General information
This Privacy Policy explains how CodeGen Limited (hereinafter referred to as “we”, “us”, “our” or “the Company”) collects, uses, discloses, and otherwise processes your Personal Information or Personal Data, in connection with the use of our application named “Fleet Handler” (“Application”) along with any Application updates, supplements, functionalities, features, internet-based services, and support or other related services (“Services”).
We are processing your Personal Information only to provide services which our customers/clients (“Customer/s”) have subscribed to under a master subscription agreement or any other contractual agreement/s (“Customer Agreements”).
This Privacy Policy applies to all your Personal Information processed by us, whether in physical, electronic or any other mode. By using the Applications, you agree to the collection and use of information in accordance with this policy.
For the purpose of this Privacy Policy, adhering to the Data Protections Legislation, we shall at all times act as the Data Processor and our Customers shall be the Data Controller. “Data Processor” and “Data Controller” has the meaning defined in the Data Protection Legislation. “Data Protection Legislation” means the General Data Protection Regulation (EU) 2016/679 ( EU GDPR), the Data Protection Act 1998 and related regulations and secondary legislation, as amended or updated from time to time.
Please read Our Terms of Service, which describe the terms under which you shall use, and we shall provide our Services in relation to the Application.
How We Use Your Information
“Personal Information” or “Personal Data” refers to any information relating to an identified or identifiable natural person.
We use the data we collect in accordance with our Customer Agreements, to provide the Services, and for related internal purposes, including to:
• To set up your account and to provide our Services to our Customers and their end users
• Provide information about the Services, such as important updates or changes to the Services, security alerts, training and the availability of new features;
• Monitor and improve the Services and the Application functionality and develop new products and services;
• Send you push notifications;
• Respond to inquiries, complaints, and requests for Customer or end user support;
• We may also use Personal Information or Personal Data as we believe necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the Services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; and
• In an aggregated, de-identified and generic manner: to market the Services, survey usage, set benchmarks, feature suggestions, product analytics, new product features or Services, Services utilization analyses and related purposes.
How We Collect Information From You
1. User Provided Information
You may not be able to use our Services offered by the Application unless you are registered with us through our Customer. When you are registering, you shall provide us with:
(a) Identity data such as your name, resident address, telephone number, email address, username, password, business type when you and/or your organization creates an account and other registration information;
(b) information you provide us when you contact us for support and assistance and;
(c) any other information you enter when using the Application.
2. Automatically Collected Information
The Application may collect certain information automatically, including, but not limited to;
a. Data on your mobile device and device identifiers such as the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browsers you use, data from device settings and other information about the way you use the Application through your mobile device.
b. Limited authentication details such as authentication ID, email or phone number, provided by third party service providers when registering an account.
c. location based data (GPS coordinates) through our geolocation feature
d. access to certain features and applications from your mobile device, with your permission, including your mobile device’s:
a. camera or gallery for the purpose of obtaining images to set up a profile picture;
b. Storage for the purpose of accessing file systems to read and write persistent data in relation to the Application; and
c. GPS location for the purpose of ascertaining your geolocation;
e. data and communications in order to provide Customer support such as an email with information relating to the Application performance or other issues
Lawful Bases for Collecting, Processing and Storing your Information
We collect, process and store your Personal Data by relying on one or more of the following lawful bases:
(a) You have provided your consent at the point of registration for us to do so, by accepting our Terms of Service;
(b) Processing your data in the way explained above is necessary for us to provide our Services to our Customers under any Customer Agreement.
(c) Processing is necessary for compliance with a legal obligation we may have
(d) Processing is necessary for the purposes of pursuing our legitimate interests.
We require your Personal Information and consent to use your Personal Information in order to deliver our Services to our Customer or You and without this we will not be able to provide our Services. However, we shall not access any other Personal Information except the information required/derived through the Application.
Sharing Your Information
We will not share your Personal Information with any third party unless we have our Customer’s acknowledgement of your consent, or under the following circumstances where it is lawful to do so:
(a) when there is a necessity to provide you or our Customers with further products or services such as hosting services where third party cloud service providers will store your Personal Data;
(b) when we have a legitimate business reason for doing so;
(c) in the event we are involved in a merger, acquisition, restructuring, bankruptcy, or sale of all or some of our assets;
(d) when we have a legal obligation to do so or if we believe that it is reasonably necessary to comply with a law, regulation, legal process to protect the safety of any person; address fraud, security, or technical issues; or protect our rights or the rights of those who use our Services by assisting with detecting and preventing fraud, regulatory reporting, litigation or asserting or defending legal rights and interests.
Securing Your Personal Information
We are committed to protecting your personal information in our possession. We shall take all reasonable steps to ensure appropriate physical, technical, and managerial safeguards are in place to protect your Personal Information from unauthorized access, alteration, transmission, and deletion.
Period of Storage
We store personal information for as long as necessary for the purposes identified in this Privacy Policy and our Terms of Service in order to fulfil our obligations under Customer Agreements, including to provide our Services or for other legitimate purposes, such as complying with legal obligations, enforcing and preventing violations of our Terms of Service, or protecting or defending our rights, property and users. The retention of your personal information is determined on a case-by-case basis that depends on factors like the nature of the information, why it was collected and processed, relevant legal or operational retention needs, and legal obligations or otherwise as may be provided in the Customer Agreements.
If we have no legitimate reason to process your Personal Information, we will delete your information within one (1) month of you uninstalling the Application and terminating our services. If this is not possible for reasons beyond our control, then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
Service Providers
We may employ third party companies and individuals to facilitate our Application (“Service Providers”), to provide the Services on our behalf, to perform Application-related services or to assist us in analyzing how our Application is used.
These third parties may have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Links To Other Sites
Our Application may contain links to other sites that are not operated by us. If you click on such a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices and shall not be liable for any loss or damage you may incur by accessing those sites.
Your Data Protection Rights
You may directly contact our Customer and request for access, rectification, amendment, deletion, objection, obtain a copy of your Personal Data stored by us or to limit the processing of your Personal Data. If the Customer informs us of the same and requests us to comply, we shall proceed to do so.
Whenever possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, you may contact us to make the required changes.
Changes to Our Privacy Policy
We keep our Privacy Policy under regular review, and we will update the same without any notification to you. It is your responsibility to periodically review our Privacy Policy to stay informed of such changes. Any information we collect is subject to the Privacy Policy in effect at the time it is collected. By continuing to access or use the Application and our Services after any changes come into effect, you are agreeing to the revised Privacy Policy.
International Data Transmission
Your Personal Data, may be transferred and processed globally. Intra-group international transfers will take place to countries where we have offices, particularly Sri Lanka. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to such transfers.
We do not rent or sell your Personal Information to other companies or individuals.
We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy during such transfers.
Governing Law
This Privacy Policy will be governed and construed under the laws of England and Wales without regard to conflict of laws. You agree to submit to the exclusive jurisdiction of the Courts located in England.
Contact Us
For any further queries and complaints related to privacy, or exercising your rights, you could contact Us via Our email address: dmc@codegen.net