Privacy Policy

This privacy policy will explain how SambaSafety (Safety Holdings, Inc. (hereinafter referred to as “SambaSafety US”) and, to the extent we jointly control data with Collision Management Systems Limited (hereinafter referred to as “SambaSafety UK”)), SambaSafety UK use(s) the personal data we collect from you when you use our website and/or services.

I. Controller(s)

Safety Holdings, Inc.:
5619 DTC Parkway, Suite 1000
Greenwood Village, CO 80111
United States of America

Collision Management Systems Limited
c/o Ellacotts LLP
Countrywide House, 23 West Bar Street
Banbury, Oxfordshire OX16 9SA
United Kingdom

II. Data We Collect

You can visit SambaSafety’s website without providing any personal information. However, when using our website or in the course of our provision of driver risk management or other professional services, there is a possibility that we process personal data from you.

We collect the following data:

  • Personal identification information (name, address, business telephone number and email address)
  • Billing information
  • Company information
  • Country

III. How Do We Collect Your Personal Data

You directly provide SambaSafety with most of the data we collect. We collect data and process data when you:

  • Register online for SambaSafety services or place an order for any of our services
  • Voluntarily complete a customer survey or provide feedback on our message board or via email
  • Use or view our website via your browser’s cookies
  • Sign up online to receive one of our publications or otherwise request such publications from us

IV. How We Use Personal Data

We collect and use your personal information for the primary purpose of providing our clients with driver risk management and other related professional services, including for the following purposes:

  • to establish and manage client relationships, perform our services, and fulfill any legal duties in connection therewith;
  • to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, evaluate credit standing, and to fulfill contractual obligations;
  • to measure and analyze traffic and browsing activity on our site(s) and serve you advertisements about the products and/or services that are likely to be of interest to you, provided that you give us your consent to do so;
  • to maintain, develop and manage our document management, knowledge-management and precedent systems and databases; and
  • to understand your needs and determine the suitability of other services we may be able to offer to you, or to improve our services to reflect your interests.

When you provide us with the personal information of other individuals in the course of our provision of professional services to you, we are relying on you to have obtained – and to maintain – the requisite authority under applicable privacy laws for the disclosure of such personal information to us, and our subsequent collection, use and disclosure of such personal information, including obtaining appropriate consent from such individuals.

V. Purposes of the processing

1. Contractual relationship / Business partners

If you enter into a contract with SambaSafety for one of our services, we process your data for the performance of a contract.

It may be necessary to process the personal data provided by you beyond the actual perfor-mance of the contract. The legitimate interests are the selection of suitable business partners, the performance of surveys on evaluations of companies, the storage and use of contact data of con-tact partners, for the digitization of files, avoidance of economic disadvantages, the allocation of work results to individual business partners, booking of business transactions, negotiating with contact partners who are not or do not become business partners directly, invitations to events, asserting legal claims and avoiding legal disadvantages (for example, in the event of insolvency), legitimation checks (for example, money supply and disposal companies), defending against dangers and liability claims and avoiding legal risks, recognizing and processing potentially damaging e-mails, access controls, clarifying possible compliance violations, preventing criminal offenses, settling damages resulting from the business relationship, and other internal administrative purposes.

2. Online registration

3. When you register with us online, we process your data on the basis of a legitimate interest. The legitimate interest of us results from the interest to be able to provide the customers with the extended functions of our services. The data of your customer account can be used for the technical administration of the customer account and for statistical anonymous evaluations.

Publications and Other Communications

When you sign up online to receive one of our publications, or otherwise request such publications from SambaSafety, we may ask for your name, business mailing address, business telephone number and business email address. We use this information for the purposes of providing you with the publications you request and as part of our customer relationship management program.

In addition, from time to time, SambaSafety may also send e-mail or other communications to subscribers, clients or other individuals in our contact database to advise such individuals of developments in driver risk management and other matters relevant to such individuals or their business or industry; provide them with information about or promotions relating to products and services we believe may be of interest to them, or to advise them of upcoming events.

If you have consented to the sending of advertising, you can object to receiving advertising at any time. You may opt-out of receiving such communications at any point by using the opt-out feature included in each email, or by contacting us using the details at How to Update your Personal Information or Otherwise Contact Us below. Please note that SambaSafety clients will continue to receive electronic communications from us relating to our provision of services to them.

We occasionally may ask visitors to our website, clients, and other contacts to complete voluntary online surveys and opinion polls about their activities, attitudes and interests. These surveys help us understand the needs of our website visitors, clients, and contacts; evaluate client service satisfaction; and enhance our product and service offerings.

We process your data on the basis of a legitimate interest. The legitimate interest of us results from the interest to be able to provide the customers with the extended functions of our services.

4. Join Our Team

You can submit your resume and other information online to apply for a job with us. We use the information you submit to evaluate your qualifications, to contact you regarding possible current and future employment opportunities, and for other employment related purposes.

We store your data only for as long as is necessary. If we are able to recruit you for our team, your data will be used for the purpose of initiating and implementing the employment relationship. Your applicant data will be deleted after seven days at the latest if we have sent you a rejection letter.

VI. Joint Controller

The controllers above processing the personal data specified below as joint controllers for the following purposes.

  • Customer Data:
    • Contact details (company name, name, e-mail address, address)
  • Marketing Data:
    • Contact details (company name, name, e-mail address, address)
  • Employee Data:
    • Typical employee record information

These data will be used for the purpose of storage and processing. Employee Data is used to pro-vide Human Resource services to employees. Marketing Data is used to provide customers in-formation regarding products and services. Customer Data is used to provide customers products and services for which they have subscribed.

VII. Tracking Activity on Our Website

In order to improve the site, we may track whether or not a site visitor is new or returning and collect information about our users through automatic data collection tools, which may include “cookies” and other commonly used technologies (e.g. web beacons). This information includes, without limitation, your web browser, location, and Internet Protocol (IP) address. Cookies are small strings of text that are sent by the site to your browser and then stored by your browser on your computer’s hard drive. Information collected via cookies will be used solely for statistical reporting, unless you are a repeat visitor to our website, in which case a code in the cookie file may enable the site to label you as a particular user so that we may personalize and enhance your experience on our site. In addition, if you submit personal information (e.g., name, address, email, etc.) via an electronic form contained on our website, the cookie file may enable us to identify you by such personally identifiable information in connection with collecting statistical information and personalizing your experience on our site. Most web browsers automatically accept cookies, but it is possible to change your browser setup so that it does not accept cookies. However, rejecting cookies may prevent you from taking advantage of certain portions of our site. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit the website: http://www.allaboutcookies.org.

We also use a tracking service that allows us to determine if a visitor accessed our website from a third-party advertisement service. This information is only a transaction count.

Except as expressly set forth in this Privacy Policy, we do not engage in the collection of personally identifiable information about your online activities over time and across third-party websites or online services. Accordingly, we do not currently process or comply with any Web browser’s “do not track” signal or other mechanisms that provide consumers with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites. Further, except as expressly set forth in this Privacy Policy, we have not knowingly authorized any third parties to collect personally identifiable information about your online activities over time and across different websites when you use the site. Nonetheless, such third-party companies (e.g., companies providing features or functionality on the site, etc.) may collect and use information during your visits to our site and other websites in order to provide advertisements on other sites about goods and services likely to be of greater interest to you. These companies typically use a cookie or a third-party Web beacon to collect such information.

Some of the third party services used on our site(s) are businesses within the scope of the California Consumer Privacy Act, and require us to provide you the notices found here.

VII. Information We Share

We do not sell, rent, trade or otherwise disclose personal information about our website visitors, clients or other individuals, except as described here or when we have your consent to do so. We may, as permitted by law, share information provided by our website visitors, clients or other individuals with our affiliates and with service providers we may retain to perform services on our be-half. For example, we use services providers to provide services such as hosting the www.SambaSafety.com site and operating certain of their features, document and data storage and management, providing client services, maintaining the security of our systems, software support and office services, and sending email or other communications. If service providers act on our behalf, we conclude an agreement of data processing.

These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements. In addition, we may disclose information about you (i) if we are required or permitted to do so by applicable US or other laws or regulations or by legal process, (ii) in response to a search warrant or other request from law enforcement authorities or other government officials in such jurisdictions, (iii) if we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, (iv) to protect the integrity or security of the site or the interests, rights or property of SambaSafety, including to establish, exercise or defend a legal claim; (v) to detect, prevent or suppress fraud; and/or (vi) to investigate a breach of, or to enforce our sites’ terms of use or other applicable agreements.

VIII. Links to Other Sites

On occasion, we provide links to other websites for your convenience and information. These sites operate independently from sambasafety.com/ and are not under our control. These sites may have their own privacy notices in place, which we strongly suggest you review if you visit any linked websites. We are not responsible for the privacy practices or policies of such third parties, content of these sites, any products or services that may be offered through these sites, or any other use of these sites.

IX. Children Under Age 18

While the content of our page may be suitable for audiences of any age, the site is not designed for children and we do not knowingly collect, use or disclose any personally identifiable information from those under the age of 18, without the consent of a parent or guardian. By accessing and using our site, you hereby represent that you are at least 18 years of age.

X. Security

We use commercially reasonable administrative, technical, and physical measures in an effort to protect against loss, theft, and unauthorized disclosure, access, use, alteration or destruction of personal information in our possession. Please be aware, however, that Internet data transmission is not always secure, and we cannot and do not guarantee that information you transmit utilizing our site is secure.

XI. Business Transfer

If we should in the future sell or otherwise transfer some or all of our assets to a third party in connection with a proposed or completed acquisition or sale (including transfers made as part of in-solvency or bankruptcy proceedings), or a corporate reorganization or share sale or other change in corporate control, the personally identifiable information and/or other information in our records may be disclosed to any such potential or actual purchasers of such assets or may be among those assets transferred, as permitted by law.

XII. Notice to Users Outside the United States of America

Where you are located outside of the United States, for example in the European Economic Area (“EEA”), by using this site and providing us your personally identifiable information, you hereby explicitly acknowledge and consent to (i) the transfer of such information to recipients in countries located outside of your country of origin, (including the United States where the site is hosted) which may not provide a similar or adequate level of protection to that provided by your home country. Your personal information may be maintained on servers in the US, and processed by our affiliates and other third party service providers in the US or other jurisdictions and as such, your data is subject to American law. You can withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

XIII. Your Rights

If you are an individual located in the EEA or Canada, you may have certain rights, which may be subject to limitations and/or restrictions. These rights may include the right to: (i) request access to and rectification or erasure of your personally identifiable information; (ii) obtain restriction of processing or to object to processing of your personally identifiable information; and (iii) have your personal data transmitted to you or a third party in a digital format. You also have the right to lodge a complaint about the processing of your personally identifiable information with your local data protection authority.

XIV. Retention

We may retain personal information provided by you for as long as necessary to comply with our legal and regulatory obligations, or to achieve the purposes for which the personal information was collected as described in this Privacy Policy.

XV. Acceptance of this Privacy Policy

This Privacy Policy is incorporated into and subject to the terms of use of the applicable SambaSafety website or service while you are using it. If you do not agree to the terms of this Privacy Policy, please do not provide us with any information and do not use our site or service. However, if you do not provide us with the required personal information, we may not be able to provide you with the requested services.

XVI. Updates to this Privacy Policy

We may update or change this Privacy Policy from time to time and without prior notice to you and any and all such modified versions of our Privacy Policy will be effective upon posting on our site. We will post a prominent notice on this site to notify you of any significant changes to our Privacy Policy and indicate at the top of the notice when it was most recently updated. In the event we modify this Privacy Policy, your continued use of our site or our services will constitute your acceptance of the modified Privacy Policy.

XVII. How to Update Your Personal Information or Otherwise Contact Us

It is your responsibility to ensure the personal information we have on file for you is accurate, complete and up to date. If you would like us to inquire about the information we have for you in our records, update your personal information, ask us to remove you from contact lists, or if you have any questions about our or our information practices, please contact the SambaSafety team member responsible for your account or contact us by:

Calling us at:
888.947.2622
(6 a.m. – 6 p.m. Mountain time)

Writing us at:
5619 DTC Pkwy #1000
Greenwood Village, CO 80111

Emailing us at: dataprivacyoffice@sambasafety.com


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