In a nutshell:
Now in more detail:
Surfsight is a technology platform and service owned and operated by us, Surf Communication Solutions Ltd. (and our subsidiary Surf Communication Solutions Inc.). You can find our contact details below.
Surfsight helps organizations to protect their staff and vehicles on the road, and to protect their legal interests in claims and disputes. These organizations are our Customers.
Surfsight is a cloud Platform, connected to Dash Camera Devices (which the Customer buys, owns, installs, and operates), and accessible to Customers and their permitted Users through a dedicated Web Portal.
As soon as they’re turned on upon the vehicle’s ignition, Devices record Videos and collect various Location Data and Driving Data, which might include personal information or personally identifiable information of the vehicle’s Drivers, Passengers, or Other People, as explained in detail below.
Our Customers decide the purposes for which they use Surfsight, as well as the means for collecting data from Surfsight’s magnitude of features. Our Customers control the data processed on their behalf on Surfsight and they are responsible under our Terms of Service for handling any data rights and data requests of their employees and contractors, Users, Drivers, Passengers, and Other People as Data Controllers. We also use the data collected on Surfsight for product improvement and commercial uses, as described in detail below, and therefore assume Joint Controller responsibility with respect to such data. Our responsibilities as Joint Controllers are mostly towards our Customers and detailed in the Joint Controllers Arrangement in our Terms of Service.
To make things clear with an example: if you’re an employee of CorpCo and got a CorpCo company car that has a Surfsight Device installed in it, then you are a Driver, CorpCo is our Customer and has full control over your personal data, and we process your personal data on CorpCo’s behalf and according to its instructions. If CorpCo gave you access to the Surfsight Portal, you’re also a User, and you can access the Platform to view videos, get statistics, and take some actions, all according to your permissions as defined by CorpCo.
If you’re a User, Driver, or Passenger and have any issue regarding your personal information, please contact your employer first! Our Customer’s contact details appear on or around the Device, in the Portal, and in communications you receive from Surfsight.
In addition, we also operate several Websites – such as Surfsight.net – and collect personal data of Visitors. Some Visitors and other people who communicate with us, become our business Contacts or Customers. We collect and process various personal information regarding our Visitors, Contacts, and Customers, and we are the Data Controllers for such personal data.
If you are a Visitor, Contact or Customer of ours and have any issue regarding your personal information that we control, please contact us (details below).
If you’re a Contact or Customer of ours, there might be several ways in which we receive your personal data:
If you’re a Surfsight User or Driver, there are two ways in which we receive personal data about you that we process on behalf of our Customer:
You can usually shut down the Device or unplug it from electricity to stop its operation and collection of information. However, your handling of the Customer’s Devices and vehicles is subject to your relationship with your employer, our Customer. If Surfsight does not receive data from the Device, it might not function properly. The data provided by Surfsight to our Customer who controls your account might be incomplete or inaccurate, and that might affect your relationship, work or compensation. Please consult with your employer regarding the potential effect of disabling or tampering with the Device and its operations.
If you’re a Passenger or another person unrelated to the Customer (Other People), Surfsight might still process some personal data about you. Such data is received from the Customer’s Device assigned to the Driver that picked your video footage, location information, or other visible or inferred personally identifiable information, inside the Customer’s vehicle or around it. If you have any question or request regarding your data on Surfsight, please approach first the Driver whose vehicle you’ve ridden, or our Customer, the Driver’s employer.
Surfsight makes no attempt whatsoever to personally identify Drivers, Passengers, or Other People, who appear on Customer’s videos processed on the Platform.
If you’re a Visitor to our Websites or a User using Surfsight, we might receive some personal data through your device, operating system, and browser, and various hosting, tracking, analytics and advertising technologies used on our Websites, such as cookies (see below), Amazon Web Services, WordPress and WordPress plugins, Analytics and Advertising technologies by Google and others, Customer support services by Freshdesk, Social Login APIs by Google, Facebook, Twitter and others, and other technologies. Our Websites do not currently respond to “Do Not Track” signals sent by your browser or device.
If you’re a Contact or Customer of ours, or a Surfsight User, we may collect and process these types of personal data about you:
On Surfsight, we process mostly data from and about Devices, not people. However, in the process of collecting such information, various types of personally identifiable information are also collected. Our Customers decide what data to collect from Devices, whether and to which extent to associate Devices with specific people in their organization, and what personal information of Users and Drivers to store on the Platform.
These are the types of personally identifiable information and other personal data about Drivers, Passengers, and Other People that we may process on Customers’ behalf, or occasionally through collection of Device videos and data:
We also collect and process these types of personal data about anyone using the Devices, Surfsight Platform, Portal, or Websites:
Surfsight is a technology platform for driving safety and documentation, and is not intended for children. We do not knowingly collect or process information about children, although Passengers and Other People who are children might be captured on Customer videos coincidentally. Surfsight makes no attempt whatsoever to personally identify Children, Passengers, or Other People, who appear on Customer’s videos processed on the Platform.
Occasionally, parents use Surfsight to keep track and sight of their children’s driving, location, and conduct in their cars. Such children usually have a driving license and are older than 16 years old. Even in such cases, Surfsight is intended to be used with significant parental involvement and approval, and with the children/Drivers’ awareness.
Please contact our Customer or the Driver if you have any concern with respect to Children’s personal data on Devices. Please contact us (contact details below) if you have any concern with respect to Children’s personal data on the Platform.
The purposes for the processing of personal data on Surfsight are determined by our Customers. Each Customer might use Surfsight for different purposes. Such purposes might include encouraging and monitoring driving safety; protecting Customer assets, such as their vehicles; protecting the Customers, staff, and third parties in case of accidents, legal proceedings, and insurance claims; tracking vehicles and fleet management; determining or corroborating the circumstances of a lawsuit, claim, loss or theft; preventing and detecting fraud; supervising professional drivers; route planning; traffic measurement and documentation; and more.
If you’re a Driver, we collect and use your personal data to provide our services to our Customers, according to their instructions and settings, so they can achieve their respective purposes. Surfsight may use your Device and contact details, according to Customer’s instructions and settings on the Portal, to communicate with you and to provide you with support and handle requests and complaints. Such interactions are performed on Customers’ request, and based on the Customer’s settings, or on your own requests or based on your settings in the Device and Portal (if you’re also a User).
Our purpose in processing personal data on Surfsight is to provide our services to the Customers according to our agreements with them and applicable law. We also use of the data collected on Surfsight to ensure our products and services are working as intended; to analyze, measure and understand how our services are used; to improve our products and services; to develop new features, products, and services; to protect our company, staff, Customers and Users, as well as Drivers, Passengers, and the general public; and to comply with any applicable law and assist law enforcement agencies under any applicable law.
We may also use anonymous, statistical or aggregated information collected on the Platform, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to customers, vendors, partners and any other third party. For example, GPS information that we receive from your Device may be provided to municipalities in an aggregated and/or anonymous form to help improve road safety and solve traffic problems.
We also process usage and analytics information, as well as some statistical and aggregate data derived from personal data, for the improvement and further development of Surfsight, Platform, App, Devices, and the Portal, or for research purposes.
Websites, Customers, Contacts and Visitors
If you’re a Customer, Contact, or Visitor on our Websites, we may process your personal data for our own business purposes, including:
As Data Controllers, our Customers usually process personal data on Surfsight (and we process such data as data processor on behalf of our Customers and according to their instructions) based on any or some of the following legal bases:
As Data Processors and Joint Data Controllers for certain data, we process personal data on Surfsight based on the legal bases above, and also any or some of the following legal bases:
Websites, Customers, Contacts, and Visitors
As Data Controllers for our Customers, Contacts and Visitors’ personal data, we process personal data based on any or some of the following legal bases:
Our services sometime enable our Customers, their Users, or you, to share information, including personal data, based on your consent or other legal bases, as referenced above. Our Customers, Users, or you, decide about the sharing of videos and other data on the Platform, the identity of the recipients, and the distribution of the information. For example, the Customer may use the Platform to transfer Videos or Driving Data captured on its Devices to employees within the organization, insurance companies, law firms, law enforcement agencies, government or municipal authorities, etc.
This section deals with information we share about you with others.
For the delivery of our services, we share all User, Device, and Platform data on Surfsight (inc. identifiable information of Drivers, Passengers and Other People) with the Customer who is the Data Controller with respect to such data. This means that your employer has access and control over all the information we collect about you. We also share Customer’s representatives contact details to all the Customer’s Users and others who might need such details, to comply with any applicable law. Our Customers may select to share the information with some of their staff and other organizations and bodies, as mentioned above.
Customers, Contacts, and Visitors
We process your details on our servers and computers, cloud CRM services, support systems and services (such as Freshdesk), billing systems (such as Priority), SMS gateways, Email and SMS communication services (such as Twilio and MailChimp), and backup systems. We may share some of your details with our staff, consultants, resellers, affiliates, and other third-party business partners for research and analysis, cooperation opportunities, joint promotions, sales, and events.
We use additional processors around the world for various processing activities needed for the performance of Surfsight, our Websites, our other products and services, our operations, and our business, and share information with such processors on a need basis. Such processors include hosting and backup providers (such as Amazon Web Services), analytics providers (such as Google and Heap), website technology (such as WordPress and WordPress plugins), advertising technology (such as Google), telecommunication services, media transmission services (such as Velia.net), security technology, and more. We limit the information we share with each processor based on the business need in using such processor, to protect your information while still effectively benefiting from the services of such processor.
We may also share non-personally identifiable information and aggregate information for any purpose. Such data is not personal data, and its sharing cannot be used to identify you.
We may need to share your information with law enforcement agencies, courts of law, and other governmental organizations, if ordered to do so by competent bodies and according to applicable law.
Mergers and Acquisitions
If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your information with that company and its advisors before and after the transaction date.
We take information security very seriously. We implement the state of the art security standards to prevent unauthorized or excessive access, maintain data accuracy, and ensure the correct use of information. We encrypt all major data communication transmissions to avoid interception and securely backup the information on the Platform to avoidance data loss. We also implement appropriate organizational measures to protect your information.
We apply our security standards also when working with business and technology partners. We only select and contract with processors and third parties who use appropriate security measures and provide sufficient guarantees, including technical and organizational measures, to ensure the appropriate protection of the data we entrust with them. Unfortunately, although we make every effort to keep your data safe, we cannot fully ensure or warrant the security of your personal information.
You can take part in securing your personal data. Always lock the vehicle where the Customer’s Device is installed. If you’re a User, prevent unauthorized access to your Surfsight account and personal information by selecting a strong password and protecting your login credentials appropriately. Limit access to your computer and mobile device. If you’re using the Portal, sign off when you finish accessing your account.
Most of our information is stored over the cloud on Amazon Web Services in the U.S. and Europe. Amazon takes extreme measures with respect to privacy and data security. Read more about it here. Our R&D and customer support center are located in Israel.
At the same time, our business is international – we serve Customers that keep sight on their vehicles around the world on Surfsight, and we utilize additional processors and service providers in various countries. Therefore, we transfer, store or otherwise process your personal information in other countries. We take appropriate safeguards in the selection of our processing vendors around the world to require that your personal information is well protected. Despite our efforts, it may be the case that a country where your personal information is processed has different, or less protective, data protection and privacy regulation than the country you live in.
Surf Communication Solutions Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
In compliance with the Privacy Shield Principles, Surf Communication Solutions commits to resolve complaints about our collection or use of your personal information. European Union and/or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Surf Communication Solutions at: firstname.lastname@example.org
Surf Communication Solutions commits to cooperate with the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable, and comply with the advice given by the panel and/or Commissioner, as applicable, with regard to data transferred from the EU and/or Switzerland. You may have the option, under certain circumstances, to select binding arbitration for the resolution of your complaint. For further information, please see the Privacy Shield website.
Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you’re an User or Driver on Surfsight, please approach your employer to exercise any rights you may have, as they are the Data Controllers of your personal information. Otherwise, please contact us (details below).
According to the data protection and privacy regulation where you live, you may have certain rights with respect to your personal information.
Your rights may include, under certain terms and conditions set in the EU General Data Protection Regulation (GDPR) or other applicable law:
After deletion or anonymization of your personal data following its retention period, the rights to access, erasure, rectification, and data portability cannot be enforced.
Your personal information is processed based on several legal bases, including your consent. You can withdraw your consent at any time. Other legal bases, including statutory or contractual requirements that apply to you or our Customer might remain intact even following the withdrawal of your consent. You can also turn off, unpower, or disable the Device in the vehicle – this will stop the Device from recording Videos, collecting data, or sending new personal data to Surfsight. If we do not receive data from the Device, Surfsight might not function properly, and the data provided by Surfsight to our Customer who controls your account might be incomplete or inaccurate, and that might affect your work or compensation. Please consult with your employer regarding the potential effect of withdrawing your consent, or not using the Device.
If you’re a User or Driver on Surfsight, please contact your employer first with any issue, as they are the Data Controllers of your personal information. Your organization’s contact details appear on or around the Device, in the Portal, and in any communication you receive from Surfsight. If you do not know who your Data Controller is, please contact our customer support and we will let you know.
You can contact us with any question or concern you have at:
Surf Communication Solutions Ltd.
7 Hamada St., P.O.B. 343
Yokneam Hi-Tech Park 2069205
Surf Communication Solutions Inc.
240 Massachusetts Ave, Suite # 1523
Arlington, MA 02474, USA