Terms of service
SVR Tracking Inc. (“SVR Tracking”) is committed to protect the privacy of our customers. This Privacy
Policy relates to SVR Tracking, together with its affiliate Positioning Universal Holdings Inc., (collectively
“we”, “us” and/ or “our”), and describes our policies and practices with respect to your personally
identifiable information (“Personal Information”) and other data that you may give us or that we may
collect about you when using our website: www.svrtracking.com and our services (“Sites and Services”). It
also describes the choices available to you regarding our use of your Personal Information and how you
can access and update this information. The use of information collected through our service shall be
limited to the purpose of providing the service for which the customer has engaged SVR Tracking.
Our servers are located in the United States. Accordingly, if you reside outside of the United States or are
a European Union citizen living in the United States, you agree that your information will be transferred to
the United States and processed and stored in the United States in accordance with the EU-U.S. Data
Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF. You also acknowledge
and agree that your information may be transferred to facilities of those third parties with whom we share
data as described herein.
Information Collection, Purpose, Use, Disclosure, and Sharing
We collect, use and share two (2) types of information: Personal Information and Non-Personal
Information. Personal Information is information that can be directly or indirectly associated with a specific
person or entity, including but not limited to, names, email addresses, usernames, passwords, and
payment information. Non-Personal Information is information we collect or compile that by itself cannot
be directly associated with a specific person or entity.
During the use of our Sites and Services, we collect and process information for the following purposes:
• Improving our websites and their user experience by analyzing their use;
• Diagnosing problems in our websites and providing notifications of issues and corrective actions;
• Communicating with you on contractual information (date established and when it is ready to
expire), credit card payment information (ready to expire or expired credit card) and similar
information or to communicate and respond to your requests, including customer support;
• Processing and fulfilling orders requested by resellers and customers;
• Providing information on SVR Tracking’s products and services, special offers & promotions,
existing and pending regulations, and similar information;
• Conducting market research about our customers, their interests, and the effectiveness of our
campaigns;
• Completing cybersecurity activities, including fraud prevention, software and IP privacy, misuse of
services, and protecting the confidentiality of your account;
• Tracking of vehicles to aid in the recovery if a vehicle is stolen, abandoned or for general
recovery purposes;
• Tracking of vehicles or assets for security, fleet optimization and automotive dealer lot
management;
• Tracking of mileage for vehicle routine maintenance;
• Tracking of vehicles to improve driver safety (i.e., speed alerts and late driving);
• Management reporting for business optimization;
• Integration with third party hardware or software solutions;
• Analyzing, troubleshooting, protecting, improving, and further developing our SVR Tracking’s products
and services;
• As may be required by applicable law; and
• Other purposes to which you consent.
When accessing one of our websites, our system will gather information such as what kind of browser is
being used, the user’s operating system, their IP address, their navigation patterns, and referring site.
Note that information is only gathered while the user is on a website owned or operated by SVR
Tracking. SVR Tracking monitors how a user arrives at the website, but cannot, and will not, gather
information about other websites the user has been on before arriving at a website owned or operated
by SVR Tracking.
When you register with SVR Tracking, information is needed such as your name, company name, and
email address. A billing address and credit card information is also required if you have chosen a paid
account. We will use collected information for purposes such as processing and fulfilling your order,
billing, service improvement, research, and other general purposes. We will share your Personal
Information with third parties only in the ways that are required for the use of our service and as described
in this Privacy Policy. We will not sell, rent, exchange or share your Personal Information with any third
parties without permission.
SVR Tracking will use your Personal Information to send a welcome email. We may also email account
holders for the purpose of billing or to provide service-related announcements. As this is part of your
service, you cannot opt out of any service-related email notifications. At any point in which a newsletter
subscription is made available, we will use your name and email address to send the newsletter to you. At
any time, you may choose to stop receiving our newsletters or other promotional emails by following the
instructions provided in the email or through our website using the Contact Us form.
If you use a mobile device connected to a SVR Tracking solution, we receive and process Personal
Information about you which may include, but is not limited to, the monitoring of your driving behavior,
hours driven and location. We process this data in accordance with this Privacy Policy.
If SVR Tracking is involved in a merger, acquisition, bankruptcy, or sale of all or a portion of its assets,
you will be notified via email or by notice on our website of any change in ownership or uses of your
Personal Information, as well as any choices you may have regarding your Personal Information.
When necessary, SVR Tracking will share the collected information in order to respond to lawful requests
by public authorities, including to meet national security or law enforcement requirements, court orders,
legal processes, or to investigate, prevent or take action against illegal activities, suspected fraud, or other
circumstances concerning potential physical threats of personal safety, violations of SVR Tracking’s terms
of service, or as otherwise required by law.
Cookies
SVR Tracking uses a technology called "cookies" to store session information. A cookie is a small text file
that is stored on your local computer and allows us to identify users who have previously registered or
visited the site. Session cookies are automatically deleted from your hard drive at the end of a session. If
you access the portions of our website that require a password, persistent cookies, which are not
automatically deleted from your hard drive at the end of a session, are used. Most web-browsers offer the
option to refuse any cookie, but they also usually accept cookies by default. You can change this default
in most browsers and cause the browser to stop accepting cookies or to prompt you before accepting a
cookie from a website. If you choose to decline cookies, you may not be able to fully experience the
functionality for our website or services. Please note, there is no accepted standard on how to respond to
Do Not Track signals, and we do not respond to such signals.
Security
In order to protect both the Personal Information and the general information that we receive from you
through your use of SVR Tracking’s website, we have taken measures to ensure your security. When you
enter sensitive information (such as your credit card number) on our online forms, we encrypt that
information using secure socket layer technology (SSL). You can verify this by looking for a lock icon in
the address bar and looking for "https" at the beginning of the address of the web page. We also follow
generally accepted industry standards to protect the Personal Information submitted to us, both during
transmission and once we receive it. While every precaution is used to protect your Personal Information
and privacy, SVR Tracking cannot guarantee the security of any information you disclose online. By using
SVR Tracking’s service, you expressly acknowledge and agree that we do not guarantee the security of
any data provided to or received by us through your use of SVR Tracking’s service, and that any
information or other data received from you through your use of our service is provided to us at your own
risk.
While we use encryption to protect sensitive information transmitted online, we also protect your
information offline. Only employees who need the information to perform a specific job (for example, billing
or customer service) are granted access to Personal Information. The computers/ servers in which we
store Personal Information are kept in a secure environment.
Service by Minors
SVR Tracking’s service is a general audience service, and does not direct any of its content, products, or
services specifically toward children less than thirteen (13) years of age. We understand and are
committed to respecting the sensitive nature of children's privacy online. If we learn or have reason to
suspect that a user of SVR Tracking’s service is under age thirteen (13), we will promptly delete any
Personal Information in that user's account. If you have such information, please contact us as
admin@svrtracking.com.
SVR Tracking’s service is intended for use by individuals who are at least eighteen (18) years old; or, in
the case where your state or province has an age requirement greater than eighteen (18) years of age,
the stipulated minimum age per your state or province; or, whose parent or guardian have provided
consent to use SVR Tracking’s service. Any Personal Information submitted by a minor is in violation of
our website terms of use. Personal Information provided by a minor and collected while visiting this
website may be used as indicated in this Privacy Policy. SVR Tracking is committed to protecting the
privacy of children and has no intention of collecting Personal Information from minors. We encourage
parents and guardians of minors to regularly check and monitor their children's use of email and other
activities online.
Third Party Relationships
Due to the nature of our business, we work with a variety of third-party partners that may process and store
your Personal Information on our behalf. These third-party partners are service providers and vendors that
we have selected to provide us with services, and process some Personal Information on our behalf, to
operate our Services (e.g., payment processing, customer service software solutions, IT and related
services, telecommunication and text providers, location & map services, motion detection, order
fulfillment, electronic signature solutions and resellers of our services, etc.).
We share Personal Information with third-party partners with your express, affirmative consent. For
example, you may give us permission to share Personal Information with others for marketing use,
authorize a third-party web client or application to access your account, or ask us to share your feedback
with a business. These third-party partners are contractually obligated to safeguard any Personal
Information they receive from us. This includes restricting them from using or sharing Personal Information
except as necessary to perform the contracted services on our behalf or to comply with applicable legal
requirements.
The use of your Personal Information by our third-party partners is governed by the privacy policies of
those third-party partners, and is not subject to our control. SVR Tracking does not assume or have any
responsibility or liability for the Personal Information collection, use, security practices, or storage activities
of the third-party partners used by SVR Tracking to provide you with our Services.
In the context of an onward transfer SVR has responsibility for the processing of Personal Information it
receives under the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) and under the
UK Extension to the EU-U.S. DPF Principles,and subsequently transfers to a third party acting as an agent
on its behalf. Any transfers will be in compliance with applicable law. SVR Tracking shall remain liable
under the Principles if its agent processes such Personal Information in a manner inconsistent with the
Principles, unless we prove that we are not responsible for the event giving rise to the damage.
Additionally, we de-identify and aggregate your Personal Information to Non-Personal Information, to share
it with partners and the public in a variety of ways, such as by providing research reports about GPS or
vehicle usage. When we provide this Non-Personal Information, we perform appropriate procedures so that
the information does not identify you and we contractually prohibit recipients of the information from trying
to re-identify you.
Third-Party Links
SVR Tracking may insert links to third-party websites whose privacy practices may differ from those of
SVR Tracking. This Privacy Policy does not apply to such third-party websites. These links take you
outside our service and are beyond our control. This includes links from customers or partners that may
use SVR Tracking’s logo as part of a co-branding agreement. While we seek to protect the integrity of our
service, SVR Tracking is not liable for the content and activities of those sites. Your access to such
websites is at your own risk. Please note that those other sites may send their own cookies to users,
collect data, or solicit Personal Information.
Changes to Privacy Policy
We reserve the right to edit SVR Tracking’s Privacy Policy at any time and without prior notice to you
to reflect changes in our information practices or relevant laws. We will post a notice on our website
that points to this Privacy Policy to notify you of any substantive changes to the way we collect and
use information. The most recent version of the Privacy Policy is reflected by the version date located
at the top of the Privacy Policy. We strongly encourage you to read our Privacy Policy and regularly
check for any changes.
If you continue to use our Site and/ or Services, you agree to be bound by any changes to this Privacy
Policy. If you do not agree to these changes, please contact us so we can attempt to resolve your concern
by providing an explanation of these changes. If this information is not acceptable to you, then your only
remedy is to discontinue use of the Site and/ or our Services.
Questions
You can reach us using the information found on our “Contact Us” page on our website, by contacting
our Data Protection Officer via the email listed in the “Data Privacy Regulations” section of this
Privacy Policy or by using the mailing address provided at the end of this Privacy Policy. We will
respond to your request to within thirty (30) days.
Data Privacy Regulations
The European Union’s General Data Protection Regulation (GDPR) and other emerging data privacy
regulations, such as the UK’s Data Protection Act and implementing regulations, provide data subjects
that are users of our Site and Services with the following rights, described below. This section applies to
EU and UK data subjects.
Right to Access
You have the right to request access to and/ or copies of the Personal Information SVR Tracking holds on
you. In order to ensure the safety of your data, SVR Tracking will request identity verification of any data
subject requesting access to Personal Information. As a result, the email must specify the following
information:
1) Name, company, business address, and scope of information requested; and
2) Identification documents to demonstrate that the user is an employee of the named company.
SVR Tracking will comply with the request within thirty (30) days of the request receipt; provided, the
required verification document has been received.
Right to Rectification
You have the right to have your data corrected in the event any Personal Data held by SVR Tracking is
incorrect or incomplete.
Right to Erasure
You have the right to be forgotten or have your Personal Information erased. We will remove your
Personal Information from our systems, after receiving written notification from you, once the retention is
no longer necessary for the performance of services based on a contractual commitment or if there is not
an existing need to retain this information for the establishment, exercise, or defense of any legal claims.
Right to Restriction of Processing or Transfer to another Data Controller
You have the right to restrict the processing of your Personal Information. You also have the right to
transfer or port your Personal Information from SVR Tracking to another data controller. After Service
cancellation, data will not be retained on our servers if requested in writing via email. SVR Tracking will
abide by this right as long as the data transfer does not infringe on the contractual rights of a customer.
Right to Object
You have the right to object to the use of your Personal Information. This includes the right to withdraw
consent to process Personal Information if consent was previously given and the right to object to the
use of Personal Information. This could include the removal of your Personal Information from an
account or a request to remove your email from a mailing list.
Exercising Rights
In the event you would like to inquire about exercising these rights, you may contact our Privacy/ Data
Protection Officer at dataprotection@svrtracking.com.
It should be noted that if you choose to withdraw consent, restrict the processing of your Personal
Information, or have your Personal Information erased prior to the contractual end of an existing Service
agreement, this may result in SVR Tracking discontinuing your use of the Site and / or Service.
Your information will be retained for as long as your account is active, needed to provide you with our
services and in adherence to the data privacy rights outlined within this “Data Privacy Regulations”
section. We will retain and use your information as necessary to comply with our legal obligations, resolve
disputes, and enforce our agreements.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, SVR Tracking INC.
commits to refer unresolved complaints concerning our handling of personal data received in reliance on
the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to JAMS Data Privacy Framework (DPF)
Dispute Resolution an alternative dispute resolution provider based in the United States, the European
Union, and the United Kingdom. If you do not receive timely acknowledgment of your DPF Principles
related complaint from us, or if we have not addressed your DPF Principles-related complaint to your
satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file
a complaint. The services of JAMS Data Privacy Framework (DPF) Dispute Resolution are provided at no
cost to you.
Breach Protocol
In the case of a data breach, SVR Tracking will notify affected users within seventy-two (72) hours of
SVR Tracking becoming aware of the breach. The notification will include the nature of the breach,
measures to be taken to correct the breach and the primary point of contact for inquires at SVR
Tracking.
Data Retention
SVR Tracking will retain Personal Information for only as long as needed to fulfill the purposes for which
the data was provided and to meet any contractual or legal requirements. SVR Tracking will delete or
anonymize Personal Information when there is no longer a legitimate business need for it. If it is not
immediately possible to delete Personal Information because, for example, it has been backed up in
archives by third party partners, then SVR Tracking will work with its third-party partners to securely store
the Personal Information and isolate it from further processing until deletion is possible.
Amazon Web Services (AWS)
SVR Tracking has partnered with AWS to process and store all data for our Services in the United States.
AWS has in place effective technical and organizational measures to secure Personal Information in
accordance with GDPR. AWS also participates in the EU-US Data Privacy Framework, and the UK
Extension to the EU-US Data Privacy Framework.
Cross-Border Data Transfers
Any Personal Information (including Personal Information) that we collect may be transferred, accessed,
and processed outside of your country, as we and our service providers process data in the United States.
If you are located in the EEA, the UK, Canada, or other regions with laws governing the processing of
Personal Information that may differ from U.S. law, please note that your Personal Information may be
transferred to countries that do not have the same data protection laws as the country in which you initially
provided the information. We comply with applicable legal requirements providing adequate safeguards
for the transfer of Personal Information to countries other than the country where you are located. In
particular, we may transfer Personal Information to countries for which adequacy decisions have been
issued by the European Commission, the Secretary of State in the UK or other relevant bodies in other
jurisdictions, or use contractual protections for the transfer of Personal Information to third parties, such as
the European Commission’s Standard Contractual Clauses. You may contact us to obtain a copy of the
safeguards we use to transfer Personal Information outside the EEA or the UK.
EU-U.S. Data Privacy Framework (EU-U.S. DPF)
SVR Tracking maintains its self-certification status under both the EU-U.S. Data Privacy Framework
(EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF. These frameworks were specifically
designed to facilitate companies in complying with data protection requirements when transferring
personal data from Europe to the United States. For additional information on the Data Privacy
Framework program and to view our certification, please visit https://www.dataprivacyframework.gov.
In relation to the collection, utilization, and retention of personal data transferred from the European Union,
the United Kingdom, SVR Tracking adheres to the EU-U.S. Data Privacy Framework and the UK
Extension to the EU-U.S. DPF, as outlined by the U.S. Department of Commerce. SVR Tracking has
certified to the U.S. Department of Commerce its adherence to the EU-U.S. Data Privacy Framework
Principles (EU-U.S. DPF Principles) concerning the processing of personal data received from the
European Union under the EU-U.S. DPF and from the United Kingdom under the UK Extension to the EU
U.S. DPF. In the event of any conflict between the terms in this privacy policy and the EU-U.S. DPF
Principles, the Principles shall take precedence. To learn more about the Data Privacy Framework (DPF)
program and to view our certification, please visit https://www.dataprivacyframework.gov/.
In alignment with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU
U.S. DPF, SVR Tracking is committed to resolving complaints related to the collection or use of personal
information transferred to the U.S. under the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.
Individuals from the EU and UK with inquiries or complaints are encouraged to contact SVR Tracking at
privacy@svrtracking.com or using the contact details provided in the "Contact Us" section of this privacy
policy.
We commit to resolve DPF Principles-related complaints about our collection and use of your personal
data. EU and UK individuals with inquiries or complaints regarding our handling of personal data
received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact
us via our “Contact Us”. You have an option to invoke binding arbitration by delivering notice to us and
following the procedures and subject to conditions set forth in Annex I of the Data Privacy Framework
Principles.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
If you feel that we are not abiding by this Privacy Policy, you should contact us immediately.