Privacy Policy
1. Introduction
Welcome to Secured Mobility LLC’s Privacy Policy (“Policy”) for SMART-tag.net, Secured Mobility LLC’s public-facing website (where the general public can visit to learn general information about SMART tag products and services, applicants can apply for jobs, and potential customers can request additional information on SMART tag products and services (the "website").
This Policy describes how Secured Mobility LLC (“SMART tag”) uses and protects any Personal Information (i.e., information that can be used to identify you) that SMART tag collects about you when you visit and interact with the website. It also outlines how SMART tag uses the information it collects about you. By using visiting and/or interacting with the website, you agree to the terms of this Policy, and consent to Secured Mobility LLC’s use of the information we collect through the website. Please read this Policy carefully.
Summary of the website: Our mission is to improve the safety and efficiency of pupil transportation operations, by providing hardware and software that helps automate vehicle and student ridership data collection to allow school bus fleet operators to understand how their vehicles are being used and for monitoring bus ridership. The website is a public forum that allows us to share information about our products and services with current and prospective customers, post job openings, and share information about our organization.
Applicability: This Policy does not apply to job applicants or our employees.
When You Represent a Third Party: Whenever you interact with us on behalf of another individual or entity, such as by providing or accessing Personal Information about another individual, you represent that your interactions and exchanges comply with applicable data protection laws. You shall have sole responsibility for any violation of privacy laws as a result of a failure to inform the other individual about how their Personal Information will be processed or to obtain any necessary consent from such an individual.
Changes: We may update this Policy from time to time, and at least once per year we will review this Policy to ensure accuracy with and appropriateness to the website. The current Policy will be effective when posted. Please check this Policy periodically for updates. If any of the changes are unacceptable to you, you should immediately discontinue your use of the website and cease interacting with us. When required under applicable law, we will notify you of any changes to this Policy by posting an update on this website. When required under applicable law, we will seek your consent before making material changes to the way we handle Personal Information previously collected from you. If you do not provide such consent, Personal Information will continue to be used in a manner that is consistent with the version of this Policy under which it was collected.
2. Sources of Personal Information
Personal Information refers to any information relating to an identified or identifiable natural person or household.
We collect information about you and how you interact with us in several ways, including:
a. Information you provide to us directly. We collect the information you provide to us directly.
b. Information automatically collected or inferred from your interaction with us. We automatically collect technical information about your interactions with us (such as IP address and browsing preferences).
c. Information from public sources, including government entities from which public records are obtained and information you submit in public forums.
d. Information from third parties. We may receive information about you and your interactions with us from third parties, such as from your employer or coworkers, third party service and content providers, credit reporting agencies, companies that provide or sell lists of potential purchasers, and others interacting with us.
We may combine information that we receive from the various sources described in this Policy, including third-party sources and public sources, and use or disclose it for the purposes identified below.
3. Types of Personal Information We Collect
The types of information that we may have collected about you during your visits to and interactions with the website during the previous 12 months are:
a. 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.) social security number, driver’s license number, passport number, or other similar identifiers.
b. Personal Information defined by California Civil Code Section 1798.80, including name, telephone number, address, passport or other government-issued identification numbers, signatures, physical characteristics or descriptions, insurance policy numbers, and any other financial, medical, or health information.
c. Financial information, such as your bank account number, credit card number, debit card number, government-issued Tax ID, or any other financial information.
d. Internet or other electronic network activity information, such as your browsing history, search history, and information regarding your interactions with us (including interacting with us online, by the mobile application, and through advertisements).
e. Geolocation information, such as longitude and latitude from your IP address.
f. Audio, electronic, visual, thermal, olfactory or similar information, such as video recordings of our premises.
g. Professional, employment, or education information, such as job title, business address, employment history, or other professional information.
h. Education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act.
i. Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Note that we generally try to match the information we collect from you to the information we require to provide you the information, products or services you request, and the above list is broad to simply capture the types of information required for many possible different interactions between us. Not all of the above information is captured for each interaction between us. Our core business is providing products and services and information about those products and services, as well as information that can help us improve those products and services, as opposed to collecting information about you and trying to monetize that information in a manner not related to the products and service we provide. Sometimes we do need to share information we collect with third-party service providers to provide you the information, products or services you request (see Section 5 below for more details about sharing of information). Privacy expectations and regulations are changing, and we expect our use and handling of your information will change over time to meet those changes and expectations.
4. How We Use Your Personal Information
We may use each category of your information described above in the following ways:
a. To enable interactions between you and us, such as to facilitate online purchases of our products; process shipping and returns; register and administer your account; provide you with and support your interactions with us; diagnose, repair and track service and quality issues; facilitate an order, download, return, or exchange; provide requested product information; communicate with you about your account or our data practices; install and configure changes and updates to programs and technologies related to interactions with us; authenticate those who interact with us; or to respond to your requests, complaints, and inquiries.
b. For our own internal business purposes, such as to evaluate or audit the usage and performance of programs and technologies related to interactions with us; evaluate and improve the quality of your interactions with us and programs and technologies related to interactions with us; design new services; process and catalog your responses to surveys or questionnaires (e.g., customer satisfaction reviews); perform internal research for technological development and demonstration; conduct data analysis and testing; maintain proper business records and other relevant records.
c. For legal, safety or security reasons, such as to comply with legal requirements; protect our safety, our property or rights of those who interact with us, or others; and detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity.
d. In a de-identified, anonymized or aggregated format. When converted to a de-identified, anonymized, or aggregated format, data no longer constitute Personal Information and we may use this information for any purpose.
e. For any other purposes for which you provide consent.
f. For marketing. We may use your Personal Information to market our products or services or those of third parties, such as our business partners. We may use your Personal Information when you participate in marketing surveys, questionnaires, promotions, events or contests. We may audit aspects of our ad impressions. We may use your Personal Information for short-term transient use, including for contextual ad customization. We may use your Personal Information to enhance our content and to potentially send you commercial emails.
g. 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
5. With Whom Do We Share Your Information?
We may share your Personal Information with the categories of recipients described below:
a. Affiliates and subsidiaries: We may share your Personal Information within our group of companies, which includes parents, corporate affiliates, subsidiaries, business units and other companies that share common ownership for the purposes described above.
b. Third-party service providers: We may share your Personal Information with third-party service providers working on our behalf to facilitate our interactions with you or request or support our relationship with you, such as hosting service providers, IT providers, operating systems and platforms, internet service providers, analytics companies, and marketing providers (e.g., we may share your email address with our outbound email marketing provider). 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.
c. 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.
d. 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 of Use and other agreements; and to protect our rights and our property or safety of our users or third parties.
e. In connection with a transaction: If we sell some or all of our assets, 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.
f. Your employer or coworkers: If you interact with us in connection with your employment, your employer, coworkers, or other individuals designated by your employer may view any Personal Information that we collect in connection with your use of or interaction with us.
We may also de-identity, anonymize, or aggregate Personal Information to share with third parties for any purpose.
6. Security and Retention
We maintain appropriate security procedures and technical and organizational measures to protect your Personal Information against accidental or unlawful destruction, loss, disclosure, alteration, or use. But no security measures can be 100% effective, and we cannot guarantee the security of your information, including against unauthorized intrusions or acts by third parties.
7. Children’s Privacy
Interactions with us are intended for individuals 16 years of age and older. Our interactions are not directed at, marketed to, nor intended for, children under 16 years of age. We do not knowingly collect any information, including Personal Information, from children under 16 years of age. If you believe that we have inadvertently collected Personal Information from a child under the age of 16, please contact us at the address below and we will use reasonable efforts to delete the child’s information from our databases.
8. External Links
When interacting with us you may encounter links to external sites or other online services, including those embedded in third-party advertisements or sponsor information, which we do not control. We are not responsible for the privacy practices and data collection policies for such third-party services. You should consult the privacy statements of those third-party services for details.
9. Terms of Use
The Terms of Use for interactions with us is incorporated by reference into this Policy, and can be found at: www.SMART-tag.net/terms-of-service.
10. Contact Info/Your Choices
If you have questions regarding this Policy, please contact us at:
EMAIL: privacy@SMART-tag.net
PHONE: (512) 686-2360
MAIL: Secured Mobility LLC, 920 Rockmoor Dr, Georgetown, TX 78628
Attn: Data Privacy
To opt-out of receiving promotional email messages from us, please click on the "Unsubscribe" link contained at the bottom of each email or by contacting us using the information above.
11. California Residents – Your Privacy Rights
If you are a California resident, this section applies. Pursuant to the California Consumer Privacy Act of 2018 (the CCPA), in the sections above we have provided a summary of the Personal Information we collected from consumers, the sources from which we collected the Personal Information, the business or commercial purpose for which the Personal Information was collected and the categories of third parties with whom we share consumer Personal Information. Under the CCPA, you may have specific rights, as discussed below.
WE DO NOT CURRENTLY SELL PERSONAL INFORMATION TO THIRD PARTIES, NOR DO WE HAVE ANY PLANS TO DO SO IN THE FUTURE.
Your Rights
California consumers have certain rights, subject to legal limitations, regarding the collection, use, and sharing of their Personal Information. These rights are described below:
Right to Know What Personal Information We Collect About You
You may have the right to know:
- The categories of Personal Information we have collected about you;
- The categories of sources from which the Personal Information is collected;
- Our business or commercial purposes for which we have collected or sold Personal Information;
- The categories of third parties with whom we share Personal Information, if any; and
- The specific pieces of Personal Information we have collected about you.
Please note that we are not required to:
- Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or
- Provide the Personal Information to you more than twice in a 12-month period.
Right to Know Personal Information We Sell to Third Parties
In connection with any Personal Information we may sell or disclose to a third party for a business purpose, you have the may right to know:
- The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and
- The categories of Personal Information that we disclosed about you for a business purpose.
Right to Opt-Out of Sale of Your Personal Information to Third Parties
You may have the right under the CCPA and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your Personal Information to third parties. SMART tag does not sell your Personal Information to third parties.
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your Personal Information from our records; and
- Direct any service providers to delete your Personal Information from their records.
Please note that we may not delete your Personal Information if it is necessary to:
- Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with an existing legal obligation; or
- Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
We are also not obligated to delete your Personal Information if an exception to the right applies, including:
Where we are using your Personal Information to provide business-to-business services (e.g., we are providing services requested by your employer or principal); and
Where the Personal Information is provided in the context of an employee-employer relationship, including where we are providing services to your employer.
Freedom from Discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide an inferior level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.
How to Exercise Your CCPA Rights
If you would like to exercise any of your rights under the CCPA, please click here to send a request via webform.
If you do not want to use the webform, you may contact us directly using one of the following methods:
- Call us at (512) 686-2360;
- Email us at privacy@SMART-tag.net.
Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly, please be prepared to provide us with:
- Enough information to allow us to verify your identity (which may include, but is not limited to, name, e-mail address, mailing address, phone number);
- Information regarding the context in which you interacted with us; and
- A description of what right(s) you want to exercise and the information to which your request relates.
Verification: We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf. If we cannot reasonably verify the identity of a person making a request, we will honor such request to the extent possible. Any Personal Information we collect from you to verify your identity in connection with your request will be used solely for verification.
Authorized Agents: You may use an authorized agent to exercise your rights on your behalf. If you are making any of the requests above through an authorized agent, we will request written authorization from you and will seek to verify you as described above or we will accept a legal Power of Attorney under the California Probate Code to the authorized agent.
Timing: We will respond to Requests to Delete and Requests to Know 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.
12. How We Use Cookies and Automatic Data Collection Tools
We also collect information, via cookies, web beacons, pixels, tags or other tracking technologies, such as your Internet Service Provider and IP address, the date and time you access our website, the pages you accessed while visiting our website, and the Internet address from which you accessed our website. Some cookies exist only during a single session and some are persistent over multiple sessions over time. We use these technologies to remember user preferences, maximize the performance of our website and services, provide you with offers that may be of interest to you, measure the effectiveness of our email campaigns and personalize online content. These cookies and other technologies may be used to track you across devices.
To provide you with more relevant and interesting experience, we may work with third-party companies to display ads or customize the content on the website and other websites. These companies may use cookies and similar tracking technologies as described in this Statement to gather information about your visits to the website, as well as your visits elsewhere on the Internet. These companies use this information to provide you with more relevant advertising known as interest-based advertising. The Digital Advertising Alliance (“DAA”) offers a choice mechanism for certain types of data collection and use by third parties available at www.aboutads.info. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.
Some browsers have incorporated Do Not Track (“DNT”) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement about how to interpret DNT signals, we do not honor DNT signals from website browsers at this time. However, you may refuse or delete cookies. If you refuse or delete cookies, some of our website functionality may be impaired. If you change computers, devices, or browsers, or use multiple computers, devices, or browsers, and delete your cookies, you may need to repeat this process for each computer, device, or browser. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies.
This Policy was last updated on August 25, 2024.
