Privacy and Cookie Policy

Privacy Policy overview

Inseego Corp. and its affiliates  (“Inseego”, "Company", or "We") respect your privacy. Inseego Corp. is a company registered in California, USA which owns various subsidiary companies around the world including in EU member states and the United Kingdom. The protection of your personal data is our top priority. We are committed to developing technology that gives you a safe online experience and protecting your information through our compliance with this policy.

Purpose

This policy describes the types of information we may collect from you or that you may provide when you visit our sites or use our services and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Scope

We provide a broad range of services to our customers which involves processing personal data in various countries around the world depending on the services to which you subscribe. When we process such data, we are subject to multiple data protection laws governed by different jurisdictions. These laws include the UK General Data Protection Regulation (“UK GDPR”), the EU General Data Protection Regulation (“EU GDPR”) and U.S. State laws. We will always process personal data in accordance with applicable data protection law. The services we provide (collectively referred to as our “Services”), which are subject to this privacy policy, include our:

• Apps and sites (like inseego.com, Inseego Connect, Inseego Subscribe, and Inseego Vision)
• Any associated sites linked to our sites by us or our subsidiaries, including sites around the world
• Cloud or Telematics services (like web services integrated in other companies’ apps or sites)
• Devices (like Skyus, MiFi, and Wavemaker)
• Firmware Updates (FOTA)

Many of these Services also include content that you can interact with. This policy applies to personal data we collect:

• On Inseego sites.
• In email, text, and other electronic messages between you and Inseego.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

It does not apply to personal data collected by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use a Service. By downloading, registering with, or using a Service, you agree to this privacy policy. This policy may change from time to time (see "Changes to our Privacy Policy" below). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. Where we process personal data on your behalf or on behalf of a third-party controller, this activity will be subject to our Data Processing Agreement.

Data protection principles

We will comply with applicable data protection law. The personal data we hold about you will be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and to the extent appropriate, kept up to date;
• kept only as long as necessary for the purposes we have told you about; and
• kept securely.

Information we collect about you and how we collect it

We collect several types of personal data from and about users of our Services, including information:

• by which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline, government identification number, billing information or credit card information, and other ("personal information").
  • For certain Services this may include biometric information (such as facial recognition) through the use of video surveillance if you or your employer chooses to enable those features when you enroll in our Services. Biometric information constitutes special category data under the UK GDPR and EU GDPR. Where we process this and other special category data, we will only do so on a lawful basis in accordance with applicable data protection law and take additional measures to protect that data. In most cases, this will take the form of acquiring your explicit consent before any special category processing takes place. However, we may also be able to do so to protect your (or someone else’s) vital interests where you are unable to express consent, or so that we may establish, exercise, or defend legal claims.
  • In addition, your personal financial information may be required in connection with credit and financing decisions;
• that is about you but individually does not identify you, such as configuration information about our product that you are installing, data usage, statistical information, and pictures of your location and locations where our products are installed; and/or
• about your internet connection, the equipment you use to access our Sites, and usage details.

We collect this information:

• Directly from you when you provide it to us, or when our Services are used.
• Automatically as you navigate through our sites or use our Service. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
• From third parties, for example, our trusted business partners or your company who uses our Services. If we do attain personal data from third parties or your employer, we will ensure that party has appropriate consent or another lawful basis for the collection.

Where we need to collect personal data by law or under the terms of a contract, and you fail to provide the data when requested, we may not be able to perform the contract and may have to cancel a product or service you have with us. In most cases, we require all the personal data which we request from you in order to enter into a contract. If that is the case, we will notify you.

Information you provide to us

The information we collect on or through our Website or when you purchase products and Services through us may include:

• Information that you provide by filling in forms on our Website or documents as part of our Services. This includes information provided at the time of registering to use our Site, subscribing to our Service or third-party partner services, posting material, subscribing to our mailing list, entering data in a field provided for your use, or requesting further Services. We may also ask you for information when you report a problem with a Service.
• Records and copies of your correspondence (including email addresses) when you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Details of your visits to our Site and search queries.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Inseego encourages you to review the privacy statements of Websites you choose to link to from Inseego Sites so that you can understand how those Web sites collect, use, and share your information. Inseego is not responsible for the privacy statements or other content on Websites outside of the Inseego family of Sites.

Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Children under the age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. 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 might have any information from or about a child under 16, please contact us using the contact information listed at the end of this policy.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see "Your California privacy rights" below for more information.

Information we collect through automatic data collection technologies

As you navigate through and use our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Site Usage. 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.
• Service Usage. When you access and use our Services, we may automatically collect certain details of your access to and use of the Services, including location data and other resources you access or use through the Services. This data is to improve our service and only aggregated and anonymized.
• Device Information. We may collect information about your electronic device and internet connection, including the device's unique device identifier, Internet Protocol (IP) address, operating system, browser type, mobile network information, the device's telephone number, and similar information about the products that you install in connection with your use of the Services.
• Stored Information and Files. Our App or Cloud service also may access metadata and other information associated with pictures you take or use or files you upload. If you upload a third party’s personal data, such as a photograph, you are responsible for attaining the consent of that party.
• Location, Device and Driver Performance Information. Our App or Cloud service may collect real-time information about the location of your device and information about your wireless network service performance. This data is processed for performance of our contract and is limited to our service.

The information we collect automatically is only statistical aggregated and anonymized data and does not include personal data. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your location, product configuration and preferences, allowing us to provide services to you (such as App-based device installation assistance and cloud-based device management services) and to customize our Services according to your individual service needs.
• Speed up your searches.
• Recognize you when you use our Services.

We may use location information we collect in connection with your use of our App or Cloud service to provide the Services, for example to help you install your Inseego product in an optimal location or, for our telematics services, to collect information about vehicle location and driver behaviors. We provide telematics customers with a cellular device that enables our customers to determine how, when, where and by whom a vehicle is being driven. We provide software to our customers that allows them to access this data through our online portals. Personal data relating to customer’s personnel is input into our software by our customers, and we may anonymize data to share with regulatory bodies. We do not use personal data as set out in this paragraph that could be used to identify an individual other than to provide our services to our customers.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). Our sites use “cookies” to help you personalize your online experience. A cookie is a text file that is uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. One of the main purposes of cookies is to provide ease of use to save you time. A cookie signals to the web server that you have visited a specific page, and the information you have already provided (such as name, email address and so on) can be easily retrieved on subsequent visits. Please visit our Website Cookies Policy for further information about our use of cookies.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see "Choices about how we use and disclose your information" below.
• Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website or App content and verifying system and server integrity).

You may refuse to accept cookies; however, if you do, you may be unable to access certain parts of our Website. Please note that while you are free to decline cookies, you may not be able to take full advantage of all our Services.

Third-party use of cookies and other tracking technologies

If our Service is used in connection with a third-party service, such as if our Service is provided in connection with a device that you’ve acquired from a wireless network provider, when you use the Service, the network provider may use automatic information collection technologies to collect information about you or your device as a data controller in its own right and not on our behalf. These third parties may include your wireless network provider and their affiliated service providers.  In addition, if we provide a service to you as a reseller for a third party, we will inform you about the nature of the third-party service and related terms and conditions for the service.  In those cases, you may be required to provide personal data as condition of using the service, and the third party’s privacy policy and terms and conditions will apply with respect to the resold service.

When you leave our Site, we encourage you to read the privacy notice/policy of every website you visit. We do not control third-party’s collection and privacy of your personal data. Third parties may use tracking technologies to collect information about you and will apply different terms to the use of your data. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your use of the Service and connected devices. They may use this information to provide you with services or targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly and review their privacy policies.

How we use your information

Under data protection law, we can only use your personal data if we have a lawful basis to do so. For example, the most relevant to us are where you have given consent; to comply with our legal and regulatory obligations; for the performance of a contract with you or to take steps at your request before entering into a contract; or 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 personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

We use information that we collect about you or that you provide to us, including any personal data:

• To present our Website and its contents to you – for our legitimate interest to promote our business and services to prospective and existing customers and personalize your experience.
• To provide you with information, products, or services that you request from us or otherwise to deliver goods or services to you – to perform our contract with you or to take steps at your request before entering into a contract.
• To provide you with notices about your account/subscription, including expiration and renewal notices – to perform our contact with you.
• To conduct research about your opinion of our services or of potential new services that may be offered – for our legitimate interest to understand how our business and services could be improved for customers. This is optional and you can choose not to respond to these communications.
• To carry out our obligations and enforce our rights arising from any contracts between you or your employer and us, including for billing and collection or account administration – to perform our contract with you, and/or to comply with our legal and regulatory obligations under the applicable employment relationship.
• To notify you about changes to our Website or any products or services we offer or provide though it – for our legitimate interest to understand how our business, website, and services could be improved for customers and to perform our contract with you.
• To allow you to participate in interactive features on our Website – for our legitimate interest to understand how our business, website and services could be improved for customers when they participate in interactive features.
• In any other way we may describe when you provide your personal data, provided our processing is lawful.
• To fulfill any other purpose for which you provide it, provided any subsequent purpose is not incompatible with the original purpose for which the personal data was collected. For any other purpose with your consent.

Inseego does not sell, rent, or lease its customer lists or customer personal data to third parties. We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party.

Monitoring and recording

We may monitor and record communications with you (such as telephone communications and emails) for the purpose of quality assurance, training, fraud prevention, and compliance. Additionally, we may have CCTV cameras installed on our premises for safety and crime prevention.

How we disclose your information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal data that we collect, or you provide, as described in this privacy policy:

• To our subsidiaries and affiliates for use in connection with providing you with our Services – for the performance of our contract with you.
• To our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For example, we use service providers to help operate our data centers, deliver our products and services, improve our internal business processes, and offer additional support to customers and users. The third parties we use to support our business are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor (including their professional advisers) in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Inseego Corp. 's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Service users 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.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any law enforcement, government or regulatory request and other agreements.
• To enforce our rights arising from any contracts between you and us, including the terms of use for a Service, terms of sale of our products and services, and for billing and collection.
• To our professional advisers (such as lawyers and other advisers), our external auditors and accountants, in which case the recipient of information will be bound by confidentiality obligations.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Inseego Corp., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

All such third parties are prohibited from using your personal information, unless required by law, except to provide these services to Inseego, and these providers are required to maintain the confidentiality of your information.

If you do not want us to collect this information, do not use or register for our Website or Cloud Service or download, register for, or use our App or delete the App from your device. Note, however, that deleting the App will prevent its use to assist with the installation of our fixed wireless access (“FWA”) products or other purpose.

Choices about how we use and disclose your information

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies. You manage your cookie preferences and choose what cookies you consent to. If you disable or refuse cookies, please note that some parts of our site may be inaccessible or not function properly.
• Promotional Offers. We may use information we have collected from you to enable us to display advertisements to you about our products and services but will only do so with your consent. If you are a customer and do not want us to use information that we collect or that you provide to us to deliver advertisements, you can adjust your cookie preferences or contact us via any method listed at the end of this policy. This opt-out does not apply to warranty registration, product service experience, or other customer service or financial billing transactions.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Your rights to your information

Data protection legislation gives you the right to object to the processing of your personal data in certain circumstances or withdraw your consent to the processing of your personal data where this has been provided. You also have the right to access information held about you.

Inseego will comply with all applicable legal requirements related to the transfer, processing, and storage of personal information.  We are committed to the protection of your personal information that we process in line with the data protection principles set out in UK GDPR and EU GDPR. These rights include:

• The right to be provided with a copy of your personal data.
• The right to require us to correct any mistakes in your personal data.
• The right to require us to delete your personal data—in certain situations.
• The right to require us to restrict processing of your personal data in certain circumstances, e.g., if you contest the accuracy of the data.
• The right to receive the personal data you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations.
• The right to object:
  • —at any time to your personal data being processed for direct marketing (including profiling);
  • —in certain other situations to our continued processing of your personal data, e.g., processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise, or defense of legal claims.
• The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

If you have provided us with a consent to use your personal data, you have a right to withdraw that consent easily at any time. You may withdraw consents by emailing [email protected] . Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

If you would like to exercise any of your above rights, please email [email protected] .

Rights to correct and delete your data

It is important that the personal data we hold about you is accurate and current. You can review and change your personal information by logging into our respective Service. In some cases, we may not be able to delete all of your personal data except by also deleting your user account. You have the right to view, correct, or delete your personal data, subject to applicable contractual and legal restrictions.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored.

We will retain and use your personal data as needed to fulfill the purposes for which it was collected and as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our rights and agreements. We may not accommodate a request to change information, if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Please keep us informed if the personal data we hold about you changes.

Rights to withdraw consent and port your data

Where the processing of your personal data is based on consent, you may withdraw such consent at any time, subject to applicable contractual and legal restrictions. You also have the right to port your data to you or another organization elected by you.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal data that we hold about you or make your requested changes. In certain circumstances, we reserve the right to charge a reasonable fee to comply with your request.

You also have the right to lodge a complaint with the relevant supervisory authority for your jurisdiction.

California privacy rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information listed at the end of this policy. To learn more about your California privacy rights, visit our Privacy Policy California Supplement at https://inseego.com/download/california-supplement-policy.pdf.

How we protect your information

We have implemented appropriate physical, technical, and organizational 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 secure servers behind firewalls, and when personal data is transmitted, it is protected with encryption. We limit access to personal data to those employees, agents, contractors and other third parties that have a legitimate business need for such access.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We are not responsible for circumvention of any privacy settings or security measures we provide. Unfortunately, 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 through our Service. Any transmission of personal information is at your own risk.

How we transfer, process, and store your information

Certain of our services are provided internationally. We may transfer your personal information to our operations in the United States of America, to any Inseego subsidiary worldwide, or to third parties and business partners that are located in various countries around the world. By using our websites and or providing any personal information to us, where applicable law permits, you acknowledge and accept the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different.

Even if data protection standards are different, we will comply with all applicable legal requirements related to the transfer, processing, and storage of personal information.  We are committed to the protection of your personal information that we process in line with the data protection principles set out in UK GDPR and EU GDPR.

If and when transferring your personal data outside the UK, EU or European Economic Area (“EEA”), we will only do so using one of the following safeguards, and provided you have effective legal remedies and enforceable rights:

• If the transfer is from the UK to a third country:
  • the receiving country is subject to an adequacy regulation by the UK Government (which includes all EEA countries); or
  • a UK Government-approved data transfer agreement with an organization in a third country is in place (i.e., the International Data Transfer Agreement, or the International Data Transfer Addendum if the transfer is governed by the EU standard contractual clauses);
• If the transfer is from an EEA-country to a third country :
  • the receiving country is subject to an adequacy decision by the EU Commission; or
  • EU standard contractual clauses are in place between us and the organization located in the third country.
• The international data transfer is subject to binding corporate rules approved by the UK or an EU data protection authority (depending on where the data is being transferred from)

International transfers to our affiliate and subsidiaries company are governed by an Intra Group Data Sharing Agreement.

We may also transfer your data to third-party vendors outside the UK and EU, such as our customer relationship management system and network service providers. Where we do so, the UK’s International Data Transfer Agreement or EU’s Standard Contractual Clauses or other safeguards approved by the UK Government or the EU Commission (depending on where the data is transferred from) are in place to safeguard that personal data. You may request a copy of these agreements by contacting us using the contact information listed at the end of this policy.

We do not retain your data for longer than necessary. Unless required by law, we will retain your personal data for as long as we require this to provide you with services and for a period afterwards in order to comply with limitation periods and accounting and tax requirements applicable to our business. We will not retain personal data in identifiable form when the purpose(s) for which the personal information was collected have been achieved and there is no legal or business need to retain such personally identifiable information. If the purpose for storing the data no longer applies, the personal data will be destroyed, deleted, anonymized, and/or removed from our systems, as long as there are no legal storage obligations to the contrary.

Changes to our Privacy Policy

We will notify you if there are any changes to this policy that materially affect how we collect, store, or process your personal data. If we make material changes to how we treat our users' personal data, we will post the new privacy policy on this page with a notice that the privacy policy has been updated. We encourage you to periodically review this policy to be informed of how Inseego is protecting your information.

If we would like to use your previously collected personal data for different purposes than those you were notified about at the time of collection, we will provide you with notice and, where required by law, seek your consent before using your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent where required by applicable law or regulation.

Contact information

If you have any questions, comments, or requests regarding this policy or how we use your personal data, please contact us at the addresses below, based on your location:

Germany

DE DSB (Datenschutzbeauftragter)

Email: [email protected]

Ireland

IE DPO (Data Protection Officer)

Email: [email protected]

Netherlands

NL FVG (Functionaris Voor Gegevensbescherming)

Email: [email protected]

United Kingdom

FAO UK Data Protection Representative

Inseego UK Ltd, Stockdale House, 8 Victoria Road, Leeds, LS6 1PF

Email: [email protected]

United States (Global Headquarters)

Inseego Corp., Attn: Legal Department, 9710 Scranton Road, Suite 200, San Diego, CA  92121

Email: [email protected]

You have the right to lodge a complaint with a supervisory authority in the country in which you are based. For information on what supervisory authority governs your country, please see our table below. You can assert the right to complain with a supervisory authority in the country or member state of your place of residence, your place of work, or the place of the alleged infringement.  

Australia

Australian Information Commissioner

Call: 1300 363 992

Website: https://www.oaic.gov.au/

California, USA

California Privacy Protection Agency

Website: https://cppa.ca.gov/

Germany

Federal Commissioner for Data Protection and Freedom of Information

Call: 49(0)228 997799-0

Website: https://www.bfdi.bund.de/DE/Home/home_node.html

Ireland

Data Protection Commission

Call: 01 7650100 / 1800437 737

Website: https://www.dataprotection.ie/

Netherlands

The Dutch Data Protection Authority

Call: (31) - (0)70 - 888 85 00

Website: https://www.autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us

New Zealand

Office of the Privacy Commissioner

Call: 0800 803 909

Website: https://www.privacy.org.nz/

United Kingdom

Information Commissioner’s Office

Call: 44(0)303 123 1113 

Website: https://ico.org.uk/

Before you contact the competent supervisory authority with a complaint, we would like to ask you to clarify this matter with us. We will use commercially reasonable efforts to promptly determine and remedy the problem.