This Privacy Policy (this “Policy”) describes the practices of Toggle, Inc., (“Toggle”) for collecting,using, maintaining, disclosing, and otherwise processing (collectively, “Processing”) the information thatwe collect from you, as well as how we protect and secure your data. If you have additional questionsregarding your rights under this Policy or any agreement you may have with Toggle regarding your data,please contact us. Please read this Policy carefully to understand our Processing of your information and how we will treat it.
This Policy generally applies to the information that Toggle Processes and explains how we use thePersonal Information we hold on prospective, current, or former customers, and the rights you may havein relation to that Personal Information.
However, this Policy is subordinate to any specific terms and conditions set forth in any Terms of Use,end user license agreements, or other agreements you may have with Toggle relating to a particularproduct, service, or data. Please visit this website from time to time, as we may update it to reflectchanges in the law or our data practices. Further, this Policy applies only to information Toggle Processes.It does not apply to information collected by Toggle’s business partners, which may have their ownprivacy policies that apply to you.
We take your privacy seriously. This notice:
Personal Information means information that identifies, relates to, describes, is reasonably capable ofbeing associated with, or could reasonably be linked, directly or indirectly, with a particular consumer orhousehold. It does not include deidentified or aggregate information, or public information lawfullyavailable from governmental records.
It is routine for us to collect, process and store Personal Information about you over the course of yourinteractions with us.In the past 12 months, we have not sold your Personal Information to any other entity. We do not sellPersonal Information to third parties.
The following chart describes the categories of Personal Information we may have collected about you inthe past 12 months and, for each category, where and why we collected it, and the categories of entitieswith which we may have shared the Personal Information, if at all.
| Category of Personal Information (PI) | Sources of Personal | Purpose of Collection | Categories of Entities with Which Personal Information was Shared |
|---|---|---|---|
| Address and other identifiers such as name, postal address, email address, account name, Social Security and/or Employer Identification number, driver’s license number, MC Number, VIN Number, passport number, or other similar identifiers | • Directly from you; • From your employer; • Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; • From an agent or third party acting on your behalf,such as distributor, one of our affiliated operating companies, a lead referral service, or a data provider that collected information from you directly or indirectly; • Through publicly available sources;or • From the use of our CCTV cameras, as where we have cameras on our premises,your image and movements maybe recorded. | • to contact you to discuss the services or products you receive from us; • to respond to any questions or concerns you have raised; • to deal with administrative matters such as invoicing,renewal or to audit customer transactions • to perform services on our behalf, such as customer service,processing or fulfilling orders, and processing payments • to otherwise carry out our obligations arising under our contract with you and to enforce the same; • to carry out anti-money laundering and other compliance checks and controls; • to verify your identity or for other fraud or crime prevention • to debug errors in our systems; • for marketing and advertising purposes;or • for internal research,analytics and development. | • Professional advisers,including accountancy and legal firms, in order to provide us with advice; • Service providers,including to provide and support our data management,analytics, security,and storage systems; • Our operating and other affiliated companies, for business and operational purposes; and • Transaction(merger and acquisition)partners,including to facilitate the diligence,negotiation, and completion phases of transactions contemplated buys, our parent company, or affiliated operating companies. |
| Unique electronic identifiers such as IP address, device IDs,session tokens, or other similar identifiers | • Directly from you; • From your employer; • Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; • From an agent or third party acting on your behalf,such as distributor, one of our affiliated operating companies, a lead referral service, or a data provider that collected information from you directly or indirectly; • Through publicly available sources;or • From the use of our CCTV cameras, as where we have cameras on our premises,your image and movements maybe recorded. | • to debug errors in our systems; • for marketing and advertising purposes;or • for internal research,analytics and development. | • Professional advisers as described above; • Service providers as described above; • Our operating and other affiliated companies as described above;and • Transaction partners as described above. |
| Financial information | • Directly from you; • From your employer; • Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; • From an agent or third party acting on your behalf,such as distributor, one of our affiliated operating companies, a lead referral service, or a data provider that collected information from you directly or indirectly; • Through publicly available sources. | • to respond to any questions or concerns you have raised; • to deal with administrative matters as described above; • to perform services on our behalf as described above • to otherwise carry out our obligations arising under our contract with you and to enforce the same; • to carry out anti-money laundering and other compliance checks and controls; • to verify your identity or for other fraud or crime prevention | • Professional advisers as described above; • Service providers as described above; • Our operating and other affiliated companies as described above;and • Transaction partners as described above. |
| Commercial information such as records of personal property, products or services purchased,obtained, or considered, or other purchasing or consuming histories or tendencies | • Directly from you; • From your employer; • Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; • From an agent or third party acting on your behalf,such as distributor, one of our affiliated operating companies, a lead referral service, or a data provider that collected information from you directly or indirectly; • Through publicly available sources. | • to contact you to discuss the services or products you receive from us; • to respond to any questions or concerns you have raised; • to deal with administrative matters as described above; • to perform services on our behalf as described above • to otherwise carry out our obligations arising under our contract with you and to enforce the same; • to carry out anti-money laundering and other compliance checks and controls; • to verify your identity or for other fraud or crime prevention • to debug errors in our systems; • for marketing and advertising purposes;or • for internal research,analytics and development. | • Professional advisers as described above; • Service providers as described above; • Our operating and other affiliated companies as described above;and • Transaction partners as described above. |
| Education or other professional information | • Directly from you; • From your employer; • Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; • From an agent or third party acting on your behalf,such as distributor, one of our affiliated operating companies, a lead referral service, or a data provider that collected information from you directly or indirectly; • Through publicly available sources. | • to contact you to discuss the services or products you receive from us; • to respond to any questions or concerns you have raised; • to deal with administrative matters as described above; • to perform services on our behalf as described above • to otherwise carry out our obligations arising under our contract with you and to enforce the same; • to carry out anti-money laundering and other compliance checks and controls; • to verify your identity or for other fraud or crime prevention • to debug errors in our systems; • for marketing and advertising purposes;or • for internal research,analytics and development. | • Professional advisers as described above; • Service providers as described above; • Our operating and other affiliated companies as described above;and • Transaction partners as described above. |
| Audio or video footage collected using CCTV cameras (only if you visit one of our premises that uses this technology) | • Directly from you; • From your employer; • Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; • From an agent or third party acting on your behalf,such as distributor, one of our affiliated operating companies, a lead referral service, or a data provider that collected information from you directly or indirectly; • Through publicly available sources. • From the use of our CCTV cameras, as where we have cameras on our premises,your image and movements maybe recorded. | • to deal with administrative matters as described above; • to carry out anti-money laundering and other compliance checks and controls; • to verify your identity or for other fraud or crime prevention | • Professional advisers as described above; • Service providers as described above; • Our operating and other affiliated companies as described above;and |
| Biometric information | • to respond to any questions or concerns you have raised; • to perform services on our behalf as described above • to otherwise carry out our obligations arising under our contract with you and to enforce the same; • to carry out anti-money laundering and other compliance checks and controls; • to verify your identity or for other fraud or crime prevention • to debug errors in our systems; • for internal research,analytics and development. | • to contact you to discuss the services or products you receive from us; • to respond to any questions or concerns you have raised; • to deal with administrative matters as described above; • to perform services on our behalf as described above • to otherwise carry out our obligations arising under our contract with you and to enforce the same; • to carry out anti-money laundering and other compliance checks and controls; • to verify your identity or for other fraud or crime prevention • to debug errors in our systems; • for marketing and advertising purposes;or • for internal research,analytics and development. | • Professional advisers as described above; • Service providers as described above; • Our operating and other affiliated companies as described above;and |
| Geo location and location information Information | • Directly from you; • Through the app and website • From your employer; • Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; • From an agent or third party acting on your behalf,such as distributor, one of our affiliated operating companies, a lead referral service, or a data provider that collected information from you directly or indirectly; • Through publicly available sources. • From the use of our CCTV cameras as described above. | • to contact you to discuss the services or products you receive from us; • to respond to any questions or concerns you have raised; • to deal with administrative matters as described above; • to perform services on our behalf as described above • to otherwise carry out our obligations arising under our contract with you and to enforce the same; • to carry out anti-money laundering and other compliance checks and controls; • to verify your identity or for other fraud or crime prevention • to debug errors in our systems; • for marketing and advertising purposes;or • for internal research,analytics and development. • for required location tracking – app always on location will be used to track the location of the shipment you are transporting per the requirements of your contract with Toggle.Once this feature is enabled, the app will track your location while tracking is on,even when the app is closed. | • Professional advisers as described above; • Service providers as described above; • Our operating and other affiliated companies as described above;and • Transaction(merger and acquisition)partners as described above. |
| Inferences drawn from Personal Information such as individual profiles,preferences,characteristics,behaviours | • Directly from you; • From your employer; • Through your direct or indirect use of our products or services or those of one of our affiliated operating companies; • From an agent or third party acting on your behalf,such as distributor, one of our affiliated operating companies, a lead referral service, or a data provider that collected information from you directly or indirectly; • Through publicly available sources. • From the use of our CCTV cameras, as where we have cameras on our premises,your image and movements maybe recorded. | • to contact you to discuss the services or products you receive from us; • to respond to any questions or concerns you have raised; • to deal with administrative matters as described above; • to perform services on our behalf as described above • to otherwise carry out our obligations arising under our contract with you and to enforce the same; • to carry out anti-money laundering and other compliance checks and controls; • to verify your identity or for other fraud or crime prevention • to debug errors in our systems; • for marketing and advertising purposes;or • for internal research,analytics and development. | • Professional advisers as described above; • Service providers as described above; • Our operating and other affiliated companies as described above;and • Transaction(merger and acquisition)partners as described above. |
We will continue to collect the same categories of Personal Information listed in the chart above, for thesame purposes. If this should change, we will issue an updated Privacy Notice.
To provide certain products and services, Toggle may share information with third parties who provideservices to us, such as the manufacturers, distributors, and operators of hardware and software used in ouronline dashboard and mobile application. Any third party with whom we share identifiable informationwill only have access necessary to perform specific tasks on our behalf, will only use the information forthis purpose, and will protect your information at least to the same extent that we do.
Toggle may share information to comply with our legal obligations, such as to respond to lawful requestsand legal processes. In the event we are asked to disclose your Personal Information, we will attempt tovalidate the request and inform you of it.
Finally, Toggle may disclose information where needed to affect the sale or transfer of its assets, enforceits rights, protect its property, or protect the rights, property, or safety of others, or as needed to supportexternal auditing, compliance, and corporate governance functions.
If Toggle needs to share your information for a purpose not identified here, we will obtain your consentand disclose this purpose at the time of obtaining your consent. For example, Toggle may wish to useyour information in demonstrations or other marketing materials and will contact you before doing so.
Our products and services are not directed to minors under the age of 18, and we do not knowingly collector sell the Personal Information of minors.
We implement and maintain reasonable security appropriate to the nature of the Personal Information thatwe collect, use, retain, transfer or otherwise process. Our reasonable security program is implemented andmaintained in accordance with applicable law and relevant standards as outlined in the report issued bythe California Attorney General in February 2016, available here. Specifically, among other safeguards,our reasonable security program implements and maintains all 20 of the Center for Internet Security’sCritical Security Controls for Effective Cyber Defense identified in Appendix A of the CaliforniaAttorney General Report. As noted in that report, “there is no perfect security,” and reasonable security isa process that involves risk management rather than risk elimination.
We are committed to developing, implementing, maintaining, monitoring and updating a reasonableinformation security program, but no such program can be perfect. In other words, all risk cannotreasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminalexploits, or other factors that cannot reasonably be prevented. Accordingly, while our reasonable securityprogram is designed to manage data security risks and thus help prevent data security incidents andbreaches, it cannot be assumed that the occurrence of any given incident or breach results from a failureon our part to implement and maintain reasonable security.
We keep different kinds of information for different lengths of time, depending on the purpose for whichit was processed and your specific situation. Thus, we will retain information as long as necessary toaccomplish the relevant purpose, but no longer.
No, we do not respond to browser or do not track signals.
You can do so by using the contact details set out at the end of this Privacy Notice.
Residents of certain states may have the following additional privacy rights.
YOUR RIGHT TO REQUEST Disclosure OF INFORMATION WE COLLECT AND SHARE ABOUT YOU
We are committed to ensuring that you know what information we collect about you. You can submit request to us for the following information, with respect to Personal Information we have collected:
We are also committed to ensuring that you know what information we share about you. You can submit arequest to us for the following further information:
The categories of Personal Information that we have shared with service providers who provide servicesto us.
Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.
Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.
YOUR RIGHT TO REQUEST THE DELETION OF PERSONAL INFORMATION WE HAVECOLLECTED FROM YOU
Upon your request, we will delete the Personal Information we have collected about you, except forsituations where specific information is necessary for us to: provide you with a good or service that yourequested; perform a contract we entered into with you; maintain the functionality or security of oursystems; or comply with or exercise rights provided by the law. The law also permits us to retain specificinformation for our exclusively internal use, but only in ways that are compatible with the context inwhich you provided the information to us or that are reasonably aligned with your expectations based onyour relationship with us.
WE ARE COMMITTED TO HONORING YOUR RIGHTS
We are committed to providing Consumers control over their Personal Information. If you exercise any ofthe rights explained in this Privacy Notice, we will continue to treat you fairly. In particular, this meansthat Consumers who exercise their rights under this Notice will not be denied or charged different pricesor rates for goods or services or provided a different level or quality of goods or services than otherConsumers.
CALIFORNIA “SHINE THE LIGHT” CIVIL CODE SECTION 1798.83
No information is shared with third parties for their own marketing purposes.
If you have provided your Personal Information to Toggle when communicating or transacting with us onbehalf of your employer or another business, you can always contact us at the details set forth below. Wedo not sell your Personal Information to third parties.
If you exercise any of your privacy rights as an individual who does business with us on behalf of youremployer or contractor, Toggle will not discriminate against you for doing so and will continue to treatyou fairly in our subsequent interactions with you.
To exercise any of the rights above, please contact us, by postal mail at:
Legal Department
2323 Grand Ave, Suite 215
Des Moines, Iowa 50312
USA
by calling from within the United States: (515) 954-2525
We cannot respond to your request or provide you with personal information if we cannot verify youridentity or authority to make the request and confirm the personal information relates to you. Making averifiable consumer request does not require you to create an account with us. We will only use personalinformation provided in a verifiable consumer request to verify the requestor’s identity or authority tomake the request