DEKRA Services, Inc. SMART Privacy Policy
Last modified: February 19, 2019


Introduction
DEKRA Services, Inc. and its affiliate companies (collectively, “DEKRA” or “we” or “us”) respect your privacy and value our relationship with you. This policy describes the types of information we may collect from you or that you may provide when you use the DEKRA SMART service or visit the DEKRA Dispatch website (collectively, the "Services"). This policy also describes our practices for using, maintaining, protecting and disclosing that information. Finally, this policy describes the rights and choices available to you regarding such information.
This policy is not intended to override the terms of any contract you have with us, nor any rights you might have under applicable data privacy laws.
This policy applies to information we collect:
- through the Services;
- from e-mail, text, other electronic messages exchanged between us;
- through offline written or verbal activities and communications;
- mobile applications;
- social networking presence; or
- from other sources.
This does not apply to information collected by any third party, including through any application or content that may link to or be accessible through the Services.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you object to the policies and practices explained in this document, do not use the Services. By using the Services, you agree to this privacy policy. This policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It
Types of Information. We collect several types of information from and about users of the Services, including information:
- by which you may be personally identified, such as name, job title, postal address, e-mail address or telephone number ("Personal Information");
- location data logged through the IP address and through GPS data collected from mobile devices that use a DEKRA application installed on the device; and
- about your internet connection, your IP address, the equipment you use to access the Services, and your usage details.
How We Collect Personal Information. The information we collect on or through the Services may include:
- Information that you provide by filling in forms. This includes information provided at the time of subscribing to our mailing list, requesting further services, or generally when you use our website.
- Records and copies of your correspondence (including e-mail addresses), if you contact us.
- Details of transactions you carry out using the Services and the fulfillment of your orders. You may be required to provide financial information before placing an order for services.
- Your search queries on the website.
- Information provided by subsidiaries or affiliates of our parent company, DEKRA SE.
- Information provided by third parties, for example, companies from whom we may purchase data.
Usage Details, IP Addresses, Cookies and Other Technologies. We may automatically collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our website, including traffic data, location data, logs and other communication data and the resources that you access and use on the website.
- Information about your computer and internet connection, including your IP address, operating system and browser type.
The information we collect automatically is statistical data. It helps us to improve the website and to deliver a better and more personalized service by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize the Services according to your individual interests.
- Personalize content based on location.
- Speed up your searches.
- Recognize you when you return to use the Services.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our website or certain features of the Services may be unavailable to you. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the website.
- Flash Cookies. Certain features of the website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on the website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
We do not collect Personal Information automatically, but we may tie automatically collected information to Personal Information about you that we collect from other sources or that you provide to us.
Children Under the Age of 16. The Services are not intended for children under 16 years of age and we do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any Personal Information to us through the Services. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we have collected Personal Information from a child under the age of 16, please contact us as described at the end of this policy.

How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal Information:
- To present the results of the Services to you and allow you to use interactive features on our website.
- To provide you with information, products or services that you request from us.
- To develop, customize and improve the Services.
- To promote the Services.
- To track for audit purposes where the Services were performed using the SMART mobile application.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to the Services.
- To comply with applicable laws and regulations.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.

Disclosure of Your Information
Non-personal Information. We may disclose aggregated information about you, and information that cannot identify you in any individual capacity, without restriction.
Personal Information. We may disclose Personal Information that we collect or you provide:
- To our subsidiaries and affiliates.
- To contractors, service providers and other third parties we use to support our business, for example for third party data storage or hosting.
- To a buyer or other successor company in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of assets, if Personal Information held by DEKRA is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of DEKRA, our customers or others.

Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of the Services may be unavailable.
- Promotional Offers from the Company. If you do not wish to have your e-mail address used by DEKRA to promote our own or our affiliates’ products or services, you can opt-out by unsubscribing to emails that we send to you or at any other time by sending us an e-mail stating your request to legal.na@dekra.com. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions or by using the unsubscribe button at the bottom of each email. This opt out does not apply to information provided to DEKRA as a result of a product purchase, service experience or other transactions.

Accessing and Correcting Your Information
You may send us an e-mail at legal.na@dekra.com to request access to, correct or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or obligation or cause the information to be incorrect.

Consent to Data Processing Within the United States
These Services are controlled by DEKRA from the United States and are not intended to subject DEKRA to the laws or jurisdiction of any state, country or territory other than that of the United States. By using the Services, you agree and consent to the transfer, storage and processing of your Personal Information within the US, and that the protection of such information may be different than required under the laws of your residence or location.
California Privacy Rights
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding 2018 sharing activities).
To obtain this information or to opt-out of such information-sharing, please send an e-mail to legal.na@dekra.com with “Request for California Privacy Information” on the subject line.

Data Security
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
However, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us. Any transmission of Personal Information is at your own risk. Please note that e-mails and other communications you send to us through the Services are not encrypted, and we strongly advise you not to communicate any confidential information through the Services. We are not responsible for circumvention of any privacy settings or security measures used with the Services.

Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' Personal Information, we will notify you through a notice on the website for the Services. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting the Services and this privacy policy to check for any changes.

Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at:
DEKRA Services, Inc.
3901 Roswell Road, Suite 120
Marietta, GA 30062
Attn: Legal Department
Or by email at: legal.na@dekra.com