Privacy Shield Policy

Privacy Shield Policy


Cellcontrol Inc. ("Cellcontrol") has adopted this Privacy Shield Policy ("Policy") to establish and

maintain an adequate level of Personal Data privacy protection. This Policy applies to the
processing of Personal Data that Cellcontrol obtains from Customers located in the European
Union and Switzerland.


Cellcontrol complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield
Framework as set forth by the US Department of Commerce regarding the collection, use, and
retention of personal information from European Union member countries and Switzerland
transferred to the United States pursuant to Privacy Shield. Cellcontrol has certified that it
adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between
the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the
Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to
view our certification page, please visit:


The Federal Trade Commission (FTC) has jurisdiction over Cellcontrol's compliance with the
Privacy Shield.



Data Subject is an identified or identifiable natural living person. An identifiable person is one
who can be identified, directly or indirectly, by reference to a name, or to one or more factors
unique to his or her personal physical, psychological, mental, economic, cultural or social
characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal

Customer is an individual Data Subject or legal entity from EU or Switzerland that has a business
relationship with Cellcontrol. The term also shall include any individual agent, representative of
an individual agent or legal entity who has an employee-employer relationship with a Data

Employee is an employee (whether temporary, permanent, part-time, or contract), former
employee, independent contractor, of a Cellcontrol Customer or its subsidiaries, who is also a
resident of a country within the European Economic Area. An Employee, as used in this
document, does not refer to EU Data Subjects who have an employee-employer relationship with

Personal Data as defined under the European Union Directive 95/46/EC means data that
personally identifies or may be used to personally identify a person, including an individual's
name, address, phone number, e-mail address, user ID, password, and identification numbers.
Personal Data does not include data that is de-identified, anonymous, or publicly available. For
Switzerland, the term "person" includes both a natural person and a legal entity, regardless of
the form of the legal entity.

Sensitive Data is Personal Data that discloses a Data Subject's medical or health condition, race
or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or
trade union membership.

Third Party is any individual or entity that is neither Cellcontrol nor an Cellcontrol employee,
agent, contractor, or representative.



Cellcontrol collects Personal Data from Customers when they purchase its products, register with
our website, log-in to their account, use our product or services, request support, solicit
information or otherwise interact with us.
The Personal Data that we collect may vary based on the Customer's interaction with us, but

• Contact information, including, a contact person's name, work email address, work
mailing address, work telephone number, title, and company name for sales and
• Payment information (which might include credit card and/or bank account information)
to facilitate purchase of our product or services.
• IP address and User Agent information for troubleshooting or analyzing user behavior to
improve our products and services.
• Information about mobile devices when Customers use the Cellcontrol mobile application
or when enrolled in the Cellcontrol Mobile Device Management program to provide the
service expected of Cellcontrol.
• GPS Location information when using the mobile application or a Cellcontrol hardware
device (e.g., DriveTag, DriveID) to provide the service expected of Cellcontrol.
• Vehicle acceleration information of a vehicle that has the Cellcontrol hardware device to
provide the service expected of Cellcontrol.
• Information that is voluntarily entered by Customer about their employees including
person’s name, email, telephone number, and Employee ID to provide service expected
of Cellcontrol.



Cellcontrol uses Personal Data that it collects directly from its Customers for the following
business purposes, without limitation:

• delivering and providing the requested products/services
• maintaining and supporting its products
honoring its contractual obligations related thereto (including managing transactions,
reporting, invoices, renewals, and other operations related to providing services to a
• performing business-related purposes permitted or required under applicable local law
and regulation and as otherwise required by law
• complying with the law
• satisfying Customer requests


All questions, concerns and complaints regarding privacy including the compliance with the EU-
US and Swiss Privacy Shield should be directed to


Except as otherwise provided herein, Cellcontrol may disclose Personal Data to Third Parties who
agree to abide by the confidentiality obligations required to safeguard the data. Third Parties
include business partners, vendors, agents, consultants, and contractors.
For example, Cellcontrol may store such Personal Data in the facilities operated by Third Parties.
Such Third Parties must agree to use such Personal Data only for the purposes for which they
have been engaged by Cellcontrol and they must (a) either comply with the Privacy Shield
principles or another mechanism permitted by the applicable EU & Swiss data protection law(s)
for transfers and processing of Personal Data or (b) agree to provide adequate protections for
the Personal Data that are no less protective than those set out in this Policy. Cellcontrol
recognizes the potential liability when Third Parties do not adequately protect the data
transferred to them.

Cellcontrol may be required to disclose an individual's personal information in response to a
lawful request by public authorities, including to meet national security or law enforcement


Cellcontrol does not collect Sensitive Data from its Customers.



Customers and Data Subjects can request access, correction or deletion of their Personal Data by
sending an email to Upon verification of their identity, they can
exercise the following rights:

Right to Access: Upon reasonable request and as required by the Privacy Shield principles,
Cellcontrol will provide the data stored about the Customer or Data Subject.

Right to Correct: Upon reasonable request and as required by the Privacy Shield
principles, Cellcontrol will correct the data about a Customer or Data Subject.

Right to Delete: Upon reasonable request and as required by the Privacy Shield principles,
Cellcontrol will delete the data about a Customer or Data Subject.

In cases where the Data Subject is an Employee of the Customer who availed of the service, the
Customer may be informed of the Data Subject’s intention of access, correct or delete


Customers and Data Subjects can request Cellcontrol to not collect or transfer some or all data
about their Employees or about themselves respectively. These requests should be directed to

Note however that certain data collection is necessary in order for Cellcontrol to provide the
services it offers.

We will provide an individual opt-out or opt-in choice before we share your data with third parties
other than our agents, or before we use it for a purpose other than which it was originally
collected or subsequently authorized.
To limit the use and disclosure of your personal information, please submit a written request to


In compliance with the Privacy Shield Principles, Cellcontrol commits to resolve complaints about
your privacy and our collection or use of your personal information transferred to the United
States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield
inquiries or complaints should first contact Cellcontrol at:

Cellcontrol has further committed to refer unresolved privacy complaints under the Privacy
Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD,
operated by the Council of Better Business Bureaus.

If you do not receive timely acknowledgment of your complaint, or if your complaint is not
satisfactorily addressed, please visit for
more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain
conditions, you may invoke binding arbitration for some residual claims not resolved by other
redress mechanisms.

See Privacy Shield Annex 1 at



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