Last Updated: October 01, 2022
- Visit our website at dinc.dev, or any website of ours that links to this privacy notice
- Download and use our mobile application (DIMO Mobile), or any other application of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing, or events
Collection of Information
Use of Information
Sharing of Information
Advertising and Analytics
Transfer of Information to the United States and Other Countries
Your California Privacy Rights
Additional Disclosures for Individuals in Europe
COLLECTION OF INFORMATION
Information You Provide to Us
To use the Platform, you must enroll and agree to log-in to certain features through designated third-party provider accounts. If you log-in through such third party accounts, such third party will share certain of your personal data with us in accordance with the terms you have agreed with such third party. In other cases, you may provide personal information directly to us. For example, you share information directly with us when you complete a digital form, submit or post content through our Platform, make a purchase, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, vehicle identification number (VIN), digital asset wallet address and any other information you choose to provide.
The Platform is not directed to children under the age of 16. If you are a parent or guardian and become aware that your child has provided us with personal information without your consent, please contact us at [email protected] If we become aware that a child under the age of 16 has provided us with personal information, we would contact the user, verify their age and, if necessary, seek the consent of the parent/guardian before deleting their data.
You can change your sharing preferences at any time under Settings to what information you wish to share. By default, all sharing of personal information will be turned off.
Personal & Sensitive Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. Depending on your choices in the Settings, the personal information we collect may include the following:
- Vehicle metadata (e.g., VIN, Make, Model, Year)
- Telemetry device attributes (e.g., serial number)
- Vehicle location information
- Vehicle telemetry data including
- steering - angle of wheels/steering wheel
- pedals - throttle (% applied)
- pedals - brake (% applied)
- wheels - speed per tire (lf/lr/rl/rr)
- speed - car speed (on/off)
- metadata - odometer (odometer from vehicle)
- wheels - pressure per tire (lf/lr/rl/rr)
- apertures - door status per door (driver, passenger, trunk)
- apertures - window status per window (open/closed)
- lights - turn signals status (left/right on/off)
- lights - running lights (on/off)
- recovery - low beam (on/off)
- recovery - high beam (on/off)
- seat belts - buckled/unbuckled per seat (lf/lr/rl/rr)
- battery - state of health (as reported)
- battery - battery voltage (overall battery voltage)
- battery - battery capacity remaining (in kwh)
- battery - battery temperature
- battery - battery resistance
- battery - battery information per cell (volts/amps) (values per battery cell)
- battery - estimated range (as reported by the car)
- charging - charging (yes/no)
- charging - charging rate (kwh)
- charging - charging voltage (in volts)
- charging - charging amperage (in amps)
- charging - charging time to full
- regenerative braking - recovery rate (kwh)
- ADAS - engaged yes/no
- ADAS - disengagements (information about disengagements)
- Document photos and associated metadata when you upload license, title, registration, lease, and/or insurance documents
- User preferences and identity including email, wallet address, name, region, app preferences, and app usage which may reveal race or ethnic origin
If you wish to learn more about the above the personal information and sensitive information fields, please read the details under Settings before opting in to sharing your data.
Information We Collect Automatically When You Interact with Us
When you access or use our Platform or otherwise transact business with us, we automatically collect the following information:
- Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
- Transactional Information: When you make a purchase, we (and our service providers) collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
- Device and Usage Information: We collect information about how you access our Platform, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Platform, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Platform.
Information We Collect from Other Sources
We obtain information from third-parties to email you when necessary and obtain analytics of you as a user, to the extent permitted by your local rules and regulations. Additionally, if you create or log into DINC sites or DIMO mobile through a third-party platform (such as Google), we will collect certain information from that platform, such as your name, birthday, and profile picture, in accordance with the authorization procedures determined by such platform.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address, VIN, or wallet address.
USE OF INFORMATION
We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. The purposes for which we process your personal information (and the legal basis for such processing) are set out below:
- To facilitate account creation and authentication and otherwise manage user accounts, as well as keep your account in working order (to perform the Services agreed with you);
- Fulfill and manage your orders, payments, returns, and exchanges made through the Services (to perform the Services agreed with you);
- Provide services, content, material and other information on the Platform (to perform the Services agreed with you, and (where legally required) with your consent);
- Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, and recall notices (to perform the Services agreed with you);
- Personalize and improve your experience on our Platform (for our legitimate interests and (where legally required) with your consent;
- Identify and/or diagnose problems on or related to our Platform (for our legitimate interests);
- Send you technical notices, security alerts, and support and administrative messages (to perform the Services agreed with you);
- Provide requested information, technical support and/or integrations such as an application programming interface or API or information to support your eligibility for a token rewards program (to perform the Services agreed with you);
- Respond to your comments and questions and provide customer service (to perform the Services agreed with you);
- Communicate with you about products, Platform, and events offered by DINC and others and provide news and information that we think will interest you (for our legitimate interests and (where legally required) with your consent). See the Your Choices section below for information about how to update your choices with regard to these communications at any time;
- Monitor and analyze trends, usage, and activities in connection with our Platform (for our legitimate interests and (where legally required) with your consent);
- Target prospective customers with our products or services (for our legitimate interests and (where legally required) with your consent);
- Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of DINC and others (for our legitimate interests);
- Debug to identify and repair errors in our Platform (for our legitimate interests);
- Comply with our legal obligations;
- Carry out any other purpose described to you at the time the information was collected (to perform the Services agreed with you, for our legitimate interests or with your consent, as applicable); and
- To save or protect an individual’s vital interest, such as to prevent harm.
SHARING OF INFORMATION
We share personal information in the following circumstances or as otherwise described in this policy:
- If you choose to use integrations we offer on our Platform, we may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
- Cloud Computing Services
- Data Analytics Services
- Data Storage Service Providers
- Finance & Accounting Tools
- Order Fulfillment Service Providers
- Payment Processors
- Testing Tools
- Ad Networks
- Affiliate Marketing Programs
- Sales & Marketing Tools
- Performance Monitoring Tools
- Product Engineering & Design Tools
- User Account Registration & Authentication Services
- We may disclose personal information if that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We may share personal information if you have violated the law, or if this is necessary to protect the rights, property, and safety of DINC, our users, the public, or others to the extent required for us to pursue, defend or enforce our legitimate legal rights, and where required by mandatory laws.
- We may share personal information in connection with, or during negotiations concerning, merger, sale of company assets, financing, bankruptcy, business closure, or acquisition of all or a portion of our business by another company.
- We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- We share personal information with the DIMO foundation with your consent for instance for the token reward program.
We will disclose the following categories of personal information for business purposes to the following categories of recipients:
TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES
DINC is headquartered in the United States, and we have operations and service providers in the United States and other countries. Therefore, we and our service providers will transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. However, to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it we encrypt all at-rest data and on-transit data with the TLS 1.2 protocol.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our approved third-party providers mentioned above. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request.
You may also opt out of receiving said promotional emails from DINC by following the instructions in those communications or by emailing [email protected] If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Our Platform may contain links to third-party websites and applications. Any access to and use of such linked websites and applications is not governed by this policy but instead is governed by the privacy policies of those third parties. We do not endorse these parties, their content, or any products and services they offer, and we are not responsible for the information practices of such third-party websites or applications.
YOUR CALIFORNIA PRIVACY RIGHTS
California law, including the California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) and the Shine the Light law (Cal. Civ. Code § 1798.83), afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.
California Consumer Privacy Act
We will collect the following categories of personal information: identifiers, internet or other electronic network activity information, inferences and classification characteristics. For details about the data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. We will disclose the following categories of personal information for business purposes to the following categories of recipients:
California law requires that we provide transparency about personal information we “sell,” which, for the purposes of the CCPA, broadly means scenarios in which DINC has shared personal information with third parties in exchange for valuable consideration. You will have the opportunity to opt-in to allow DINC to share or “sell” personal information, with your consent at enrollment, so others may advertise products to you or for other uses as described herein. DINC will only share personal information with your express consent and as agreed within DINC’s terms of service. We may enable the “sale” of the following categories of personal information to the following categories of third parties.
Digital Infrastructure Inc. may sell the following categories of personal information to third parties:
- Category A. Identifiers, such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.
- Category B. Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information.
- Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth.
- Category D. Commercial information, such as transaction information, purchase history, financial details, and payment information.
- Category E. Biometric information, such as fingerprints and voiceprints.
- Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
- Category G. Geolocation data, such as device location.
The categories of third parties to whom we may sell personal information are:
- Data Analytics Services
- Insurance companies
- Retargeting Platforms
- User Account Registration & Authentication Services
- Ad Networks
- Vehicle Manufacturers
- Government and Public Agencies
- Vehicle Services Providers
- Energy Companies
- Ride Hailing and Taxi services
- Fleet Management Providers
Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, and sell, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests by emailing us at [email protected] We will verify your request by asking you to provide information related to your recent interactions with us, such as your name, account number and/or address. We will not discriminate against you if you exercise your rights under the CCPA.
If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact [email protected]
Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please email us at [email protected]
Do Not Track Signals
Our Services do not respond to “Do Not Track” signals communicated by your browser. We do not knowingly retain or sell tracking information collected about your online activity. For more information about Do Not Track, please visit www.allaboutdnt.com.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE
If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.
Legal Basis for Processing
When DINC processes your personal data, DINC will do so in reliance on the following lawful bases:
- To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and Platform you requested). [Art. 6 Par. 1 lit. b GDPR]
- When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and Platform, conduct data analytics, and communicate with you). [Art. 6 Par. 1 lit. f GDPR]
- To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications). [Art. 6 Par. 1 lit. c GDPR]
- When we have your consent to do so (e.g., when you enroll and opt in to receive marketing communications from us and our partners and/or enroll in the token rewards program). When consent is the legal basis for our processing of your personal data, you may withdraw such consent at any time (free of charge) and with effect for the future. [Art. 6 Par. 1 lit. a GDPR]
We store personal data associated with your enrollment for as long as your use of our services and products remains active. In order to close your account, please contact us at [email protected] If you close your account and terminate your affiliation with DIMO, we will deactivate your account and delete any data that may be traceable back to you within 30 days; otherwise, we will delete your account data after thirty-six (36) months of inactivity. We will anonymize (make it untraceable back to you) and store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
Data Subject Rights and Requests [Art. 15 . 21 GDPR]
Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format and/or make it available for a third party named by you, the right to ask that your personal data be corrected, completed or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please email us at [email protected] If you revoke your consent or object to processing, we will no longer process your data and delete it, unless the processing is permitted on another legal basis.
QUESTIONS OR COMPLAINTS
You have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
Postal address: Digital Infrastructure Inc., 8 The Grn, Ste B, Dover, DE 19901-3618
Representative for data subjects in the EU and UK
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/12486691153