Privacy Policy

Effective Date: Jan 15, 2025

1. Introduction

SmartWheels (“we”, “us”, “our”) provides connected vehicle and telematics solutions that help users monitor driving behavior, vehicle health, safety events, and trip insights through our products, including SmartWheels Drive (mobile-based telematics) and SmartWheels OBD (hardware-based telematics) (collectively, the “Services”).

We are committed to protecting your privacy and being transparent about the data we collect, how it is used, and your choices.

2. Information We Collect

We may collect the following categories of information when you use our Services:

A. Account Information

  • First and last name
  • Email address
  • Phone number
  • Business / fleet information (if applicable)
  • Authorized users or driver profiles
  • Login credentials or authentication tokens
  • User ID (as setup by you)
  • Device ID (from device)

B. Vehicle & Driving Data

Collected from OBD devices, smartphone sensors, Bluetooth, or GPS modules:

  • Real-time and historical GPS coordinates
  • Trip start and end points, routes, distance, duration
  • Speed, acceleration, braking, cornering, idling, harsh events
  • Engine status, battery, fuel, diagnostics (DTC)
  • Crash or impact events
  • Device installation and telemetry diagnostics

C. Mobile Sensor & Technical Data (for SmartWheels Drive)

  • Precise Location (from device)
  • Photographs (only when attached by you when using Report Accident feature)
  • Technical device information (model, software version, carrier, battery information, etc.)
  • Phone sensor/movement data (display status, GPS, Bluetooth, etc.)
  • GPS / Location Information (coordinates, date and time, actual speed, etc.)
  • Patterns of application usage, user interaction, and screen views (analytics)

D. Usage Analytics

  • App navigation and feature usage
  • Screen views and interactions
  • IP address and browser type (web portal)
  • Cookies and analytic identifiers
  • Device and user ID
  • Product interaction data (from features used)
  • Application Crash data (for troubleshooting purposes only)
  • Application Version (to ensure that you have the most recent version)

E. Optional or User-Submitted Content

  • Notes or form submissions
  • Support requests and messages

We may receive some data from third parties such as fleet managers, insurers, or employers if you are enrolled through an organization.

3. How We Use Your Information

We use data to operate, improve, and secure our Services, including:

  • Delivering trip insights, dashboards, and reports
  • Monitoring vehicle health and telematics diagnostics
  • Providing alerts and notifications (speeding, curfew, engine, crash, etc.)
  • Supporting safety, risk scoring, or driver behavior analysis
  • Troubleshooting issues and responding to support requests
  • Authenticating users and preventing fraud
  • Improving model accuracy, features, and mobile performance
  • Complying with legal and regulatory obligations

For organizational customers (e.g., fleets, insurers, schools, or employers), data may also be used to:

  • Provide driver safety programs
  • Support claims handling or risk assessments
  • Comply with contractual obligations with that organization

We do not sell personal information for marketing purposes.

4. Legal Basis for Processing

Where required by privacy laws, we process data under:

  • Contract necessity (to deliver the Services)
  • Legitimate interests (safety, fraud prevention, product improvement)
  • Consent (e.g., precise location)
  • Legal obligations (regulatory or law enforcement requests)

5. Data Sharing & Disclosure

We may share information with:

A. Authorized Users

For example:

  • Fleet managers monitoring drivers
  • Family account owners
  • Organizations that onboarded you

B. Service Providers

Who support operations such as:

  • Cloud hosting (e.g., AWS)
  • Analytics
  • Customer support
  • Payment processing (if applicable)

They are contractually prohibited from using your data for their own marketing purposes.

C. Business Customers

If you are onboarded through an insurer, employer, or fleet, your data may be shared with that customer consistent with their program disclosures.

D. Legal, Safety, and Regulatory

We may disclose data when:

  • Required by law or legal process
  • Necessary to protect rights, safety, or property
  • For claims, insurance, or dispute resolution

E. Business Transactions

If SmartWheels is acquired, merged, or reorganized, your data may be transferred as part of the business assets.

We do not sell personal information to third parties.

6. Privacy Principles

We operate under the following principles:

  • We do not sell customer information.
  • We do not allow service providers to use information for their own marketing.
  • We require contractual protection of customer data.
  • We handle former users’ data with the same standard as current users.

7. Your Rights & Choices

Depending on your jurisdiction, you may have the right to:

  • Access your data
  • Correct or update information
  • Delete or request deletion
  • Withdraw consent (e.g., location permissions)
  • Request data portability
  • Restrict or object to certain processing

Requests can be submitted through the app or by contacting us.

8. Data Retention

Retention varies by data type and legal requirements:

  • Driving & Telematics Data: retained up to 90 days after account termination, then aggregated or anonymized for analytics
  • Account & Billing Data: retained up to 12 months for audit or compliance
  • Diagnostic Logs: retained up to 90 days for troubleshooting

Upon verified deletion request, personal data will be deleted within 30 days unless longer retention is required by law.

Aggregated or anonymized data may be retained indefinitely for non-identifiable analytics and product improvement.

9. Data Security

We use industry-standard protections, including encryption, secure storage, and access controls. Data is hosted on secure cloud infrastructure (e.g., AWS).

While we strive to secure your data, no method of transmission or storage is 100% secure.

10. Children’s Privacy

The Services are not intended for individuals below the legal driving age in their jurisdiction. We do not knowingly collect data from minors.

11. Cookies & Tracking

We use cookies, SDKs, and similar technologies for:

  • Authentication
  • Analytics
  • Feature performance

You may control cookies via browser settings.

12. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated via app or email. Continued use constitutes acceptance.

13. Contact Us

For privacy requests or questions:

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