WirelessCar takes privacy seriously. We value the trust that you place in us by providing us your personal information. We will always use your personal information in a way that is fair and worthy of that trust.
On this page, we provide you with information about how WirelessCar complies with its data protection obligations. We recognize that ensuring the protection of individuals’ right to privacy is not only a legal obligation, but it is also an ethical imperative and a sound business strategy. It is our belief that by demonstrating our commitment to the lawful and fair processing of personal data, we build trust between us and our staff, business clients, end-customers, and other individuals that we interact with.
The purpose of this page is to provide you with clear and straightforward information about how we interact with and approach personal data that we encounter in the course of conducting our business. We also provide you with case-specific notices detailing our use of your personal data in various context (Information Notices).
If you have any questions about this document, feel free to contact us at *protected email*. You will find further contact information at the end of this page.
Our core business is to provide our business clients (actors in the automotive industry) with connectivity-related services that enables their vehicles to provide useful functionality towards their end-customers. In this context, WirelessCar is operating on behalf of our clients and is performing any processing of personal data relating to these end-customers in our roles as a data processor. This means that, in terms of how and why personal data is used, we act on the instructions of our clients, as part of our commercial agreement.
This means that with regard to such processing activities, you (the data subject) are referred to the respective client for further information. This page only addresses processing of personal data which WirelessCar undertakes in our role as data controller, meaning that we are the one fully responsible for the proper and fair use of your personal data.
To ensure that we fulfil our legal obligations towards the law and our commitment to our clients, WirelessCar operates on a set of privacy principles that are incorporated into our business operations. These principles encompass the key aspects of data protection and end-customer privacy.
We recognize that your personal data belongs to you, and we only use it when necessary and legally permitted. For example, in some instances, we may be legally required to process your data, while in other situations we may rely on one or more legitimate interests of use. And in some cases, we will ask for your direct consent, in which case you will always be able to revoke your consent afterwards.
We are committed to only collecting and using the minimum amount of data necessary. This means designing our activities with collection and storage minimization in mind. This includes implementing retention policies aimed at keeping the amount of stored data to a minimum.
We strive to be as transparent as possible about how and why we use your data. You will inform you of any processing related to your data.
Personal data can be sensitive, and we take strong measures to ensure it is only accessed by authorized individuals and is kept secure.
We work with other companies (e.g., suppliers, customers, other WirelessCar companies) that help us to enable many of our business activities and services. This typically requires that we make personal data available to them. In such cases, we only share the necessary data, and we ensure that these third party companies adhere to the same strict privacy standards as WirelessCar.
WirelessCar is a global company with establishments in several countries outside the European Union. As such, we work to ensure that any cross-border transfers of data between international jurisdictions complies with the relevant data protection requirements. For transferring personal data outside the European Union/European Economic Areas (EU/EEA), we follow the requirements set by the General Data Protection Regulation (GDPR) and the EU Commission.
You have several rights regarding your personal data:
If you believe your data is not being processed according to the law, you can file a complaint with the local data protection authority, the details of which can be found at www.imy.se.
For any questions, or to exercise your rights, please contact us at:
WirelessCar Sweden AB (556640–4785) Vädursgatan 6, SE-412 50 Göteborg, Sweden *protected email*
These information notices provide you with case specific information relating to how we process your personal data.
WirelessCar complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.
The Data Privacy Framework for EU, UK and Swiss Individual's Data Transfer to the United States (DPF Policy)
WirelessCar complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. WirelessCar has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US. DPF. WirelessCar has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
Definitions
Scope and Responsibilities
This DPF Policy applies to Personal Data transferred from member countries of the European Economic Area, the United Kingdom, and Switzerland to WirelessCar’s COM’s operations in the U.S. in reliance on the respective DPF and does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation from the EU General Data Protection Regulation, the UK General Data Protection Regulation, and the Swiss Federal Data Protection Act.
Some types of Personal Data may be subject to other privacy-related requirements as set forth in more detail above.
All employees of WirelessCar that have access in the U.S. to Personal Data covered by this DPF Policy are responsible for conducting themselves in accordance with this DPF Policy. Adherence by WirelessCar to this DPF Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations.
Firm Personnel responsible for engaging unaffiliated third parties are responsible for obtaining appropriate assurances that such third parties processing Personal Data subject to this DPF Policy have an obligation to conduct themselves in accordance with the applicable provisions of the EU-U.S. DPF Principles, including any applicable contractual assurances required by the DPF.
Data Privacy Framework Principles
WirelessCar commits to applying the DPF’s Principles to all Personal Data that WirelessCar in the U.S. receives from European Economic Area member countries, the United Kingdom, and Switzerland in reliance on the respective DPF.
1. Notice
In accordance with our Privacy Policy set forth above, WirelessCar notifies Data Subjects about its data practices regarding Personal Data received by WirelessCar in the U.S. from member countries of the European Economic Area, United Kingdom, and Switzerland in reliance on the respective DPF, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types of third parties to which it discloses such Personal Data and the purposes for which it does so, the rights of Data Subjects to access their Personal Data, the choices and means that WirelessCar offers for limiting its use and disclosure of such Personal Data, how WirelessCar’s obligations under the DPF are enforced, and how Data Subjects can contact WirelessCar with any inquiries or complaints.
2. Choice
In accordance with the DPF, WirelessCar limits the use and disclosure of Personal Data of Data Subjects and Firm Personnel (residing in the EU and UK) Personal Data and will provide an opt-in choice for Sensitive Personal Data in the event Sensitive Personal Data is collected. If Personal Data covered by this DPF Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized or is to be disclosed to a non-agent third party, WirelessCar will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed.
WirelessCar will obtain affirmative consent (i.e., opt-in) from Data Subjects before any Sensitive Personal Data is disclosed to a third party. If Sensitive Personal Data covered by this DPF Policy is (i) disclosed to a third party, or (ii) used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, WirelessCar will obtain the Data Subject’s affirmative express consent (i.e., opt in) prior to such use or disclosure.
To opt out of such uses or disclosures of Personal Data or Sensitive Personal Data, Data Subjects may contact WirelessCar by either e-mailing WirelessCar at *protected email* or writing to us at WirelessCar Sweden AB (556640–4785) Vädursgatan 6, SE-412 50 Göteborg, Sweden.
3. Accountability for Onward Transfer
In the event we transfer Personal Data covered by this DPF Policy to a third party acting as a controller, we will do so consistent with any notice provided to Data Subjects, any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the DPF Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If WirelessCar has knowledge that a third party acting as a controller is processing Personal Data covered by this DPF Policy in a way that is contrary to the DPF Principles, WirelessCar will take reasonable steps to prevent or stop such processing.
With respect to our agents, including third parties acting on our behalf, we will transfer only the Personal Data covered by this DPF Policy needed for an agent to deliver to WirelessCar the requested product or service. Furthermore, we will (i) permit the agent to process such Personal Data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the DPF Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with WirelessCar’s obligations under the DPF Principles; and (iv) require the agent to notify WirelessCar if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.
WirelessCar remains liable under the DPF Principles if an agent processes Personal Data covered by this DPF Policy in a manner inconsistent with the DPF Principles, except where WirelessCar is not responsible for the event giving rise to the damage.
4. Security
WirelessCar takes reasonable and appropriate measures to protect Personal Data covered by this DPF Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.
5. Data Integrity and Purpose Limitation
WirelessCar limits the collection of Personal Data to information that is relevant for the purposes of processing. WirelessCar does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.
WirelessCar takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. WirelessCar takes reasonable and appropriate measures to comply with the requirement under the DPF to retain Personal Data in identifiable form only for as long as it serves a purpose of processing. Specifically, Personal Data will be retained in accordance with our business purposes and our obligations to comply with legal requirements and professional standards, unless a longer retention period is otherwise permitted by law and its retention adheres to the DPF Principles.
6. Access
Data Subjects whose Personal Data is covered by this DPF Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the DPF Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). WirelessCar will make reasonable and practical efforts to comply with your request, so long as our doing so would be consistent with applicable law, WirelessCar’s contractual requirements, and/or the professional standards applicable to WirelessCar. To make a data access request, Data Subjects may contact WirelessCar by either e-mailing WirelessCar at *protected email* or writing to us at WirelessCar Sweden AB (556640–4785) Vädursgatan 6, SE-412 50 Göteborg, Sweden.
7. Recourse, Enforcement and Liability
The Federal Trade Commission has jurisdiction over WirelessCar’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In compliance with the DPF Principles, WirelessCar commits to resolve DPF Principles-related complaints about our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding our handling of Personal Data received in reliance on the DPF should first contact WirelessCar by e-mailing *protected email* or writing to WirelessCar Sweden AB (556640–4785) Vädursgatan 6, SE-412 50 Göteborg, Sweden.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, WirelessCar has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information. Please visit www.bbbprograms.org/dpf-complaints for more information to file a complaint. This service is provided free of charge to you.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may be able to invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf for further information.
WirelessCar agrees to periodically review and verify its compliance with the DPF Principles, and to remedy any issues arising out of failure to comply with the DPF Principles. WirelessCar acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of DPF participants.
Pursuant to the Data Privacy Framework the following notifications apply to EU, UK and Swiss personal data that is transferred into the United States:
WirelessCar has further committed to refer unresolved DPF Principles-related complaints (each a “DPF complaint”) to a U.S.- based independent dispute resolution mechanisms as follows:
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf.
If your DPF complaint cannot be resolved through the above channels, under certain conditions you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2.
In the UK, unresolved complaints can be sent to the Information Commissioner’s Office by calling 0303 123 1113 or by visiting: https://ico.org.uk/concerns/.
EU residents have the option of filing complaints directly with their local DPA, which will work with the Department of Commerce and the Federal Trade Commission (FTC) to investigate and resolve complaints. In the event your complaint is unresolved by all other available mechanisms, you may have the right to invoke binding arbitration before a Privacy Framework Panel, in accordance with procedures designated by the Department of Commerce and the European Commission.
Changes to this Privacy Policy
WirelessCar reserves the right to change this Privacy Policy at any time to incorporate new rules or guidance issued under the General Data Protection Regulation, Data Privacy Framework, the UK Extension to the EU-U.S. DPF, the Swiss-U.S. Data Privacy Framework and local privacy and data protection legislation. Any changes to this Privacy Policy will be posted to this page as soon as reasonably possible and will become effective immediately. Therefore, please check this page periodically. Use of the website and our services constitutes acknowledgement that WirelessCar uses your information in accordance with the Privacy Policy then in effect.
Questions and Comments
WirelessCar is committed to protecting the privacy of Personal Data. Questions or comments about this Privacy Policy and DPF Policy e-mailing *protected email* or writing to WirelessCar Sweden AB (556640–4785) Vädursgatan 6, SE-412 50 Göteborg, Sweden.
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