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ORBCOMM Privacy Policy

This ORBCOMM Privacy Policy (“Policy”) is effective as of May 23, 2018, and it governs the online privacy practices of ORBCOMM Inc. and its affiliates, including ORBCOMM Networks LLC, ORBCOMM AIS, ORBCOMM LLC, StarTrak Information Technologies, StarTrak Logistics Management Solutions, MobileNet LLC, GlobalTrak, LLC, ORBCOMM SENS, ORBCOMM Europe B.V., ORBCOMM Europe GmbH,, Ameriscan, Inc., SkyWave Mobile Communications Inc., InSync Software, Inc., inthinc LLC, Blue Systems Ltd., Blue Tree Systems GmbH, Blue Tree Systems SARL and Blue Tree Systems Inc. (collectively, “ORBCOMM”). Your prior activities on the site may have been governed by an earlier version of this Policy.

We at ORBCOMM take your privacy seriously. This Privacy Policy describes how we handle personally identifiable information (“Personal Information”) and other information that we collect or receive through the operation of ORBCOMM products and services, any web sites, portals, telecommunications, technical or customer service support or information and as part of any of our other business activities.

This Policy applies to information collected by us in whatever format and through any medium including our website, telephones, portals, tablets and other devices; or, potentially Personal Information about you and/or your employer or employees in the course of the provision of our products and services, and how we may use and share it.

ORBCOMM is the sole owner of the information collected from our website. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement. However, from time to time, we may use your information for new, unanticipated uses not previously disclosed in our Policy. If our information practices do change, we will post the changes to our website and revise our Policy accordingly. In addition, if we have collected personally-identifying information from you, we will notify you and secure your consent before using your personal information in new ways.

WHAT INFORMATION DO WE COLLECT?

The information we collect varies depending upon your activities when visiting our web sites.

Public web site data collection:

ORBCOMM does not require that you register or otherwise provide any Personal Information in order to visit or browse our web site. However, ORBCOMM does collect certain Personal Information, including your name, email addresses, and any other information you provide including credit/debit card or other financial information when you:

  • request information from us through our web site(s); or
  • make a purchase through our web site(s); or
  • contact customer support.

This information may be used by us to provide the requested services or products and to contact you in the future to convey information about our products and services. You are under no obligation to provide us with this information, but without it, we may not be able to take the action requested.

Access-controlled Web Portals/telematic devices data collection:

Our services may be provided through telematics devices installed on customer assets which transmit a variety of information to us for processing via wireless communication, global positioning satellite, internet and other technologies.

In addition, for each visitor to our site, we automatically gather certain other potentially identifying information and store it in log files. This information includes (as applicable) internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, your operating system, date/time stamp, processor or device serial number, unique device identifier, and clickstream data. We collect and store this information on an individual basis and in aggregate, or combined, form. We also collect both user-specific and aggregate information on what pages visitors access or visit. This information is used for the maintenance and improvement of our on-line and data processing services.

When we receive a “Do Not Track” signal from your browser, we do not respond to or process it.

Cookies – We use session cookies on our websites. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. If you reject cookies, you may still use our main corporate site, but your ability to use some other sites of ours or areas of our sites will be limited.

We use session cookies to make it easier for you to navigate our site. We use session cookies to record session information, such as which web pages a user has visited, and to track user activity on the site. We also use session cookies to store any passwords used on the site (such as a password associated with a user account), so you don’t have to enter it more than once per session. Session cookies expire when you close your browser.

Analytics – To determine how many users visit our site, how often they visit this site, and to better understand the areas of greatest interest to our visitors, we use a tool called “Google Analytics” to compile this information for us. As a result of your visit to our site, Google Analytics may collect information such as your domain type, your IP address and clickstream information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected through Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party advertisers – We do not currently have third party advertisers on the site.

LEGAL BASIS FOR COLLECTION OF DATA

ORBCOMM, as a data processor, collects the Personal Information of certain data subjects in accordance with Article 6(1)(f) of the GDRP, which states that a legal basis for the collection of Personal information is proper when the “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a Third Party...” Through our contracts with data controllers, we rely on data controller’s legitimate interests in the global management of their asset classes to collect and retain Personal Information.

HOW DO WE USE THIS INFORMATION?

Public web site data use:

We also use information we collect to analyze trends, to administer the site, and to track users’ movements around the site. We also use this information to improve the content of our web pages and to make our site more useful to visitors.

Access-controlled Web Portals/telematic devices data collection:

Once you have purchased an ORBCOMM product or service, we may use your Personal Information in a number of ways, including: (a) to allow you to use the product, and to allow us to deliver the services to you and to bill you for such uses of the product and services (including sharing that information with roadside assistance providers, emergency service providers or others); (b) to communicate with you about your account; (c) to check, maintain, or update your hardware and software; (d) to help you to maintain your asset based on diagnostic information; (e) to evaluate and improve products and services; (f) to enforce the terms and conditions of any user agreement or license between you and ORBCOMM; (g) to prevent fraud or misuse of the products and services; (i) to comply with legal requirements, court orders or criminal investigations; (j) to develop and offer you new or additional products or services; (k) to confirm your eligibility for car insurance discount programs, if applicable and available; and (l) to perform market research, benchmarking and statistical analysis. Upon activation of some ORBCOMM products, you may have to provide us with the name of an individual, including yourself, who will be the designated operator of the associated asset. Our records will reflect such designation until you communicate a different designated operator. Accordingly, to ensure accuracy of our records at all times, you are responsible for notifying us of any changes to the designated operator so as to indicate the actual operator of the vehicle or asset at any particular time.

Personal Information that you submit in order to log onto site the will be used to record your access and activities on the secure portion of the site and for the purpose of identifying the correct account to bill for any services ordered or modified by you during your visit.

Information you enter during your visit will be used to record and fulfill your orders for new or modified services, to address problems or equipment or service issues you may report through an ORBCOMM website, and any other actions you may take during your visit to update information or manage your account. If you are a customer of an ORBCOMM affiliate that provides you with cellular communications service or data service that includes cellular communications service, your information, including the Personal Information you enter in order to log onto <orbcomm.com> will be shared with the underlying carrier or carriers of your terrestrial M2M services (identified in your agreement with the ORBCOMM affiliate in question) to the extent required by the applicable carrier in order to affect your orders for new or modified cellular service, to address reported problems or issues, or to update information or otherwise manage your service. Treatment of such information by the carriers is not under the control of ORBCOMM, and its use is governed by the privacy policies of such carrier as stated on that carrier’s web site. We use GPS information in connection with providing our services. We may share that information with third parties, but only in aggregate form.

Other than Personal Information, ORBCOMM may license, sell, or otherwise share anonymized and aggregated information collected through the use of the products and services to third parties, including insurers. This anonymized and aggregated information may include information about a type of vehicle or asset’s performance, geographical location, asset diagnostics, the driving experience of a particular age group, or other reported events on an aggregated basis that is completely anonymous and not identifiable to any individual. We will respond to subpoenas, court orders, legal process and other official demands and may use information to enforce or exercise our legal rights or defend against legal claims.

It is possible that, at some time in the future, our company may be sold along with its assets, or may engage in business transactions in which customer information is one of the assets transferred. In such a case, the customer information which we have gathered may be one of the business assets we transfer or to which we allow confidential access to a prospective purchaser.

CHILDREN’S INFORMATION. This site is intended for adult-use only. We do not direct any part of our site to children less than 18 years old.

DISCLOSURES & ACCOUNTABILITY FOR ONWARD TRANSFERS

Consistent with this Policy, we may transfer personal information to third parties, including from one country to another. We will only transfer your information under one of the following conditions:

The disclosure is to a third party providing services to ORBCOMM in support of our business operations and which is consistent with the purpose for which we collected the information. We have entered into agreements with these third parties and require that they comply with applicable laws regarding personal information, but not less than the privacy protection and security requirements set forth in the Privacy Shield Principles. ORBCOMM remains liable and responsible under the Privacy Shield Principles for any third-party processing personal information on our behalf that is inconsistent with Privacy Shield Principles, unless ORBCOMM can provide evidence that it was not responsible for the issue that gave rise to the damage.

With your permission to make the disclosure

Where ORBCOMM is required to meet a legal obligation, such as a lawful demand by a public authority, law enforcement or other national security obligations, as well as applicable law, rule or regulation.

Where it is reasonably necessary for the establishment of a legal claim or to meet compliance or regulatory purposes.

HOW LONG DO WE KEEP THIS INFORMATION?

If we develop a business relationship with you as a result of your inquires on the site, we will retain your information in accordance with our continuing business need to service this relationship. If you create a user account on the site, we keep your account information for so long as you are using the account. Information collected through this site is retained in aggregated form.

Right to review and correct information

For Personal Information you have given to us, directly, you have the right to review your Personal Information we hold about you. In order to do this, you must send us a written request to privacy@orbcomm.com. If the information we hold about you is incorrect, you have the right to request its correction or deletion.

For Personal Information provided to us by a data controller through your employment with that data controller, you must contact that organization to discuss the mechanism for determining how to access Personal Information we may retain as a data processor.

Right to withdraw your consent

You have the right to request erasure of your Personal Information in the following circumstances:

  • The information is no longer necessary for the purpose for which it was collected
  • You withdraw your consent to processing, and there is no other legal ground for processing, i.e., the controller cannot demonstrate an overriding legitimate basis for processing
  • The processing is otherwise unlawful

Subject to the applicable law, you have the right at any time to withdraw your consent given to the data controller to process your Personal Information, by sending notifying the party directly responsible for your information collection. We will work with the data controller to fulfill your request, however, we retain the right to retain your Personal Information in the event we need to adhere to a legal requirement. Please note that your withdrawal shall not affect the lawfulness of processing we have previously made based on your consent.

INFORMATION SECURITY AND QUALITY

ORBCOMM takes appropriate technical and organizational measures to protect your Personal Information from loss, misuse or alteration.

If you wish to know what information ORBCOMM has collected about you or if you wish to change data that you cannot change yourself on the site, then you can send a request for information on your personal data to: <customer.care@orbcomm.com>. ORBCOMM will respond to your request within 4 weeks. If you then wish to have your personal data corrected, added, removed or blocked your personal data, you may send another request thereto. ORBCOMM shall respond within 4 weeks to such a request. If ORBCOMM decides to not comply with your request, it shall inform you on the grounds of this decision.

We reserve the right to ask for information verifying your identity prior to disclosing any information to you or making any corrections. Should we ask for verification, the information you provide to verify your identity will be used only for that purpose.

LINKS TO THIRD PARTY SITES

ORBCOMM websites may include links to other Internet sites not operated by us. Your access and use of such sites, including information, material, products and services therein is solely at your own risk. We are not responsible for the privacy practices or the content of such sites.

PRIVACY SHIELD

The Federal Trade Commission has jurisdiction over ORBCOMM’s compliance with Privacy Shield.

ORBCOMM complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union and Switzerland to the United States. ORBCOMM has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and our Privacy Shield policy statement, the Privacy Principles shall govern. You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint, under certain circumstances. To learn more about the Privacy Shield program, and to view our certification, please view our Privacy Shield statement at https://www.orbcomm.com/en/privacy-shield or visit www.privacyshield.gov.

QUESTIONS ABOUT ORBCOMM’S PRIVACY POLICY

If you have any questions, inquiries or complaints about the Policy or our privacy practices, you may contact:

Wayne Kaufman
Data Privacy Officer
ORBCOMM
395 W. Passaic St., Ste 325
Rochelle Park, NJ 07662
Tel: +1-703-433-6300
privacy@orbcomm.com

PRIVACY DISPUTE RESOLUTION

For data subjects in the European Union and Switzerland, if you have made a complaint relating to this policy directly to our General Counsel and we do not resolve the complaint to your satisfaction within a reasonable time, then you may file a dispute, at no cost to you, with our independent alternative dispute resolution provider, the Judicial Arbitration and Mediation Service (“JAMS”) by following the instructions on their website, <https://www.jamsadr.com/eu-us-privacy-shield>.