OneRail

Privacy Notice

On Demand Technologies, Inc. incorporated in Florida whose registered address is at 8427 Southpark Cir, Orlando, FL 32819 is the controller and responsible for your personal data (“ODTI”, “OneRail”, “Our”, “We” or “Us”) Places the utmost importance on protecting your privacy. We believe that you have a right to know our practices regarding the information we may collect and use when visiting our websites (https://www.onerail.io, https://www.onerail.com, or https://www.GetOneRail.com) and any subdomains owned by OneRail.

This privacy notice explains what types of information are collected by our websites and how this information is used.

IMPORTANT INFOMRATION

Privacy Acknowledgement

BY INTERACTING WITH OUR WEBSITE—INCLUDING ENTERING, CONNECTING TO, ACCESSING, OR UTILIZING ANY INFORMATION CONTAINED WITHIN—your use of the website constitutes your explicit consent to the collection, use, disclosure, retention, and disposal of your personal information as outlined in this notice.

We ensure that:

  • Your consent is freely given, specific, informed, and
  • You are aware that you may withdraw your consent at any time, with the understanding that this will not affect the lawfulness of processing based on consent before its
  • The process to withdraw consent is as easy as the process to give
  • Where we rely on your consent to process personal data, we will always request it via a clear affirmative act, such as the ticking of a box, or another statement or conduct which clearly indicates in this context your acceptance of the proposed processing of your personal data.

Third-Party Links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:’
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
  • Technical Data from analytics providers such as Google based outside the UK.

 

HOW WE USE YOUR DATA

IP Addresses and Technical Data

We collect IP addresses and technical data such as browser type and operating system for troubleshooting, website administration, and to gather broad demographic information. This data helps us ensure the compatibility of our website with user platforms and to understand our user base more completely.

SMS Delivery Updates and Driver Notifications

When you opt-in to receive SMS delivery updates or driver notifications from OneRail acting as a data controller or data processor, we collect and process certain personal information to enhance your experience. This section explains how we handle that information.

SMS Information We Collect

When you opt-in to receive SMS delivery updates or driver notifications, we may collect and process the following categories of personal information:

  • For End Users: Identity Data, Contact Data, Transaction Data
  • For Drivers: Identity Data, Contact Data, Transaction Data

SMS Data Retention

We retain personal information collected for SMS delivery updates and driver notifications only for as long as necessary to fulfill the purposes outlined above, or as required by law.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

SMS Data Security

We have implemented appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, and unlawful destruction or alteration.

SMS Data Sharing

We may share personal information collected for SMS delivery updates and driver notifications with trusted third-party service providers who assist us in delivering these messages and managing our delivery operations.

Your Rights regarding SMS

As an individual receiving SMS delivery updates or driver notifications, you have the following rights:

  • The right to access and update your personal
  • The right to request the deletion of your personal
  • The right to opt-out of receiving SMS delivery updates or driver notifications at any

Cookies and Automated Technologies

Cookies and similar technologies are used to enhance user experience, for performance analytics, and for targeted advertising. Specific uses include:

  • Personalizing user experience based on past
  • Analyzing website traffic and usage
  • Managing advertisements displayed to the
  • Users have the ability to control the use of cookies at the individual browser

Disabling cookies may limit the use of certain features or functions on our website.

Marketing Communications

We process personal data for marketing purposes based on your consent or our legitimate interests. You will receive marketing communications from us if you have:

  • You’ve requested information from
  • You’ve purchased our products or
  • You’ve provided details during events, conferences, or trade
  • You’ve registered for events, competitions, or
  • You have not opted out of receiving

Third-Party Marketing

We will obtain your express opt-in consent before sharing your personal data with any external company for marketing purposes.

Opting Out

You can ask us or third parties to stop sending marketing messages at any time by following opt-out links in marketing messages or by contacting us at privacy@onerail.io.

International Data Transfers

Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) in our servers located in the United States. We ensure these transfers are compliant with GDPR, utilizing standard data protection clauses.

Legal Basis for Processing

We process personal data based on contractual necessity (Article 6(1)(b) GDPR), enabling us to fulfill our service commitments.

We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer or supplier and provide updates on services (a) Identity

(b) Contact

Performance of a contract with you
To process payments including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Data Breach Notification

In case of a data breach, we will notify the relevant data controller and the appropriate regulatory authorities, complying with GDPR requirements.

Children’s Privacy

Our services are not intended for individuals under the age of 18.

Data Protection Officer

A Data Protection Officer has been appointed and is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this notice or our privacy policy, including any requests to exercise your legal rights, please contact the DPO at dpo@onerail.io.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Data Subject Rights

You have the right to:

  • Access: Obtain a copy of your personal data we
  • Correction: Have any inaccurate data we hold about you
  • Erasure: Have your personal data erased when it is no longer necessary for us to keep
  • Object: Object to the processing of your personal data where we rely on a legitimate interest and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Restriction: Request the suspension of the processing of your personal data in certain scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Portability: Have your personal data transferred to another organization or to you in a structured, commonly used, and machine-readable format.
  • Withdraw Consent: Withdraw your consent at any time where consent is the legal basis for processing your If you wish to exercise any of these rights, please contact us at privacy@onerail.io.

No fee required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Record Keeping

We maintain detailed records of our data processing activities, demonstrating compliance with GDPR.

Data Protection and Privacy Training and Awareness

OneRail provide comprehensive data protection and privacy training to all our employees, ensuring they are fully aware of their responsibilities and the best practices for handling personal data.

Our training program covers:

  • An overview of the GDPR and other applicable data protection
  • The importance of data privacy and the impact of data
  • The rights of data subjects and how to uphold these rights within our
  • Specific processes for the collection, processing, storage, and sharing of personal
  • How to recognize and report data protection issues or potential
  • Regular updates on new developments in data protection

This approach to training ensures that every member of our team is equipped to contribute to the protection of personal information, building a culture of privacy that permeates our entire organization.

Privacy Notice Updates, Modifications and your duty to inform us of changes

We may update this privacy notice and our privacy policies from time to time in response to legal, technical, or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Personal and Sensitive User Data

Location data is collected and used by our mobile application – OneRail Driver – to determine the exact location of “on-duty” or active working users. This background service is intended to provide insight to dispatchers (the person who assigns deliveries) to determine which drivers are best suited for the delivery based on qualifications such as location and historic performance. Location pings are automatically provided to dispatchers to streamline operations as drivers actively move from one location to the next. Location data is paired with timestamps and stored in reporting to optimize future decisions (met SLA, traffic, weather, delivery exceptions) and increase driver accountability.

Updated: January 2024

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