FleetSpartan, Inc. Privacy and Data Use Policy
Last modified: November 5th, 2021

FleetSpartan, Inc. (“We,” “Our” or “Us”) respects the privacy of Our app users and are committed to protecting it through Our compliance with this privacy policy. This policy describes:
• The types of information We may collect or that you may provide when you access or use the Erbe™ mobile application (the “App”); and
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information We collect through this App. This policy DOES NOT apply to information that We collect offline or on any other of Our apps, websites, software or services, or information that You provide to, or is collected by, any third party, including without limitation Our customers. Our websites and apps, and those third parties, may have their own privacy policies, which We encourage you to read before providing information on or through them.

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 or use this App. By downloading and/or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy).

Your continued use of this App after We make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect and How We Collect It

We collect information from and about users of Our App (1) directly from you when you provide it to Us, (2) from an Erbe customer to whom you provide services as an employee or independent driver for which you are using this App (“Your Company”), and (3) automatically when you use the App.

Information You Provide to Us

• When you log into the app, the application will have access to your basic profile for authentication and identification purposes used in secure communications.

Information Provided to Us by Your Company

• Once you have created an Erbe login, your profile will link the app to your company's Erbe Admin Portal account. Your company and our systems will use your driver profile information within the Erbe Admin Portal to validate your link request.
• We may use publicly available information about you available through social media, such as your avatar or picture, to associate with and display in your Erbe app when you are logged in.
• Your Company may provide other information which will be available to you through the App on a read-only basis.

Automatic Information Collection

When you download, access, and use the App, it may use technology to automatically collect:
• Usage Details. When you access and use the App, We may automatically collect certain details of your access to and use of the App, including location data, logs, back-end information and server calls, communication data, and the resources that you access and use on or through the App. We also collect app page views using Google Analytics.
• Device Information. We may collect information about your mobile device including among others the device model number, operating system, and browser type.
• Location Information. This App collects real-time information about the location of your device only when the device screen is on and the App is displayed.
If you do not want Us to collect this information, do not download the App or delete it from your device if already downloaded.

Information Collection Technologies.  The technologies We use for automatic information collection may include:

• Web Beacons. Pages of the App and emails relating to Our App may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Us, for example, to count users who have visited those pages and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

How We Use Your Information
We use information, including any personal information, that We collect or receive about you or that you provide to Us:
• To provide you with the App and its contents, and any other information, products or services that you request from Us (e.g., support);
• To verify your identity when you are logging into the App and maintain an access log of user logins to the App;
• To display your user profile information and other reporting within the App on a read-only basis;
• To prefill geolocation data regarding your physical location when making transaction authorization requests;
• To authorize your fuel card for a fueling transaction; • If enabled to provide comparison fuel pricing among merchants;
• If enabled to provide nearby weather data; • If enabled to communicate with Erbe devices;
• If enabled to detect whether users are in a moving vehicle and display the “Safe Mode” screen if they are;
• If enabled To send communications to you or from you through the App;
• To fulfill any other purpose for which you provide it to Us;
• To notify you when App updates are available, and of changes to any products or services We offer or provide though it; and
• To improve Our App and to deliver a better and more personalized experience (e.g., to recognize you when you use the App).
• If enabled to prevent you from using the app while in a moving vehicle;
• If enabled to provide nearby weather data;
• If enabled to detect whether users are in a moving vehicle and display the “Safe Mode” screen if they are;
• If enabled To send communications to you or from you through the App;
• To fulfill any other purpose for which you provide it to Us;
• To notify you when App updates are available, and of changes to any products or services We offer or provide though it; and
• To improve Our App and to deliver a better and more personalized experience (e.g., to recognize you when you use the App).

Disclosure of Your Information
We may disclose aggregated information about Our users, and information that does not identify any individual or device, without restriction.
In addition, 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;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us about Our App 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;
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request; and
• If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of Us, Our affiliates, Our respective customers, or others.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to Us. This section describes mechanisms We provide for you to control certain uses and disclosures of over your information.
• Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the App may then be inaccessible or not function properly.
• Push Notifications. You may have the option to opt out of certain communications to you through the app, e.g., push notifications based on your device ID, through the App's settings.
• Google Analytics. You can install Google Analytics' opt-out browser add-on by visiting http://tools.google.com/dlpage/gaoptout (please note this will not impact the collection of metrics regarding your use of the Erbe app). You can opt out of receiving interest-based Google advertisements or customize the ads you receive from Google, by visiting http://www.google.com/settings/ads.

Accessing and Correcting Your Personal Information
For questions regarding changes to your user name or profile information, please contact Erbe, LLC. customer support.

Data Security
We have implemented measures designed to secure personal information provided by you through Our App from accidental loss and from unauthorized access, use, alteration, and disclosure.
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 App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although We do Our best to protect your personal information, We cannot guarantee the security of information, including without limitation your personal information, transmitted through Our App. Any transmission of information through the App is at your own risk. We are not responsible for circumvention of any privacy settings or security measures We provide.

Children Under the Age of 13
The App is not intended for children under 13 years of age, and We do not knowingly collect personal information from children under 13. Children under 13 should not have a commercial drivers' license anyway. If We learn We have collected or received personal information from a child under 13 without verification of parental consent, We will delete that information.

Changes to Our Privacy Policy
We may update Our privacy policy from time to time. If We make material changes to this privacy policy, We will post the new privacy policy on this page with a notice that the privacy policy has been updated.
The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting 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:
By email: privacy@fleetspartan.com
By mail: FleetSpartan, Inc.
ATTN: Privacy Officer (Legal)

Privacy Policy: v2021.11.05

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