and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third-party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such websites and third-party services. We do not receive or store your passwords for any of these third-party services.
Protecting Rights and Safety: we may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Nexar, any of our users or any members of the general public.
Nexar Subsidiaries and Affiliated Companies; Change of Control: we may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Nexar or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant and/or a potential investment, personal data may be shared with the parties involved in such an event. If we believe that such an event might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
For the avoidance of doubt, Nexar may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
For the purposes of the CCPA, specifically in the past 12 months, we may have disclosed to the third parties listed above the following categories of personal information: Identifiers; Professional or employment-related information; Internet or other electronic network activity information; Customer records information, Audio, electronic, visual, thermal, olfactory, or similar information; Inferences from personal information collected, and geolocation information. We do not use or disclose Sensitive Personal Information as defined in the CCPA.
6. Cookies and Data Collection Technologies
We and our Service Providers use “cookies”, anonymous identifiers, pixels, and other technologies to provide our Services and ensure they perform properly, analyze our performance and marketing activities, and personalize your experience. Such cookies and slimier files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, previously indicated by a User, Prospect, or Visitor on our Site.
We may disclose non-identifiable/aggregated extracts of such information to our partners for our legitimate business purposes. Under some data protection laws, including the California Consumer Privacy Act (CCPA) and other US state privacy laws, such disclosure of this data to third parties for targeted advertising may be considered as “sale” or “sharing” of personal information. Please see our Cookie Policy for more information about the types of cookies we use, or click the “Cookie Settings” at the bottom of our Site’s homepage to set your preferences and opt out of the sale or sharing (for targeted advertising) of your data.
We use Google Analytics to collect information about the use of our Services. Google Analytics collects information such as how often users visit the Services, which pages they visit when they do so, and which other sites they used prior to coming to our Services. We do not merge the information collected through the use of Google Analytics with personally identifiable data. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Services is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can learn more about how Google collects and processes data specifically in connection with Google Analytics here. Further information about your option to opt-out of these analytics services is available here.
7. Communications
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: we may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset instructions, etc. You can typically control your communications and notifications settings from your Nexar user profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Notifications and Promotional Communications: we may send you notifications concerning messages and other updates in your user account (such as messages concerning collision reports, road conditions etc.). We may also send you notifications about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. SMS, phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Nexar at any time by sending an e-mail to: privacy@getnexar.com, changing your communications preferences in your user profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
8. Data Security
We and our hosting services implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, confirmed also by Nexar’s ISO/IEC 27001 and 27018 certifications. However, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties.
9. Data Subject Rights
If you wish to exercise your privacy rights under any applicable law, including (to the extent applicable) the EU or UK General Data Protection Regulation (GDPR or UK GDPR, respectively) or the California Consumer Privacy Act (CCPA), such as the right to request access to, and rectification or erasure of your personal data held with Nexar, or to port such personal data, please log into the Platform, and select either the “Export” or “Delete” options in your account dashboard settings.
If you wish to exercise your right to restrict or object to such personal data’s processing, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at: privacy@getnexar.com. If you are an individual subject to the GDPR/UK GDPR, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact from the data which we will make available to you, any personal data related to others.
You may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us. In such cases, we may request further information to verify such power of attorney and authorization.
10. Roles and Responsibilities
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Nexar is the “data controller” of User Data, Usage Data, User Content, personal data contained in Public Data (solely for the purpose of anonymizing such data and so long as such data relates to an identified or identifiable person), Training Data, and CRM, Visitor & Prospect Data. With respect to such data, we assume the responsibilities of the data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, to the extent our Service Providers process such data, the relevant Service Provider will assume the role of “data processor”.
When Nexar provides Services to a Fleet, Nexar is the “data processor” of Fleet Data and User Content. With respect to such data, the respective Fleet Manager assumes the responsibilities of data controller and as such directs and instructs us how and for what purposes to process such data.
Accordingly, when Nexar processes Fleet Data as a data processor, it will do so strictly in accordance with the relevant Fleet Manager’s reasonable instructions and as further stipulated in our Data Processing Addendum or other commercial agreements we have entered into with such Fleet Manager. The Fleet Manager, as controller of such data, will be responsible for meeting any legal requirements applicable to data controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
For the avoidance of doubt, each Fleet Manager is solely responsible for providing adequate notice to their users – including sufficient reference to the processing of their personal data via the Services and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.
11. Additional Information and Contact Details
Updates and amendments: we may update and amend this Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Sites, Platform and/or Services. After such notice period, all amendments shall be deemed accepted by you.
External Links: while our Sites, Platform and/or Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Sites, Platform and/or Services for the website or application of such third-parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Sites, Platform and/or Services.
Requirements under US State Privacy Laws: this Privacy Policy describes the categories of personal information we may collect and the sources of such information (in Section 1), and our retention and deletion practices (in Sections 4 and 9). We have also included information about we may process your personal information, which includes “business information” for the intents and purposes of the CCPA and similar US state laws, as applicable. We do not sell your personal information for the intents and purposes of the CCPA. We may share and disclose your personal information to third parties or allow them to collect personal information from our Services as described in Sections 5 and 6, if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you integrate the services of third parties with our Services, or direct us to disclose your personal information to third parties, or as otherwise describe in Section 3. If you have any questions or would like to exercise your rights under US state laws, you may contact us at privacy@getnexar.com. We will not discriminate against you by withholding our Services from you or providing a lower quality of service to you for requesting to exercise your rights.
Our Services are not designed to attract children under the age of 16: we do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Sites, Platform and/or Services, we will attempt to prohibit and block such use and will make all efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at privacy@getnexar.com.
Nexar has appointed PrivacyTeam Ltd. As its Data Protection Officer, for monitoring and advising on Nexar’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by Nexar, you can contact privacy@getnexar.com or our DPO at dpo@getnexar.com.
Questions, concerns or complaints: if you have any comments or questions about this Privacy Policy or if you have any concerns regarding your privacy, please contact us at privacy@getnexar.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.
EU and UK Representative: We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact in the EU and UK.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit the following website https://prighter.com/q/13925556347.