Welcome to the Zonar GTC Mobile mobile application (“Zonar GTC” or “Service”). This Privacy Notice (“Notice”) describes how Zonar Systems, Inc. (“Zonar”) uses and protects any personal information (i.e., information that can be used to identify you) that Zonar collects, processes, or accesses when you download, set-up, access, and/or use the Service. It also outlines how Zonar uses your personal information in relation to the Service. By using the Service, you agree to the terms of this Notice, and consent to Zonar’s use of your personal information as further described in this Notice. Capitalized terms not defined in this Notice have the meaning set forth in the Zonar GTC Terms of Use (“Terms”) or in the Zonar Service Agreement.
In general, Zonar does not provide products and services directly to individual consumers or households. Zonar primarily provides products and services to school districts, transit authorities, and fleet operators in a business-to-business (B2B) context. Zonar does not sell Subsciber (as such defined in the Terms) data, and Zonar shares Subscriber data with third parties only to the extent necessary to provide the contractual services.
Personal Information We Collect
In providing the Service, Zonar may collect, process, transfer, or otherwise have access to various information and data, including your personal information. As used in this Notice, “personal information” refers to any information relating to an identified or identifiable natural person or household, and includes “personal data”, “personal information”, and such other substantially equivalent terms used in applicable data protection laws.
The types of personal information that Zonar has collected about you during your registration and use of the Service during the preceding 12 months are:
- Identifiers. We may collect personal information that can be used to identify you individually or your household, such as your name, username, phone number, alias, postal address, country of residence, unique personal identifier, online identifier, internet protocol address, email address, account name, phone number, driver’s license number, or other similar identifiers.
- Internet or other electronic network activity information. We may automatically collect certain information regarding your interactions with and use of Zonar GTC and information regarding your interactions with Zonar.
- Customer support data. Information collected when Zonar GTC user contacts Zonar for help with their account (name, telephone number and contact information, summary of issue discussed, and audio recording of voice call interactions for internal Zonar use).
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Sensitive Personal Information, including:
- Precise Geolocation Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using Zonar GTC, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
Sources of Personal Information
We collect personal information about you and how you interact with Zonar in several ways, including:
- Information You Provide to Us Directly. We collect the information you provide to us directly.
- Information from Your Mobile Device. Use of Zonar GTC requires access or permission to certain features of your mobile device, including location-based services. If you wish to restrict our access or permissions, you may do so in your device’s settings. Restricting our access may negatively impact your use of Zonar GTC.
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Information Automatically Collected or Inferred from Your Interactions with Us. We automatically collect technical information about your interactions with Zonar GTC (such as IP address and preferences), as well as from your interactions with Zonar representatives and agents.
- Use of Session Replay Tools. We use session replay tools to collect information regarding your use of the Service and record your interactions with Zonar GTC.
- Information from Third Parties. We receive information about you and your interactions with us from third parties, including the Subscriber, your employer, principal, coworkers and others interacting with us and/or using Zonar services.
We may combine information that we receive from the various sources described in this Notice, including third party sources and public sources (e.g., information you submit in a public forum), with personal information and use or disclose it for the purposes identified below.
How Zonar Uses Your Personal Information
- To Provide the Service and Enable Interactions Between You and Zonar. We will use your personal information to deliver the Service. This includes, but is not limited to, registration and administration of your account, providing you with and support in your interactions with us; diagnosing, repairing and tracking service and quality issues; facilitating an order, download, return, or exchange; providing requested information; communicating with you about your account or our data practices; installing and configuring changes and updates to the Service, programs and technologies related to interactions with us; authenticate those who interact with us; or to respond to your requests, complaints, and inquiries.
- To Provide Customer Support. Zonar has a relatively large customer support staff relative to our customer base. We strive to provide quality products and services including supporting you when you need it. To do this, we use your personal information to investigate and assist you in resolving questions or issues you have regarding Zonar products and services, and provide you support or respond to you.
- For Our Internal Business Purposes. We may use your personal information for our internal business purposes related to providing the Service, as well as other products and technologies. This includes, but is not limited to, evaluating or auditing the usage and performance of Service, programs and technologies related to interactions with us; evaluating and improving the quality of your interactions with us and the Service, programs and technologies related to interactions with us; designing new services; processing and cataloging your responses to surveys or questionnaires (e.g., customer satisfaction reviews); performing internal research for technological development and demonstration; conducting data analysis and testing; maintaining proper business records and other relevant records.
- For Legal, Safety or Security Reasons. This includes complying with legal requirements; protecting the safety, property or rights of Zonar, you, and those who interact with us, or others; and detecting, preventing, and responding to security incidents or other malicious, deceptive, fraudulent, or illegal activity.
- For any Other Purpose For Which You Provide Consent.
- In a De-identified, Anonymized or Aggregated Format. When converted to a de-identified, anonymized, or aggregated format, this data no longer constitutes personal information and we may use this information for any purpose.
- For Our Legitimate Interests or Those of a Third Party. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
With Whom We Share Your Personal Information
We do not currently sell your personal information, nor do we have any future plan to do so. However, to provide the Service, we may share your personal information with the following recipients:
- The Subscriber.
- Affiliates and Subsidiaries. We may share your personal information within the Zonar group of companies, which includes parents, corporate affiliates, subsidiaries, business units and other companies that share common ownership for the purposes described above.
- Service Providers. We may share your personal information with third party service providers working on behalf of us in order to provide and support the Service, to otherwise facilitate an interaction with Zonar that you request, or to support our relationship with you (including, but not limited to, hosting service providers, IT providers, operating systems and platforms, internet service providers, analytics companies, and marketing providers). We may contract with other companies to provide certain services, including shipping, identity verification, email distribution, market research, promotions management and payment processing. We provide these companies with only the information they need to perform their services and work with them to ensure that your privacy is respected and protected. These companies are prohibited by contract from using this information for their own marketing purposes or from sharing this information with anyone other than Zonar.
- Professional Consultants. We may provide your personal information to our professional consultants who are bound by confidentiality obligations and professional responsibilities, including accountants, lawyers, financial advisors, and audit firms.
- Business Partners. We may also provide your personal information or provide access to your personal information to our business partners, including for third party marketing or as a sale. If legally required, we will seek your consent before engaging in such sharing.
- For Legal, Security and Safety Purposes. We may share your personal information with third parties such as law enforcement or other government agencies to comply with law or legal requirements; to enforce or apply our Terms and other agreements; and to protect our rights and the property or safety of Zonar, our users, or third parties.
- In Connection with a Transaction. If we sell some or all of our assets, or merge or are acquired by another entity, including through a sale or in connection with a bankruptcy, we will share your personal information with that entity.
- Your Employer or Coworkers. If you interact with Zonar in connection with your employment, your employer, coworkers, or other individuals designated by your employer may view certain personal information that we collect in connection with your use of Zonar GTC or interaction with Zonar.
- Based on Subscriber Direction. Subscribers often want their data to be shared with third parties that also provide products and services to them. Zonar will share data with third parties when authorized to do so by the Subscriber. Data sharing is often enabled by application programming interfaces (API).
Your Rights
Please note that under applicable data protection laws and regulations you may have the following rights in connection with Continental’s processing and use of your personal information:
- Right of Information/Notice. You have the right to be informed about the types of personal information that we collect and how we use such personal information. Continental provides this Policy, detailing how personal information is processed, including the third parties with which Continental has shared your personal information. Continental will provide updated notice and information any time the types of personal information processed and/or Continental’s use and sharing of your personal information materially change.
- Right to Revoke Consent (where applicable). Where processing of your personal information is based upon your consent, you may withdraw consent at any time, and the Continental will stop processing and delete your personal information, subject to the Continental’s right to retain the data as allowed for lawful purposes, including to comply with its legal obligations and to use it exclusively on an anonymized basis. Consent must be withdrawn in writing to privacy@zonarsystems.com. See Cookies section below for additional information regarding placement of cookies and associated processing activities.
- Right of Access. You may obtain from the Continental confirmation regarding whether personal information is being processed and, if it is, access to the personal information and additional information about the processing of such personal information.
- Right to Correction/Rectification. You may have inaccurate personal information corrected and have incomplete personal information made complete.
- Right to Deletion. You may have personal information deleted in certain circumstances.
- Right to Restrict Processing. You may have additional processing of personal information restricted and/or temporarily blocked while the sufficiency, necessity, accuracy, or legality of processing of the personal information is contested.
- Right to Data Portability. You may be able to receive personal information for the purpose of providing that personal information to another controller, either through you as our business customer or directly by Continental.
- Right to Object. You may object, at any time and on grounds relating to their particular situation, that processing of personal information is unnecessary or excessive.
- Right to Complain to the Relevant Supervisory Authority. If you have a complaint about our privacy practices, you have the right to submit a complaint to a relevant supervisory authority.
You may exercise your rights by using the contact information set forth below. We may request additional information from you as necessary to allow you to exercise your rights, and we may deny your request where we have a legitimate basis to do so.
Security
We take your privacy seriously and use reasonable precautions to protect your personal information. For example, we encrypt certain communications using industry standards for encrypting such communications. However, we do not guarantee the security of your information. There is always a risk that information we collect or that you provide may be compromised. To mitigate this risk, you should (a) use secure usernames and passwords and carefully protect them from disclosure and (b) implement up-to-date security and virus protection on your device. If you suspect that your device’s security or your information has been compromised, or your password accessed or used by an unauthorized third party, please contact us immediately to have your password changed.
Cookies and Analytics Tools
We automatically collect certain non-identifying information about you and your use of the Service as described in this Notice. We use “cookies” to facilitate your interaction with Zonar GTC and to customize and improve your use of the Service. Cookies are small pieces of information or data stored on Your computer or mobile device that are used to determine your preferences and track certain behavior or activities when you use the Service. In providing the Service, we use only essential (functional) cookies. If you object to this practice, you may erase or block cookies; however, such action may negatively impact your use of the Service.
The Service uses Google Analytics, a web analysis service of Google LLC ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help analyze Zonar GTC’s performance and how users interact with and use the Service. We do not transfer your IP address to Google, nor do we allow Google to collect your personal information through the Service.
Third-Party Websites
When you click on a link to any other website or location, you will leave Zonar GTC and go to another site and another entity may collect personal information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Notice do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites. If you decide to access any third-party links appearing in Zonar GTC, you do so at your own risk.
Policy for Children
We do not knowingly solicit information from or market to children under the age of 16. If you become aware of any data we have collected from children under age 16, please contact us using the contact information provided below.
ZONAR DOES NOT SELL YOUR PERSONAL INFORMATION.
WE ARE COMMITTED TO SUPPORTING OUR CUSTOMERS WHEN THEIR USERS SEEK TO EXERCISE THEIR RIGHTS AVAILABLE UNDER THE CCPA.
Acceptance of Notice
By downloading, accessing, and/or using the Service, or otherwise providing your personal information to Zonar, you signify your acceptance of this Notice. If you do not agree to this Notice, please discontinue your use of the Service.
Modifications
Zonar may modify this Notice from time to time as the Service and applicable laws change. If we change our Notice, we will post a new statement on this website and update the effective date stated at the end of the Notice. You are encouraged to review this Notice from time-to-time for any updates or changes. If we make any material changes, we will inform you through the Zonar Ground Traffic Control® platform or by some other method of communication (like e-mail).
Please see the Zonar GTC Terms of Use for a more detailed legal explanation of our usages policies. Changes to the Notice become effective immediately upon notice to you. Notice may be given by posting the revised Notice on this website or by other means. Your use of the Service after notice constitutes your acceptance of the revised terms.
Contacting Zonar
If you have any questions about our Notice or our use of your personal information, you can contact us by e-mail at privacy@zonarsystems.com, phone at (877) 553-1113, or by regular mail to Zonar Systems, Inc., 821 2nd Avenue, 11th Floor, Seattle, WA 98104, Attn: Data Protection Office. Requests for changes to your personal information or deletion of your personal information (and cancellation of your registration) can be made to privacy@zonarsystems.com.
SUPPLEMENT FOR CALIFORNIA RESIDENTS
This section applies only to California residents. It does not apply to the following information:
- Information about individuals who are not California residents.
- Information about our own job applicants or our employees, contractors, or agents.
Pursuant to the California Consumer Privacy Act of 2018 (the CCPA), in the table below we provide a summary of the personal information we collected and disclosed in the prior 12 months. We have not “sold” personal information for money in the past 12 months. We do not knowingly sell or share any personal information of minors under the age of 16.
ZONAR DOES NOT SELL OR SHARE YOUR PERSONAL INFORMATION,
AS SUCH TERMS ARE DEFINED IN THE CCPA.
WE ARE COMMITTED TO SUPPORTING OUR CUSTOMERS WHEN THEIR USERS SEEK TO EXERCISE THEIR RIGHTS AVAILABLE UNDER THE CCPA.
| Categories of Personal Information We Collect | Categories of Third Parties With Whom We Disclose Personal Information for a Business Purpose | Categories of Third Parties to Whom Personal Information is Sold or Shared |
| Identifiers, such as your name, alias, postal address, country of residence, unique personal identifier, online identifier, internet protocol address, email address, account name, phone number, social media identifiers (e.g., Twitter handle, Instagram name, etc.), or other similar identifiers. |
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| Internet or other electronic network activity, such as your browsing history, search history, and information regarding your interactions with our Digital Properties. |
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| Customer support data, such as information collected when user of Zonar GTC contacts Zonar for help with their account (name, telephone number and contact information, summary of issue discussed, and audio recordings of voice call interactions for internal Zonar use). |
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| Sensitive personal information, including Specific Geolocation |
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Sensitive personal information. We use and disclose your Sensitive personal information only for (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) short-term, transient use; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of Zonar GTC or your mobile device; and/or (viii) purposes that do not infer characteristics about you.
Retention. We retain your personal information as long as necessary to fulfill the purposes outlined in this Notice unless we are required to do otherwise by applicable law. This includes retaining your personal information to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your personal information in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest.
Your Rights
California residents have certain rights, subject to legal limitations, regarding the collection, use, and sharing of personal information. California residents may exercise the following rights via emailing us at privacy@zonarsystems.com, or by calling (877) 553-1113.
- Right to Know. You may have the right to request information about the categories of personal information we have collected about you, the categories of sources from which we collected the personal information, the purposes for collecting, selling, or sharing the personal information, and to whom we have disclosed your personal information and why. You may also request the specific pieces of personal information we have collected about you.
- Right to Delete. You have the right to request that we delete personal information that we have collected from you.
- Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.
We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.
Verification: In order to exercise your rights, we will need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases, we will collect some or all of the following data elements: first and last name, email address, and telephone number. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are. We will inform you if we need such information.
Authorized Agents: Authorized agents may exercise rights on behalf of consumers by emailing us at privacy@zonarsystems.com, or by calling (877) 553-1113 and indicating that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on behalf of the consumer by providing signed permission from the consumer. We may also require the consumer to verify their own identity directly with us or to directly confirm with us that they provided the authorized agent permission to submit the request.
Timing: We will respond to Right to Delete, Right to Correct, and Right to Know requests within 45 days unless we need more time, in which case we will notify you and may take up to 90 days total to respond to your request.
The Effective Date of this version of the Zonar GTC Privacy Notice is 8 June, 2023