Privacy Policy

1. Introduction

This Privacy Policy applies to FleetPulse Procurement Inc. ("FleetPulse," "we," "us," "our") and governs how we collect, use, maintain, and disclose information obtained from users of our website (www.fleetpulse.io), mobile applications, and the FleetPulse Platform (collectively, the "Services").

FleetPulse is headquartered in Toronto, Ontario, Canada (120 King St W, M5H 1J9) and is subject to the Personal Information Protection and Electronic Documents Act (PIPEDA), the privacy laws of Canadian provinces, and the General Data Protection Regulation (GDPR) for residents of the European Economic Area.

This policy was last updated on January 1, 2026, and is effective for all users of our Services.

2. Types of Information We Collect

We collect various types of information in connection with the services we provide:

• Account Information: Name, title, organization, email address, phone number, and job function provided during registration or account setup.
• Fleet Data: Network device information, hardware inventory, serial numbers, lifecycle dates, purchase history, and maintenance records provided by you or transmitted through our sensors and APIs.
• Transaction Information: Procurement requisitions, purchase orders, supplier communications, pricing data, and payment information processed through our platform.
• Technical Information: IP address, browser type, operating system, referring URLs, pages visited, time and date stamps, clickstream data, and cookie identifiers automatically collected via our website and mobile applications.
• Communications: Records of your interactions with our support team, including emails, chat transcripts, and phone call logs.
• Usage Analytics: Information about how you use the FleetPulse Platform, including feature adoption, user behavior patterns, and workflow analytics.

3. How We Collect Information

We collect information from you in the following ways:

• Direct Collection: Information you voluntarily provide to us through account registration, contact forms, support requests, or direct communication with our team.
• Automated Collection: Information automatically collected through cookies, web beacons, pixel tags, server logs, and similar technologies when you access our website or applications.
• Sensor Data: Information transmitted from IoT sensors deployed in your network infrastructure or collected through API integrations with your existing systems (inventory, purchasing, ERP).
• Third-Party Sources: Information from device manufacturers, suppliers, and data partners (Ricoh, Zebra, Xerox, HP, and similar vendors) to enrich your fleet profiles and pricing data.
• Inference: Derived data created when we analyze collected information to generate insights, predictions, and procurement recommendations.

4. Legal Basis for Processing

We process personal information based on the following legal grounds under PIPEDA and GDPR (where applicable):

• Contract Performance: Processing necessary to provide the FleetPulse Services you have subscribed to and fulfill our contractual obligations to you.
• Legitimate Interest: Our business interests in improving our Services, conducting analytics, detecting fraud, maintaining security, and complying with legal obligations.
• Consent: Where you have explicitly consented to specific processing activities, such as marketing communications or use of optional analytics features.
• Legal Obligation: Processing required to comply with applicable laws, regulations, court orders, or government requests.
• Vital Interest: Processing necessary to protect the vital interests of individuals or the public (security incidents, legal disputes).

5. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the FleetPulse Platform and related Services.
• Process and fulfill procurement requisitions, purchase orders, and transactions.
• Generate fleet analytics, lifecycle forecasts, and AI-powered procurement recommendations.
• Send transactional emails related to your account, subscriptions, and Services.
• Respond to customer inquiries, support requests, and complaints.
• Monitor, analyze, and optimize platform performance, user experience, and feature adoption.
• Detect, investigate, and prevent fraud, security incidents, and unauthorized access.
• Conduct anonymized and aggregated analytics to understand market trends and customer patterns.
• Comply with legal and regulatory obligations, including data retention requirements.
• Enforce our Terms of Service and other agreements.
• Send marketing and promotional communications (only with your consent or where legally permitted).

6. Data Sharing and Disclosure

FleetPulse does not sell personal information. We may share information with:

• Service Providers: Vendors and contractors who provide services on our behalf (hosting, analytics, email delivery, payment processing) under confidentiality agreements and Data Processing Agreements (DPAs).
• Integrated Partners: Third-party providers of ERP systems (SAP, Oracle), inventory management, and procurement platforms you authorize to connect with FleetPulse.
• Supplier Networks: Aggregated device and spend data with suppliers (Ricoh, HP, Xerox, etc.) to facilitate competitive pricing and inventory recommendations — always in anonymized, non-identifying form.
• Legal Authorities: Information disclosed as required by law, court order, or government request.
• Business Transactions: Information disclosed in connection with merger, acquisition, bankruptcy, or sale of assets — subject to appropriate privacy protections.
• Other Users: Within your organization, only to other authorized users of the same FleetPulse account.

7. Data Retention

We retain personal information for as long as necessary to provide the Services and fulfill the purposes outlined in this Privacy Policy. Specific retention periods include:

• Account Information: Retained for the duration of your subscription plus 2 years for legal and tax compliance purposes.
• Fleet and Transaction Data: Retained for 7 years to comply with audit and regulatory requirements (CRA, provincial regulators).
• Support Communications: Retained for 3 years after resolution of the support request.
• Technical Logs: Retained for 90 days for security and performance purposes.
• Marketing Communications: Retained until you unsubscribe or request deletion.

You may request deletion of personal information at any time, subject to legal and contractual retention obligations. Deleted information may persist in encrypted backups for 30 days before permanent destruction.

8. Data Security

FleetPulse implements comprehensive security measures to protect your information from unauthorized access, alteration, disclosure, or destruction:

• Encryption: AES-256 encryption for data at rest; TLS 1.3 for data in transit.
• Access Controls: Role-based access control (RBAC) and multi-factor authentication (MFA) for all platform users.
• Network Security: Firewall protection, intrusion detection, and DDoS mitigation.
• Compliance Certifications: SOC 2 Type II certified; ISO 27001 compliant; annual penetration testing and vulnerability assessments.
• Canadian Data Residency: All customer data stored in encrypted form within Canadian data centers (Ontario, Quebec).
• Incident Response: 24/7 security operations center; incident notification procedures compliant with PIPEDA and GDPR requirements.

While we implement strong security measures, no system is completely secure. You acknowledge that there is some inherent risk in transmitting information over the internet.

9. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

• Right of Access: You may request a copy of personal information we hold about you.
• Right of Correction: You may request correction or amendment of inaccurate personal information.
• Right of Deletion: You may request deletion of your personal information (subject to legal and contractual obligations).
• Right of Portability: You may request transfer of your personal information to another service provider in a structured, commonly used format.
• Right to Object: You may object to processing of your information for marketing, profiling, or other specific purposes.
• Right to Restrict Processing: You may request restriction of processing during investigation of disputes or accuracy challenges.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time (prior processing remains lawful).

To exercise any of these rights, contact our Privacy Officer at [email protected]. We will respond within 30 days of your request.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

• Essential Cookies: Necessary for authentication, security, and platform functionality (cannot be disabled).
• Analytics Cookies: Help us understand user behavior and improve platform features (optional; configurable via Cookie Policy).
• Marketing Cookies: Enable personalized content and retargeting across platforms (optional; requires explicit consent).

For detailed information about cookies and your choices, please see our Cookie Policy.

11. Third-Party Links and Services

Our website and Services may contain links to third-party websites and services that are not operated by FleetPulse. This Privacy Policy does not apply to third-party websites, and we are not responsible for their privacy practices. We encourage you to review their privacy policies before providing personal information. When you connect your FleetPulse account to third-party platforms (ERP systems, inventory management tools), data sharing is governed by their respective privacy policies and your authorization.

12. Contact and Privacy Officer

If you have questions about this Privacy Policy or our privacy practices, please contact our Privacy Officer:

You also have the right to lodge a complaint with your local privacy regulator (in Canada, contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca; in the EU, contact your Data Protection Authority).

13. Policy Updates

FleetPulse reserves the right to update this Privacy Policy at any time. Changes will be effective upon posting to our website and will be identified with an updated "Last Modified" date. Your continued use of the Services after such modifications indicates your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.