Greater Than’s Privacy Policy for the FIA Smart Driving Challenge subevent Drive well
This privacy policy for the FIA Smart Driving Challenge 2022 app for road health and safety project (“Privacy Policy”) was created on October 12, 2022 by Greater Than. Your integrity is important to us. This Privacy Policy describes how we handle your personal data, with whom we may share your data with and your rights in relation to your personal data in connection with the FIA Smart Driving Challenge for road health and safety project (“the Challenge”). Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions. This Privacy Policy does not cover information that we collect or receive about you in other contexts, such as when you purchase a Greater Than product, browse Greater Than website, use other of Greater Than’s mobile apps etc. For our privacy practices generally, please see our general privacy policy on our website; www.greaterthan.eu.
We encourage you to read through this Privacy Policy carefully before you use the FIA Smart Driving Challenge App for the road health and safety project (the “App”) and take part of the Challenge.
1. Who collects your personal data?
Greater Than is the personal data controller responsible for the personal data processed under this Privacy Policy.
2. What is personal data and what type of personal data do we collect?
Personal data in accordance with GDPR is data which is directly or indirectly linked to a physically living person. When you download the App and participate in the Challenge Greater Than will collect, process and store the following categorize of personal data in structured material (e.g. databases, customer management systems, IT-systems and in unstructured material (eg. webpages, in documents, e-mails, reports etc) and in electronic forms and in paper form:
Categories of personal data:
(i) Sign up data: When you sign up for the App to be able to participate to the Challenge, you must provide personal data to Greater Than such as your name/nick name, e-mail address, password and country.
(ii) Participation and engagement data: During the Challenge you have the option to permit (totally voluntarily) GT and its partners and/or service providers to this Challenge to access to your health data such as e.g. your height, weight, your recorded activities, your pulse, your sleep and wake times, blood pressure, stress symptoms, GPS tracking during a run and activity data: for example steps you take, distance, pace, activity time, calories burned, your heart rate, sleep, location, hydration, music, etc).
GT and its partners and/or service providers to this Challenge will have access to your personal data regarding your car and driving pattern such as acceleration, speed, breaks, turns and G-forces, your GPS data through your FIA SDC account which you have signed up for.
(iii) Technical data and device information such as IP-address, device model, software and app related logs etc.
3. For what purposes do Greater Than collects, processes and stores your personal data?
Greater Than collects, processes and stores the personal data that is necessary to; administer the Challenge we provide to you in the App, to complete the agreement with you as a participant in the Challenge, to understand the correlation between driver health and safe driving, to enrol you in the road health and safety project, to conduct and support the road health and safety project, to issue research findings and related reports which will not identify you, to market Greater Than’s products, improve and develop products, develop new products, for market analyses, for confidentiality, administrative and education issues, for quality works, for statistical
purposes, for analysing your usage of the App and participating in the Challenge, ensure the technical functionality of the App, prevent usage of the App in violation with the terms and agreement for the App, forestall and investigate misuse of the App and fulfil obligations in accordance to the law.
4. How do we collect your personal data, and do we get some information from third party sources?
Personal data is usually collected directly from you as a customer, which includes the types of data that is generated through your use of the App, but we also collect, complete and process personal data from other sources, such as Greater Than’s partners in this Challenge which helps us understand user activities, your preferences or to improve and personalize the service in the App. The road health and safety project in the App will be based on driver’s health data provided via your account at the Garmin Connect app (if you have given your consent to Garmin to share your health data with GT) and safe driving pattern is provided by Greater Than. The health data will be accessed via Garmin smartwatches and the safe driving pattern data will be accessed via FIA SDC app.
5. On what legal basis do Greater Than process your personal data?
Greater Than will process your health personal data which is sensitive data in the App on the legal ground performance of an agreement to understand the correlation between driver health and safe driving and to enrol you in the road health and safety project.
Greater Than collects, processes and stores the personal data that is necessary to;
- to process your namn, e-mail address and password and administer the Challenge based on the legitimate interest in protecting the security of your account.
- to complete the agreement with you as a participant in the Challenge based on the legal ground: agreement.
- to complete the project and thereby understand the correlation between driver health and safe driving based on the legal ground agreement.
- to conduct and support the road health and safety project, to issue research findings and related reports which will not identify you, based on the legal ground agreement.
- to market Greater Than’s products. If you provide your opt-in consent to receiving marketing information from us based on the legal ground to processing your e-mail for marketing purpose is your consent. You may withdraw your consent at any time by changing your preferences in your FIA STC account or through the unsubscribe link at the bottom of our marketing e-mail.
- improve and develop new products, for market analyses; based on the legal ground legitimate interest in providing relevant and quality features and services to our customers.
- for administrative and education issues, for quality works, for statistical purposes, for analysing your usage of the App and participating in the Challenge based on the legal ground agreement
- ensure the technical functionality of the App based on the legal ground legitimate interest in resolving technical issues and errors and providing quality products to our customers.
- prevent usage of the App in violation with the terms and agreement for the App based on the legal ground agreement.
- forestall and investigate misuse of the App and fulfil obligations in accordance with the law based on the legal ground: Legal obligation.
6. Disclosure of your personal data to third parties
Greater Than will share your information to Greater Than’s partners and/or service providers who provide services for and on behalf of the Challenge in the App, to companies within Greater Than group, to courts and other authorities to comply with legal obligation and to respond to a valid legal process (such as a search warrant, court order, or subpoena) for our own or a third party’s justifiable interest, and to other partners and service providers (e.g. Microsoft in EU) within different areas to help us store, support, understand and improve the performance of our business and products.
We will not share, sell, give or in other way provide your personal data beyond what is being stated in this Privacy Policy if we are not obliged by law due to a demand by a governmental agency, court decision or if we received your consent to do so. We will never transfer personal data regarding customers who lives in EU to countries outside EU, except to subsidiaries within Greater Than Group. In such a case Greater Than ensures that an adequate level of protection in accordance with GDPR is fulfilled upon such transfer of personal data to another country and/or organisation. To the extent that Greater Than transfers personal data to a non-EU country which, according to the European Commission, does not achieve an adequate level of protection, Greater Than will ensure that the transfer is subject to applicable model clauses or standard safeguards regulations adopted by the European Commission. This also applies, where applicable, to transfer to any personal data processor, who processes personal data for the purposes stated in this Privacy Policy on behalf of Greater Than.
7. For how long time do we store your personal data?
Your personal data shall not be stored longer than necessary to fulfil the purpose of processing the personal data and no longer than permitted under GDPR. Your personal data is allowed to be stored for historical, statistical and scientific purposes for a longer period of time. Collected personal data may be used for research in road health and safety project and further development of Greater Than´s work. However, when personal data is no longer needed and the project has ended, Greater Than will delete or anonymize your personal data.
8. Automated decision-making
Automated decisions in accordance with GDPR mean that the decisions are determined without any manual human impact. Greater Than makes decisions about you based on automated decision-making when you are using the App. Greater Than determines when using the FIA Smart Driving Challenge App the distance of your driving and driving behaviour with automated processes through AI. This information might be the foundation of the deciding of your insurance premium. You have the right to contact us in case you are not satisfied with such an automatic decision.
9. How does Greater Than protect your personal data?
Greater Than takes the necessary and appropriate technical and organizational measures to protect your personal data and ensure that GDPR are complied with in the handling of your personal data. The security measures Greater Than uses may include access control, logging, use of firewalls, pseudonymization, encryption, detailed instructions and training for personnel concerning the protection of personal data and careful consideration when choosing service providers who process the personal data on our behalf. Your information is stored in our protected IT systems and networks. Access is restricted to authorized personnel only.
10. Your rights and contact
You have the right to access your personal data that we process and receive an extraction of your personal data. You also have the right to correct, block or delete false personal data. If the case is that we store your personal data in accordance with the law, the personal data may only be blocked. You also have the right to object regarding balancing interests, to object to direct marketing, to withdraw your consent. If you have given special consent to GT of processing your personal data, you always have the right to withdraw your consent.to have the processing of your data restricted and not to be subject to an automated decision. You also have the right to ask for your personal data to be transferred to another company and the right to complain to the Swedish Authority for Privacy Protection, https://www.imy.se/kontakta-oss or other competent supervisory authority in the country in question if you believe that Greater Than process your personal data in violation of
applicable data protection legislation. You manage your personal data with ease under the menu settings in the App.
11. Changes in the Privacy Policy
We may change or update this Privacy Policy. You accept the updates to the Privacy Policy by continuing to use the App. The latest version of this Privacy Policy is available through our website: www.fiasmartdrivingchallenge.com
12. Contact details to the data controller/Greater Than AB
To exercise your rights in accordance with the above or if you have any questions regarding our processing, please contact us: Greater Than AB, Karlavägen 60, 114 49, Stockholm, E-mail: info@greaterthan.eu
Last updated: October, 12 2022