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THE “GREEBLE SOFTWARE, LLC” PRIVACY POLICY

Last updated:  13 March 2019

Greeble Software, LLC (”Greeble,” “us,” “we,” “our”) operates BusyCop.com/greeblesoftware.com (the "Site"), and provides the BusyCop Dashcam/BusyCop Dashcam UK software (the “App”). This Privacy Policy explains how information (the “Data”) about You as a person or as a company (“You” or “Your”) is collected, used, and disclosed by Greeble when You use the Site or the App. Our Privacy Policy explains:

·         What Data Greeble collects

·         Why Greeble collects Data

·         How Data is used

·         Your use of the Site or App

·         Other Information Collected by Greeble

·         How Data is Protected

Greeble may change this Privacy Policy from time to time, as indicated by the date at the top of the Policy. In some cases, we may provide additional notice (such as adding a statement to the Site, sending an email notification, or posting a message within the App). We encourage You to review the Privacy Policy whenever You access the Site or the App to stay informed about Greeble’s information and practices, and in this way You can help protect Your privacy. Your continued use of the Site or the App after Greeble posts modifications to the Privacy Policy will constitute acknowledgment of the modifications and agreement to abide and be bound by the modified Privacy Policy.

Occasionally, at our discretion, we may include or offer third party products or services on the Site or through the App. These third party products or services have separate and independent privacy policies. This Privacy Policy does not apply to products or services offered by third parties which are not owned, controlled, or affiliated with Greeble. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback.

Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms and Conditions. For more specific terms related to Greeble products and services, please review the appropriate terms of use (“Terms and Conditions”) or End-User License Agreement (“EULA”) as appropriate.

WHAT DATA GREEBLE COLLECTS, WHY IT IS COLLECTED, AND HOW IT IS USED

                Profile and Contact Data

In order to create and maintain a user account on the Site or the App, You must provide an email address, username, and password. For Google sign-in, You must grant access to Your Google profile information; Greeble will only process Your email address and Google Account ID. In the process of creating Your account, We will assign You a unique user ID. Your Profile and Contact Data can be deleted, at Your request, upon account termination.

Your account is used to securely store Data and give You access in Your use of the Site or the App. We will use Your email address to occasionally send information related to our products and services, or if there are updates You need to be aware of to ensure You can use our products and services in a safe, reliable way. For these reasons, Greeble advises You:

·         Use a secure password

·         Keep Your account details confidential

Greeble does not sell contact information to any third party, for any purpose.

                Information about Your Device

When You register Your device via the App, Your device sends information to the Site that can be used to uniquely identify Your device. This includes information such as the device’s hardware ID (serial number), and the nickname (“Device name”) you’ve assigned. The Site supplies Your instance of the App with a unique identifier that can be used in lieu of the hardware ID. This information is used to provide service delivery, and identify Your device so we can associate it with Reports You may send. Hardware IDs are retained indefinitely, both to prevent fraud, and to protect Greeble from liability.

If You submit a Safetygram via the App, whether live or manually uploaded, additional protocol-level data may be included. Protocol-level data includes, among other things, timestamps that indicate when each App recording session started and stopped, and information about how many recordings sessions have taken place. Users also submit GPS information to help tag Safetygrams to locations. For more information, see below in, “Your Use of the Site or App.” 

                Log Data

Like many site operators, Greeble collects information sent by Your device whenever You visit the Site/Service, whether via the App or third-party browsing software.

This Log Data includes information such as Your device’s Internet Protocol ("IP") address, browser type, browser version, the pages of our Site that You visit, the HTTP “referrer” for each page You visit, the date and time of Your visit, the Reports that You view, the Report attributes You search for (including which areas You are monitoring for Live Reports), and other statistics. Greeble uses this information to protect and improve our products and services. IP addresses are anonymized after 14 months.

                Journey, Driving, and Location Data

                Safetygrams/Reports

Safetygrams act as incident reports. They can be uploaded to the Site via the App (in real time, or manually) or via an .mp4 file (manually).

Report data can include GPS location, speed, local time, any information captured in audio or video recordings, and any annotation You make to individual reports to help associate them with a particular vehicle or incident (e.g., vehicle color, type, license plate information, etc.). Reports begin collecting data at a point some number of seconds before the report time, and continue collecting data for some number of seconds after the report time, as configured in the App settings. Note that the range of data uploaded may, in practice, extend before and after these limits by a small amount (typically less than two seconds’ worth), to aid in the proper transmission and display of Your Report.

Most Report Content is visible to the general public, by default. You can adjust the visibility of each Report using the Site controls. Keep in mind that, even if you remove a Report from public view, Site moderators, administrators, and other Greeble employees retain the ability to view your Report. To permanently remove a Report from the Site, you may delete it using the controls provided by the Site.

Please note that You are responsible for any Content You submit, including audio/video recordings and Report data or annotations. For more information, see “Your Use of the Site or App,” below.

Google Maps

When You use Google Maps through the Site or the App, Your device GPS location data and unique device identifiers (including Your Google advertising ID via the Google Maps API) are collected and used by Google according to its privacy policy.

Marketing Data

WE DON’T WANT TO SPAM YOU. If Your communication preferences allow, we may use Your email address to contact You with the occasional newsletter, marketing email or promotion. Much more likely, though, we will simply be contacting You to remind You to finish a report You submitted, to notify You of a change in one of Your “watches,” or to notify You of a routine account maintenance action. Registered Users may adjust their communication preferences in the “My Account” area of the site.

Greeble collects IP addresses and mobile advertising IDs from App Users in order to facilitate targeted advertising. This information is anonymized or deleted after 14 months.

If You opt-in to the User Experience Program (“UXP”), the App is used to collect additional information:

Occupation Identifiers

Greeble reviews user occupation (relating to commercial or professional driving) to facilitate ad targeting.

Details concerning how you use the App

For example, we may analyze how long the app is open, which features have been used, and how frequently. This information helps us improve App quality and user experience, and assists us in ad targeting.

We use “Google Analytics for Firebase” to aid us in collecting this information. Detailed lists of specific items collected by Google LLC may be found here and here. To learn how Google uses data when You use their partners’ sites or apps, please reference the Google Privacy and Terms document.

Your UXP-related information is anonymized or deleted after 14 months. However, You may opt out of the UXP at any time by un-checking the “User Experience Program” checkbox in the App settings. You may delete previously collected Usage Data by using the “Manage UXP Data” feature in Settings->Misc (an internet connection is required). Furthermore, in the “general settings” for most devices, under Google->Ads, there are options (such as “Reset advertising ID” and “Opt out of Ads Personalization”) that You can use to control how this information affects You.

YOUR USE OF THE SITE OR APP

Users will typically act as the data controller for any content they provide to Greeble via the App or the Site. Data controllers are responsible for implementing appropriate measures to comply with applicable privacy laws. As a result, You are responsible for the Data You may provide, including:

·         Comments posted to the Site’s comment areas

·         User-generated Report Annotations

·         Audio/video recordings captured by the App, including any information contained therein

·         Geo-location (GPS) information

Special Categories of Data

Safetygrams may inadvertently capture special categories of personal data about You and/or Your passengers. For example, sound or images which reveal an individual’s religious beliefs, racial or ethnic origin, or sexual orientation.  It is Your responsibility to explain what information the App collects to any passengers in Your vehicle.

Greeble will only have access to special categories of personal data if such data is captured in Your device’s camera and/or microphone when using the Safetygrams feature, or if You manually upload such information.  Such access to these special categories of data is incidental to the use of the Safetygrams feature and Greeble will not actively process this data for any reason.

OTHER INFORMATION COLLECTED BY GREEBLE

In the course of providing the Site, the App, or any other services, Greeble may collect additional information which does not relate to You as a person or as a company.

Your device’s make and model

We use Your device’s make and model information to understand how different devices work with the Service.

                                App version information

We collect App version information in order to verify software compatibility, track upgrades, and determine how different versions of the App work with the Service.

Locale information

Locale information, such as Your preferred language or dialect settings, is used to aid us in providing readable text in the form You can most easily understand.

Feedback submitted via the “Leave Feedback” feature of the App

We want to hear Your feedback! We review and store feedback in the form of text comments. Please note, You are responsible for any data entered in text comments. Feedback text may be associated with Your device, IP address, or user account. We will keep Your feedback confidential.

Order information

We retain records of Your App-related Google Play purchases in order to properly maintain the Service and account balance information.

Cookies and similar tracking technologies

We, along with third parties who assist us in operating the Site, may monitor Your use of the Site through cookies, web beacons and other data collection tools. Unless You have adjusted Your browser setting to refuse all cookies, some cookies are placed on Your browser immediately as soon as You visit our Site. We reserve the right to monitor use of this Site as described in this policy by the use of any automatic data collection tools at all times and You consent to the use of these tools when You use and access our Site.

First-Party Cookies. Those used by our Site.

Website Use: We use first-party cookies to maintain Your user session while You are signed in, to remember Your user ID, Your username (if You have so elected), to store Your Site settings, and to store other Site choices You have made. Your session cookie is a necessary cookie; the Site will not function properly without it. It is also a persistent cookie; it remains present on Your device even after You close your browser window.

Third-Party Cookies. Set by a third-party source.

Google NID cookie: Google’s NID cookie contains a unique ID Google uses to remember Your preferences and other information to help customize ads on Google properties. For more information on Google’s cookies, please refer to Google’s Privacy Terms. You can opt out of Google’s ads personalization for your browser or Google account by visiting the following page: https://adssettings.google.com/.

How You can delete and block cookies

You can block cookies by activating applicable settings on Your browser. However, if You use Your browser settings to block all cookies (including necessary cookies), You may not be able to use all or parts of the Site.

Google Fonts

The Site uses Google Fonts. When Your browser loads our Site, it may contact Google to download a font file. This transaction leaves a record on Google’s servers, but does not involve any cookies. Click here to learn more about Google’s privacy policies.

 

HOW DATA IS PROTECTED

The security of Your Data is important to us. We use several different techniques to protect and maintain the integrity of Your data, including, but not limited to:

·         The encryption of App and Service connections, using TLS, when appropriate

·         Regular testing of server software, to ensure access controls operate as intended

·         On-disk hashing of passwords, secured using commonly accepted industry practices

·         The anonymization of IP addresses within 14 months

Please remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect Your Data, we cannot guarantee its absolute security.

Data and Information Retention

In order to limit the amount of unwanted or obsolete Data/information maintained by the Service, and to enhance user privacy, Greeble reserves the right to delete certain Data and other content. At our option, we may choose to consult You prior to such a deletion, but we are not required or expected to do so.

- Reports that do not meet the criteria laid out in the Content Policy may be deleted at any time.

- Reports that are not visible to the general public, due to moderator intervention, User selection, corruption, or any other reason, may be deleted at any time.

- Reports that were made in “Training Mode” may be deleted beginning 3 days after creation.

- Reports that are at least 6 months (183 days) old, which have not received any new votes in the preceding 6 months, may be deleted at any time.

- Other, non-Report Content may be deleted beginning 6 months after creation.

- Device or User accounts that have not logged any activity in the past 6 months are subject to immediate deletion.

Greeble deletes unwanted or obsolete Data/information at its own convenience. In practice, such Data/information may be retained for a longer period than described in this schedule, according to any aforementioned Policy terms. Remember that You can easily request deletion for any Reports You own, at any time, using controls provided by the Site.

 

Sharing Your Data

We may share Your personal data with third parties for the purposes set out below:

1.       Third-party data processors to assist with enumerated processing activities per the terms of associated data processing agreements, including IT and system administration services. This includes:

                                                                                       i.      Google LLC

 

2.       Our advisers including lawyers, bankers, auditors, and insurers, who provide professional services subject to applicable confidentiality agreements.

 

We do not allow third-party service providers to process Data for their own purposes and only permit them to process Data for specified purposes in accordance with the applicable terms and conditions.

 

International Transfers of Data

Greeble is headquartered in San Antonio, Texas. As a result, all Data is subject to transfer to the United States. In addition, Data provided to third parties may be processed at any location where they or their agents maintain facilities. By using the App, the Site, or other related services, You agree for Your Data to be transferred subject to the terms of this Policy and any applicable arrangements. Any Data collected, processed, and transferred to the U.S. as a part of App delivery and service is governed by the applicable EULA. Data collected, processed, and transferred as part of visiting or using the Site is governed by our Terms and Conditions.

For EU Individuals: Privacy Shield, and Your Rights Regarding Data that is Transferred into the United States

Greeble Software, LLC complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union to the United States. Greeble has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

To view the Privacy Shield List, click here.

Greeble Software, LLC is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

In compliance with the Privacy Shield Principles, Greeble Software, LLC commits to resolve complaints about Your privacy and our collection or use of Your personal information transferred to the United States pursuant to the Privacy Shield. European individuals with Privacy Shield inquiries or complaints should first contact Greeble Software, LLC at support@busycop.com.

Greeble Software, LLC has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If You do not receive timely acknowledgment of Your complaint, or if Your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to You.

If Your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, You may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Pursuant to the Privacy Shield Framework, EU individuals have the right to access their personal data. Upon request, we will provide You with access to the personal information that we hold about You.  You may also correct, amend, or delete the personal information we hold about You.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to support@busycop.com.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share Your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.  To request to limit the use and disclosure of Your personal information, please submit a written request to support@busycop.com.

We may be required to disclose Your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We shall remain liable for personal data involved in an onward transfer to third parties acting on our behalf (e.g., to Google LLC), unless we can prove that we are not responsible for the event giving rise to the damages. Google LLC complies with the Principles of the Privacy Shield.

 

GDPR For EU Individuals

Users located in the EU or UK may have additional rights regarding their personal data, subject to applicability of relevant laws. Those rights include:

1.       The right to be informed about what personal data is being processed, for what purposes, and who else the data may be passed to.

2.       The right to access personal data stored by a Data Controller.

3.        The right to correct, amend, or rectify errors in personal data. 

4.       The right to have personal data deleted under certain circumstances.

5.       The right to restrict processing or otherwise temporarily halt processing, for example when there is a dispute over the data.

6.       The right to “data portability” – that is, to have copies of any data supplied directly to the Data Controller provided in a structure, commonly used, and machine-readable format.

7.       The right to object to further processing of personal data.

8.       The right not to be subject to decisions based solely on automated processing.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.  If You need further assistance regarding Your rights, please contact us using the contact information provided below and we will consider Your request in accordance with applicable law. In some cases our ability to uphold these rights for You may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services You have requested. Where this is the case, we will inform You of specific details in response to Your request.

 

Children

The Site and the App are not directed to children. Use is strictly limited to persons 18 years of age or over. If You are under the age of 18, You are not permitted to use the Site, or register device or a user account via the App.

 

Greeble adheres to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect Data from any child under the age of 13.

 

We ask that minors not use the App. If a child under the age of 13 has provided us with Data, a parent or guardian of that child may request that such information be deleted from our records.

 

CONTACT US

If You are located in the United Kingdom or the European Union, You may contact Achieved Compliance Advocacy, our appointed representative in the UK, at the following addresses:

 

UK

By email: greeblesoftware@privacyrep.co.uk

By mail: 40 Oxford Road, High Wycombe, Buckinghamshire, UK HP11 2EE

 

If You have any questions about this Privacy Policy, please contact us:

Greeble Software, LLC

P.O. Box 769783, San Antonio, TX 78245

support@busycop.com

 

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