FleetWallet3 Privacy Policy

1. Purpose and Scope of Privacy Policy

Cubic Telecom Limited trading as Cubic3 (“Cubic”, “we”, “us” and “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy applies to your use of the Cubic FleetWallet3 Application.

This Privacy Policy is intended to explain to you (referred to as “you” or “your”) how your Personal Data will be handled by Cubic3 and sets out the basis on which we use, process, store or disclose any personal information, including the personal information detailed below (“Personal Data”) that we collect from you or that you provide in relation to your use of the FleetWallet3 Application (“FleetWallet3 App”).

Cubic Telecom Limited trading as Cubic3 is an Irish company with company number 415374 and a registered address at Arthur Cox Building, Earlsfort Terrace, Dublin 2, Ireland and is the data controller for your Personal Data.

2. Your Personal Data collected and obtained

Personal Data Details
Identity Data This covers your name, surname, password and email address.
Relationship Data This covers information we collect in connection with the management of our relationship with you, which may include details of queries you submit, your name, surname and email address.
Vehicle Identification Data This covers information we process relating to the identification of your vehicle, specifically the location, registration number, VIN number (Vehicle Identification Number), vehicle type, vehicle brand, vehicle year, fuel type, tank size capacity and telematics ID.
Transaction Data This covers information we process relating to your refuelling transaction, specifically fuel type, vehicle type, registration number, your name, transaction date, transaction time, transaction address, fuel card ID, transaction number and merchant details.
Before and after your refuelling transaction we also process the following information: your mileage, fuel level and location.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences

3. Methods of collection of your Personal Data

We use different methods to collect data from and about you including through:

  • Direct Interactions: We collect or generate certain Personal Data from you through your use of the FleetWallet3 App and our interactions with you. This can include Relationship Data and any passwords you create to use the FleetWallet3 App.
  • Data supplied by Fleet Manager: Your Fleet Manager provides Personal Data relating to you which may include your name, surname and email address and Vehicle Identification Data.
  • Data supplied by third party data providers: Third parties such as payment transaction facilitators and vehicle telematics technology sharing providers provide your Transaction Data to us.

4. How and Why We Use Your Personal Information

The following table details the legal bases on and purposes for which we collect and process your Personal Data:

 

Legal Basis Purpose(s)
Performance of a Contract

The processing is necessary for the performance of a contract with you
  • To provide you with the FleetWallet3 App integration service and to comply with our obligations under the Terms of Use.
Legitimate Interests

It is necessary for the purpose of our legitimate interests to collect and process this Personal Data

 General Administration
  • To correspond and communicate with you;
  • To comply with our general administration including managing your queries, complaints, or claims and to send service messages to you; and
  • To comply with a request from you in connection with the exercise of your privacy rights.

Managing the FleetWallet3 App Service

  • To verify your identity in order to provide you with access to the fuel pump.
  • To administer the FleetWallet3 App and for internal operations, including troubleshooting, service management and optimisation in order to provide you and our other customers with a better customer experience;
  • To verify the accuracy of your information and create a better understanding of you as a customer;
  • To investigate, prevent or take action regarding illegal activities and violations of our Terms of Use and/or applicable laws; and
  • To meet our legal and regulatory obligations.

Improving Application Functionality & Efficiency

  • To provide, improve, test and monitor the effectiveness of the FleetWallet3 App
IMPORTANT: Before we process your Personal Data to pursue our legitimate interests for the above purposes, we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary for our legitimate interests and that the processing which we conduct does not adversely impact on these rights and freedoms.
Compliance with Legal Obligation
  • To comply with European Union and local laws.
To defend a Legal Claim
  • To file legal proceedings;
  • To investigate, establish, exercise or defend a legal claim; and
  • To settle legal claims.

We will only use your Personal Data for the purposes for which we collect it (as outlined in this section 4), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you in accordance with section 10 of this Privacy Policy and we will explain the legal basis which allows us to do so.

5. Automated Processing

We do not use automated decision making, such as profiling, to process your personal data.

6. Disclosure of your Information

We sometimes share your personal information with third parties e.g. companies who perform important functions for us based on our instructions and applying the necessary confidentiality and security measures. We share your information with the following third parties:

  • Your Fleet Manager
  • The fuel supplier

7. Transfers of your Personal Information outside the European Union or the European Economic Area:

At all times, we intend to store and process your personal information within the European Economic Area (“EEA”). We also ensure that any of our trusted third-party partners store and process your personal information within the EEA. Should this ever change, and we need to share your personal information for storage and processing with third parties or organisations located outside the EEA, we will only transfer your personal information in the following circumstances:

  1. If that country provides an adequate level of protection for personal information as set down by the European Commission; or
  2. Where the transfer is made under a legally binding agreement which covers the European Union requirements for the transfer of personal information to data processors outside of the EEA such as Module 2 or Module 3 of the Standard Contractual Clauses or such other approved mechanism or model approved by the European Commission.

8. Retention of your Personal Data

In general, we will keep your Personal Data for as long as is necessary for the purposes for which it was obtained from the date of collection or, where you enter into a contractual arrangement with us, following the end of the performance of our contract (which may be up to 7 years in some cases). Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably, in our view, expect or require us to preserve your Personal Data.

9. Your rights and how to exercise them

This table below sets out the rights which you have to address any concerns or queries with us about our processing of your Personal Data. Note that in certain circumstances, these rights may not be absolute. You can exercise any of these rights by submitting a request in writing to us. Contact details are set out at section 10 of this Privacy Policy. You also have the right to lodge a complaint with your local data protection supervisory authority. For further information see your local data protection supervisory authority’s website or reach out to them for contact information.

If you have any concerns in relation to how your Personal Data is used or processed, you have the right to lodge a complaint with the Data Protection Commission who can be contacted at [email protected] You can visit the website of the Data Protection Commission at www.dataprotection.ie for more details.

If you have any concerns in relation to how your Personal Data is used or processed, you have the right to lodge a complaint with the Data Protection Commission who can be contacted at [email protected] You can visit the website of the Data Protection Commission at www.dataprotection.ie for more details.

 

Right Further Information
Right of Access You have the right to request a copy of the Personal Data held by us about you. If you exercise this right, you will receive confirmation about whether we process your Personal Data and if so, a copy/copies of your Personal Data.
Right of Rectification You have the right to correct the Personal Data that we process about you if the Personal Data we hold about you is inaccurate or incomplete.
Right of Erasure You have the right to ask us to erase your Personal Data where: (1) it is no longer necessary to perform the contract; (2) you withdraw your consent and there is no other legal basis permitting us to process your Personal Data; (3) you object and we have no overriding legitimate grounds; (4) your Personal Data have been unlawfully processed; or (5) your Personal Data must be erased to comply with a legal obligation. Please note that in some cases erasure may not be complete or immediate to the extent that some of your Personal Data may be required in order for the FleetWallet3 App to function properly.
Right to Restriction of Processing You have the right in certain circumstances to restrict our processing of your Personal Data – for example if you contest the accuracy of the Personal Data we hold about you or you object to us processing your Personal Data.
Right to Data Portability You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible. This right only arises where: (1) we process your Personal Data with your consent or where it is necessary to perform our contract with you; and (2) the processing is carried out by automated means.
Right to Object You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.
If you have any concerns in relation to how your Personal Data is used or processed, you have the right to lodge a complaint with the Data Protection Commission who can be contacted at [email protected] You can visit the website of the Data Protection Commission at www.dataprotection.ie for more details.

 

We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request. We may extend this up to two months if necessary, however, we will inform you if this arises.

10. Changes to this Privacy Policy and Questions

If we amend this Privacy Policy, in whole or part, at our sole discretion, any changes will be effective immediately upon communicating the revised Privacy Policy to you.

If at any time we decide to use your Personal Data in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you and you will have a choice as to whether or not we use your information in the new manner.

If you have any questions, comments or concerns about the way your Personal Data are being used or processed by Cubic, please submit your question, comment or concern in writing to [email protected]