Donlen LLC and its subsidiaries (together “We”, “Us”, and “Our”) respect the privacy rights of Our customers and We are committed to protecting your privacy. This Privacy Policy (this “Policy”) explains Our data handling practices” with regard to your Personal Information (as defined below), as well as your rights associated with your Personal Information. This Policy was last materially updated on June 17, 2020.

If you want to print out this Policy, you may “right-click” on the policy in your browser and choose “print” in the dialog box that appears.

• Quick Reference Guide
• Scope
• Data collection (What & How)
• Purposes for processing
• 3rd party Recipients
• International Transfers
• Cookies and Online Advertising Choices
• Security
• Data Retention and Integrity
• Access, Correction, and Portability
• Withdraw Consent or Complaints
• Contact Us
• Changes

A. QUICK REFERENCE GUIDE:

1. Scope
   • This policy covers the Personal Information We obtain from you in connection with Our fleet leasing and fleet management businesses and other associated businesses “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
   • This policy does not cover information that cannot be related to you as an individual or your household.

2. Information We collect (what & how)
   • We, Our, business partners Our customers, and service providers may collect information from you in a multitude of ways, including, but not limited to, phone calls, customer service contacts, mobile apps, websites, and other sources.
   • We collect information directly from you, your employer or other third party who authorizes your use of a vehicle or equipment, through various channels, and from companies involved in Our provision of services to you.
   • We collect Personal Data to provide you with exceptional services, including, but not limited to;
     1. Name, phone number, address, email address
     2. Employer information (number, address, contact information)

3. Purposes for processing
   • Information you provide will be used to provide you with the services you request or requested by your employer or other third party in connection with your use of a vehicle or other equipment.
   • We will use the contact information to communicate with
   • We use “cookies” and other electronic tools to collect statistical information about your use of Our websites. This information is used for research and other reasons, generally to better help Our customers by showing Us how We can improve Our
   • We do use Personal Information for Our own analytical purposes.
4. 3rd Party Disclosures
   • We may provide your information to third party service providers and other entities.
   • We do not sell your information to unrelated third parties for purposes of marketing their products of
   • We may share your information for marketing purposes to those with which We have an agreement to do joint advertising, subject to your consent.
5. Security
   • We use reasonable measures to safeguard Personal Information from theft, unauthorized use, disclosure, or
   • We aim to maintain appropriate physical, procedural and electronic safeguards to protect your Personal Information.
6. Data retention
   • We generally keep customer information for as long as We believe necessary for the purpose for which it was collected, or as allowed by law.
7. Access, correction & portability
   • You will have access to review or update Personal Information that is collected from and about you, so you can change any information that is
   • We will try Our best to accommodate your request, but We reserve the right to impose certain restrictions and requirements.
8. Withdraw consent or complaints
   • Where We use consent as a basis for processing, you can always withdraw that consent.
   • If you feel that this policy has been violated, We will work with you to resolve your concerns.
9. Changes
   • We may modify this Privacy Policy at any time, but changes will not apply retroactively.
   • We will notify you when We make material changes by posting a note on the homepages of Our websites.

Our goal is to provide Our customers with excellent services. We do business in the United States and Canada and We aim to comply with all privacy laws that apply to the data We collect and use. This policy is subject to compliance with local law. Where this policy provides a higher standard than local law, this policy will control how Donlen handles your Personal Information. By providing your Personal Information to Us, Our designated service providers, or other third parties as noted within this Policy, you consent to Our use and disclosure of your data for the operational and other purposes listed in this Policy.

1. SCOPE

Donlen LLC and its specific subsidiaries collect Personal Information as set forth in this Policy. As Our entrusted third party vendors are independent companies, they are not owned or controlled by Us and are not covered by this policy. We are not responsible for the privacy practices of other third parties with whom you may transact.

This Policy covers the Personal Information We collect about you in connection with Our fleet leasing and fleet management businesses. “Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not apply to information that cannot reasonably be related you as an individual or your household. For example, but without limitation, aggregated anonymous data, computer operating systems, aggregated preferences, vehicle identification numbers, etc. are not Personal Information.

Our websites are not directed to individuals under the age of 13, and We do not knowingly obtain Personal Information from such individuals.

2. DATA COLLECTION (WHAT & HOW)

We, both directly and through service providers, and business partners, and collect Personal  Data that you or your employer or other third party in connection with your use of a vehicle or other equipment provide on Our websites, on third party websites, on applications, and offline in connection with any inquiries, purchases, or services.  Information collected about your use of Our websites, applications, or other websites may be combined with personal or other information about you from other online or offline sources.  We also will collect Personal Information across all the devices you use to access  Our websites or  Our applications and service providers’ websites and applications.

Providing your Personal Information to Us may be required due to a legal obligation which could be a statutory or contractual obligation, may be on a voluntary basis or may be necessary for us to enter into the contract with you, depending on the purposes for which we collect and use your Personal Information as set out in this Privacy Statement. However, if you do not provide your Personal Information to Us, this may result in disadvantages to you, e.g. we may not be able to provide certain products or services to you. However, unless otherwise stated, not providing your Personal Information will not result in legal consequence for you.

Do not provide information about others unless you are authorized to do so and have obtained consent to have all information used, disclosed, and transferred in accordance with this Privacy Policy. By submitting information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and for non-EU residents, that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

a. TYPES OF INFORMATION COLLECTED:The types of information collected regarding you and your interactions with Us may include, but is not limited to:

Personal Information:

Technological Information:

Your name, Email address, Phone number, Address, Employee ID number, Employer name and contact information, Data related to claims and violations Social Security Number (but only with respect to use as a business tax identifier), Driver’s License

IP address, Device ID, IP address; Browser type, Language, Operating system, Mobile device identifiers, Geo-location data, The date and time of a visit, The state or country from which you accessed Our websites, The date and the time of a visit, The number of links and specific links you click within Our websites, The functions you use on Our websites, Any purchases or other transactions through Our websites, The data you view or download from Our websites

Sensitive Data: We, both directly and through service providers and business partners may collect certain Personal Information that constitutes sensitive data. Depending upon applicable local law, We may be unable to process such sensitive data without your consent. Data about your health conditions is regarded as sensitive. If you ask Us to accommodate a disability, such as by provision of hand controls, or if there is an accident and We need to work with insurance and claims management companies relating to any injury you may incur, We may need to process data about your health conditions.

Please note that if you need to provide sensitive data, we will use that sensitive data for Our operational uses as described in this Privacy Policy, subject to your consent where required under applicable law.

b. METHODS AND SOURCES OF COLLECTION: We, both directly and through service providers and business partners may collect your information through a variety of methods. These methods may include, but are not limited to:

On Line / Off Line

Our websites,

Our mobile “apps”, Our official third party social network pages,Your company’s data feed, Your computer’s web browser, Third party social networks,Your employer or other third party that authorizes your use of a vehicle or equipment,

Calls to or from Our call centers, In-vehicle or in-equipment technology or through other telematic devices, Consumer reporting agencies, Other companies that have business relationships, with Us, such as Our affiliates and business partners, Companies involved in the provision of services to you, Claims management service providers (either affiliated directly with Us, or operated by a third party)

c. UTILIZATION OF COOKIES AND OTHER ELECTRONIC TOOLS: We and Our service providers, business partners and third party vendors, may place, view, or use “cookies”, web server logs, web beacons, pixel tags, or other electronic tools to collect statistical and other information about your use of Our websites and other websites. This information may include information described above in Section a

We and the parties with which We work, as described in this Privacy Policy, may use the information collected for the purposes described in this Privacy Policy, or as allowed by law; either on behalf of Us or third parties; including operational changes, research, analysis, to better serve visitors to Our websites (such as by enabling log-in, providing access to certain sections of websites or providing customized content to you or your interests as described further below), to compile aggregate and anonymize information about usage of Our websites and other websites, other statistics, and more.

The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, Our sites are not compatible with DNT and so do not recognize DNT settings.

For information on all of these categories of cookies, and for more information generally on cookies please refer to aboutcookies.org.

If you have deleted and disabled cookies, these uses will not be possible to the extent they are based on cookie information.

d. VEHICLE MANUFACTURERS: Please note that the vehicles you operate may collect Personal Information about you. We are not responsible for these activities, and such collection (and use) is subject to the vehicle manufacturer’s policies and notices.

3. PURPOSES FOR PROCESSING

a. OPERATIONS AND SERVICES: We, both directly, through Our service providers and business partners, and third party vendors may use your information to provide you with the services or products you request from

We may use your information to communicate with you regarding any services requested or required, including, without limitation, the services set forth below in this paragraph, or changes to the terms or features of any of Our programs and/or services provided to you and/or your employer or other third party who authorizes you use of a vehicle or equipment. We will share your personal data among our employees, our agents, our service providers, your service providers, other companies and/or governmental agencies to provide services to you, including, without limitation:

• Fleet leasing services;
• Fleet management services;
• Fleet administration services;
• Telematics services;
• Customer satisfaction and market research purposes to help us improve Our services;
• To provide you with customer assistance;
• To order and/or deliver a vehicle that was ordered by you, your employer or other third party who authorizes your use of a vehicle or equipment;
• To process your vehicle upgrade transaction; and/or
• To process your vehicle purchase transaction, including the processing of your vehicle’s title and

We therefore process your Personal Information for these purposes to the extent necessary  to provide you with Our services and to perform our contract with your employer or other third party who authorizes your use of a vehicle or equipment

For United States Residents, so that We may communicate with you, you give Us your consent to call you on or send text messages to your mobile telephone/device. You also consent to Our use of auto-dialers and pre-recorded messages in connection with any such telephone call or text message, including calls or texts to mobile telephone numbers. Your mobile service provider may charge you according to the applicable plan to which you subscribe.

We may also share your information with companies you use in connection with your fleet leasing and/or management services, including:

• Your credit card provider and other companies that process your charges;
• Your employer or other third party who authorizes your use of a vehicle or equipment; or
• Any company or organization that is providing a service in connection with your fleet leasing and/or management services.

b. OUR MARKETING: We, both directly and through Our service providers, business partners, and third party vendors may use your Personal Information to provide you with marketing information, special offers, and promotions via various means including e-mail, in accordance with applicable law. We may share your personal data with our parent company, affiliates and business partners for their marketing

Where We have obtained your consent to send these marketing communications to you, We therefore process your Personal Information for these purposes on the basis of your consent.

However, where permitted by applicable law We may lawfully use your Personal Information to send you such marketing communications (including via email) without your consent. Where permitted by applicable law We may also process your Personal Information for these marketing purposes where necessary for Our legitimate interests, which include promoting Our products and services, special offers and promotions which may be of interest to you.

You can unsubscribe from receiving such messages at any time by contacting Us at the details below under “Contact Us” as well as the unsubscribe link in each e-mail message. You can also request at any time that We do not to use your Personal Information covered by this Privacy Policy to provide you with special offers and promotions by contacting Us at the details below under “Contact Us”. Please note that if you exercise these choices, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you. Please also note that this opt-out process may take some time to complete, consistent with applicable law. Third party organizations are solely responsible for their own practices, and an unsubscribe request must be sent to any such organization from which you would like to stop receiving marketing materials.

c. THIRD PARTY PURPOSES: As part of Our Services, We have engaged with third party organizations to complete requested and required services. As a result of Our relationship with these third party organizations, We may be under an obligation to provide the third party with details about you and your use of Our services as they relate to your relationship.

We Process your Personal Information in relation to third party organizations to the extent necessary for performance of our contract for services.

Third party organizations may have different privacy practices than We do, and We recommend you review the third party organization’s privacy policy for the purposes which they will use your information. As We do not control the third party organization’s privacy practices, they may not be the same as Ours. However, because of your relationship with the third party organization, they can use Personal Information which they receive from Us for the purposes specified in their privacy policies or similar statements.

d. NORMAL COURSE OF BUSINESS: We may also process your Personal Information and other information if such processing is necessary:

(a) to comply with the law or in response to a subpoena, court order, law enforcement request, or other legal process; (b) to protect the interests, operations, rights, safety, privacy, or property of Us or others; (c) to enforce any terms of use on Our website; (d) to provide you and others with the services or products requested by you or your designated representative or your employer or other third party who authorizes your use of a vehicle or equipment, and to perform other activities related to such services and products, including billing and collection; (e) to provide you with special offers or promotions from Us that may be of interest to you, where permitted; (f) as part of a business transaction where all or some of Our assets are bought, sold, or otherwise transferred by act of law or contract; (g) to recover our vehicles, equipment or any monies due, such as through debt collection agencies; (h) to allow us to pursue available remedies or limit the damages that we may sustain; (i) to process, handle or otherwise respond to claims for damages, including claims or demands for bodily injury or property damage; or (j) to operate Our systems properly.

4. DISCLOSURES TO AFFILIATES AND THIRD PARTIES:

a. THIRD PARTY PROVIDERS:For the purposes described in this Policy,  We may share your personal and other information with our service providers, business partners and other third party providers,. We may share with other third parties aggregate or anonymized information about Our website users, such as your use of this website or other websites, and the services provided on this website or other websites, as well as any service or utilization information. We may provide information about you and your interactions with Us to any third party organization used ,to complete contracted services. We may also share your Personal    Data with a third party that provides you with special offers or promotions that may be of interest to you (“Third Party Provider”) where permitted. You may instruct Us at any time not to share your Personal Information covered by this Privacy Policy with such Third Party Providers by contacting us in the manner set forth below. Please note that  (i) this opt-out process may take some time to complete, consistent with applicable law; and (ii) even after such opt-out process is completed,  your personal and other information may continue to be shared with our affiliates (including affiliated websites under common ownership or control)  and designated service providers.

b. SOCIAL MEDIA: If you participate in certain public features of our websites, apps, or social media websites/apps, please note that any information you or others voluntarily disclose through use of such features, becomes available to the public and/or other users whom you have If you choose to provide access credentials to designated individuals, please be aware that any information you provide to Us may be visible to such individuals. We are not responsible for the information that you or others choose to disclose publicly and neither Our nor others’ use of such information is subject to this Privacy Policy.

c. LINKS TO THIRD PARTIES:We may provide links to third party websites, or may be linked to from third party websites. Since We do not control third party sites, and We are not responsible for any information you may provide while on such sites, We encourage you to read the privacy policies on those websites before providing applicable third parties with your information.

d. GENERAL COURSE OF BUSINESS: We may also disclose your personal and other information to unaffiliated third parties if We believe in good faith that such disclosure is necessary: (a) to comply with the law or in response to a subpoena, court order, law enforcement request, or other legal process; (b) to protect the interests, rights, safety, or property of Us or others; (c) to enforce any terms of use on Our websites; (d) to provide you and others with the services or products requested by you, your designated representative, or your employer or other third party who authorizes your use of a vehicle or equipment and to perform other activities related to such services and products, including billing and collection; (e) to provide you with special offers or promotions from Us that may be of interest to you; or (f) as part of a business transaction where all or some of Our assets are bought, sold, or otherwise transferred by act of law or contract.

5. INTERNATIONAL TRANSFERS

All data is housed and processed in the United States. No data is transferred or processed in another country.

6. COOKIES AND ONLINE ADVERTISING CHOICES

Many browsers are set to accept cookies by default. You may be able to set your browser to disable cookies, or alert you when cookies are being sent. Many mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies, or disable the collection of geo-location data.

You need to set each browser on each device you use to view websites. If you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of Our websites or other websites will not function properly. We may not respond to a web browser’s “do not track” signal, or other mechanism that indicates a request to disable online tracking of individuals who use or visit Our websites.

With regard to mobile apps, any app’s collection and use of Personal Information that is materially different from what’s described in this Policy will be supplemented by an individual Privacy Policy that will require acceptance for that specific app.

In addition to the options provided by your mobile operating systems, you may opt out of the collection of information on mobile apps as follows:

• Uninstalling the app.You can stop all collection of information by the app by uninstalling the app. You may use the standard uninstall processes as may be available as part of your mobile device or via the Mobile Application marketplace or network from which you downloaded the app;
• Opt out of location data.Go to “settings” on your mobile device to opt out of the collection of location
• Opt out of cross-app data The Digital Advertising Alliance (“DAA”) offers a separate choice tool for the collection of cross-app data on a mobile device for interest- based advertising and other applicable uses. To exercise choice for companies participating in this choice tool, you can install the DAA’s AppChoices app (http://www.aboutads.info/appchoices).

7. SECURITY

a. We use reasonable administrative, technical, personnel, and physical measures (a) to safeguard Personal Information against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of your Personal Information. To help Us protect your privacy, you should maintain the secrecy of any logon IDs and passwords, or other identifiers or credentials you may have set up or were provided with in connection with your participation in or use of Our products, services, or websites.

As you may be aware, there is no completely secure method of transmitting or storing data. Although their physical characteristics are different, postal mail,  telephone calls,  text messages, faxes and transmissions over the Internet or wireless networks all present possibilities of loss, misrouting, interception and misuse of the data that is transmitted. If you have reason to believe that any account with Us is no longer secure, you must immediately contact Us.

We try to strike a balance between the security of your data and your convenience. As a result, We may sometimes use a method of communication that is less secure than a less convenient alternative. For example, but not limitation, We may send you an e-mail or a text message in unencrypted form (i.e. instantly readable) because many of Our customers are unable to access encrypted (i.e. coded) e-mail or messages. This means that Our message,  if misrouted or intercepted, could be read more easily than encrypted messages. Such messages may contain Personal Information. Please do not include confidential information, such as your credit card number or account passwords, in any e-mail or text you send to Us or on any posting you make to a public area of a third party social network page, especially since any such posting immediately becomes public. For a more secure way to communicate with Us over the Internet, please click on the “Contact Us” link on any of Our websites.

8. DATA RETENTION & INTEGRITY

We retain personal data about Our customers for as long as necessary for the purposes for which it was collected, or unless otherwise allowed by law. Information is stored and accessed in various locations, and cloud services and storage may be utilized. Servers which store information are located in the United States.

9. ACCESS, CORRECTION & PORTABILITY

a. To access, review, or update your Personal Information covered by this Privacy Policy, please contact Us at the details set out in the “Contact Us” section below. While We will make reasonable efforts to accommodate your request, We also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable You may update your profile by logging into your applicable account profile. Please note that data transmitted by your company may be in conflict with your manual data update and in such cases, the company update will overwrite your manual update.

b. RIGHT TO BE FORGOTTEN: We may retain your Personal Information as is necessary to fulfill the purposes for which the Personal Information was collected. We may also retain this Personal Data as required by law or contract, in order to fulfill Our legal obligations and protect Our legal rights. However, once the purpose for the collection is no longer valid, and there is no legal reason for Us to retain your Personal Information, you may request Us to delete your Personal Information. You may make this request by contacting Us via the mechanism provided below in the “Contact Us” section of this Policy. If We are unable to delete your Personal Information due to one of the reasons described in this Policy, We will provide you with the reason We are unable to fulfill your request.

10. COMPLAINTS

Please contact Us as specified below if you have any questions, need access to your Personal Information, or otherwise need assistance. We are responsible for third party agents that are processing data on our behalf, unless we prove that we are not responsible for the event giving rise to the damage.

Should you have a concerns or complaints about the handling of your Personal Information being in violation of this Privacy Policy, you may contact us directly via the methods described below in the “Contact Us” section. We will work to respond and resolve your complaints in an expeditious manner.

11. Contact Us

Please contact us by email privacy@donlen.com, or by calling (224) 383-1800, or by writing to the address below.

Donlen
Attention: Legal-Privacy
3000 Lakeside Drive
Bannockburn, IL 60015
USA

Attention: Legal-Privacy

We do business in the United States and Canada and aim to comply with the privacy laws applicable to the Personal Data we collect and use.

12. CHANGES

We reserve the right to change this Privacy Policy at any time for any reason by posting revisions on this Webpage or on applicable apps or other sites. Such changes will be effective upon posting, but will not apply retroactively. Whenever We make a material change, We will note the date of such update in the introductory paragraph above, and post a note on the home page of our applicable websites.