Privacy Policy

Last Updated: October 23, 2025

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD.  IF YOU DO NOT AGREE WITH THIS POLICY AND OUR TERMS AND CONDITIONS, YOU SHOULD NOT ACCESS OR USE OUR SITE OR APP OR ENGAGE IN COMMUNICATIONS WITH US CONCERNING OUR SERVICES.

OUR SITES ARE INTENDED FOR USERS LOCATED IN THE UNITED STATES AND ARE NOT INTENDED FOR USERS LOCATED IN OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA.

1. INTRODUCTION AND PURPOSE

Transport Enterprise Leasing, LLC (also referred to herein as “TEL”, “TEL360”, “we”, “us”, and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business.  This Privacy Policy (the “Policy”) describes how TEL processes and uses the personal information that we collect through our website, tel360.com, as well as other websites that direct to or otherwise contain a link to this Privacy Policy (collectively the “Site”), download access, or use the TEL mobile application (the “App”), or otherwise provide to us in connection with our products, devices, software, and services (the “Services”). 

This Privacy Policy is incorporated into our Terms and Conditions.  By using our Site, App, or Services, you hereby acknowledge and agree to this Privacy Policy and our Terms and Conditions. 

2. INFORMATION WE MAY COLLECT

We may collect and process the following types of personal information from you for the purposes listed below.  The information we collect depends upon things such as the nature of our relationship, the method you communicate with us, the Services you use, the purpose for your interaction with us, and the choices you make. 

We collect information about you from various sources and in various ways when you use our Site, App, and Services, including information you provide directly, information collected automatically, information from third-party data sources, and data we infer or generate from other data. 

• Contact Information: When you visit the Site or our App, register for an account, sign up for our newsletter or mailing list, contact us via the Contact Us form on the Site or App, request or use our Services, submit a comment, question or review, or otherwise provide us your personal information, we may collect your first and last name, business name, date of birth, address, telephone number, email address, mailing address, or other contact details in connection with our Services or to respond to your request or inquiry.
• Account Information: Some information may be required to create an account on our Site or App, such as your name, business affiliation, date of birth, email address, username, password, telephone number, and other identifiers. Account information may also include your permission levels and access rights as set by your organization. Once you are authenticated within the Site or App, your access to documents, data, and features will be governed by the permission levels and access rights established by your organization or account administrator. You will only be able to view or interact with information and resources for which you have been granted explicit authorization.
• Transaction Information: This may include information about your purchase or lease of equipment, payment information, and billing and shipping addresses. We do not store your payment information, but our payment processor may store such payment information subject to their own privacy policies and terms.
• Vehicle Information: We collect information related to your trucks and equipment, including, but not limited to, vehicle identification numbers (VINs), registration details, Department of Transportation Inspections (DOTs), title, lease and financing documents, invoices, statements, tags, telematics data (such as location, temperature, operational metrics, and parts status), and related documentation. We do not collect or store driver-specific information, safety information, or hours-of-service data.
• Usage Information: When you visit the Site or App, view or search content, install applications or software, create or log into your account, or use our Services, we and other third parties may automatically collect certain usage or network activity information from your browser, mobile device, computer, tablet, or other devices or browsers you use, which includes the date and time of your visit, your Internet Protocol (IP) address, unique device identifier, domain server, your browser type, operating system, the referring web page, access time, cookies, and data about which pages you visit. We may also collect information regarding your interactions with the Services or our advertising.

Telematics and Location Data: In order to monitor, maintain, and safeguard the equipment that connects to the App, we may collect real-time or historical data about your vehicles, including location, temperature, operational metrics, and other vehicle-related data through integrations with third-party service providers. Location data may be collected via GPS, Google Maps APIs, or other technologies, and may be associated with specific vehicles or equipment. These data are automatically transmitted to us whenever the equipment or the App is active.

Push Notifications:  This permission allows the App to send push notifications on your device.  If granted, we may send a push notification to alert you of a notification in the App.

Device permission requests are limited to those that are necessary to implement the App.  You may change your preferences regarding device permissions at any time by changing the settings on your device.  Opting-out will cause the associated features to be disabled in the App. 

• Third-Party Information: In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, service providers, advertising partners, or publicly available sources as permitted by law. These third parties may provide us with information necessary to provide our Services or to authenticate your access, including data obtained through integrations with platforms like Google APIs.
• Cookies and Similar Technologies: We use cookies, pixels, and similar tracking technologies as described in the “Cookies and Similar Technologies” section of this Policy. If you choose to disable cookies and similar technologies, some areas and features of the Sites or Services may not work properly. Please see our “Cookies and Similar Technologies” section to learn about the types of cookies we use, how we use them, and your choices for cookies.
• Geolocation Information: This may include the IP address or other location information transmitted by a mobile or other device (depending upon your settings) when you interact with the Sites or otherwise use the Services.
• Social Media Information: If you engage with us on third-party social media platforms, such as Facebook, Instagram, YouTube, or TikTok, we may collect and aggregate the personal information through your engagement with us, including all content, messages, and information that you provide to us and that you make publicly available on the profile through which you submitted such information to us. 
• Communications Data: If you contribute to the Site or App, provide us with feedback, ask us questions, or otherwise communicate with us, in addition to your Contact Information, we may collect the subject matter of your message, any comments, content, or other information that you choose to provide, and other information needed to respond to your communication.  If you receive email communications from us, we may use certain tools to capture data related to if/when you open our message and if/when you click on any links or banners it contains. 
• Video Viewing Information: We may collect information about videos that you view or stream on the Site or App as well as the accounts that you link together with our Services, including social media accounts.  Please see the “Visual Materials and Consent to Collect, Use, and Disclose Video Viewing History” section of this Policy for additional information.
• Other information that you voluntarily share with us to facilitate use of the Site, App, or our Services which is not specifically listed here.  We will use such information in accordance with this Policy, as otherwise disclosed at the time of collection, in accordance with our applicable agreement with you, or to the extent necessary for providing the Sites or our Services.

When you are asked to provide your information, you may choose not to provide us with your information or otherwise decline or use browser or device controls to prevent certain types of data collection.  However, in some cases, if you choose not to provide information that is necessary, you may not be able to access portions of the Site or App, or some Services or features may not be available or fully functional.

3. HOW WE MAY USE YOUR INFORMATION

We may use the information described above, including any personal information, in connection with the following business or commercial purposes or otherwise to the extent permitted by law:

• Providing Our Products and Services To You: We use your information to provide our products and Services, which includes making our Site, App, Services, and our content available to you, to serve you the content and functionality you request, to provide and deliver products, including fulfilling your order, troubleshooting, and personalizing our Services, to offer you goods and services which may be of benefit to you, to communicate about our Services and responding to your feedback, requests, questions, or inquiries, to enhance your experience and provide you with a more personal and interactive experience, to improve and develop existing and new Services, including evaluations of functionality and features and recognizing your devices and remembering your preferences and interactions, to ensure the privacy and security of our Site, App, Services, and operations.
• Operating Our Business: We use your information to operate our business, such as to obtain or maintain insurance coverage, managing risks, obtaining professional advice, to mitigate risks to the privacy and security of our Site, App, Services, and operations, including fraud or phishing detection, to maintain our databases and back-ups, to enforce our Terms and Conditions, to comply with any contractual obligations, to manage our relationships with you, and to comply with your instructions or requests.
• Communicating With You: We use your information to communicate with you, such as to contact you directly by mail, telephone, email, SMS, or other electronic messaging service to in order to respond and provide the appropriate assistance and response to you; to extend offers of goods and services or information that may be of interest to you; to keep records of our communications with you; to determine user interests; for usage analytics purposes; and to administer a promotion, survey, or other customer engagement features. You may unsubscribe from certain communications at any time. Please see the “Your Rights and Choices Regarding Your Personal Information” Section of this Policy for more information
• Marketing and Advertising: We use your information to tailor our products and Services so that they are more relevant to you, to understand your preferences and provide and improve support related to our product and service offerings, including targeted offers and advertising through the Site and/or App, on third-party sites, and via other communication mediums, to advertising our products and Services, to assess the success of our marketing campaigns and enhance our marketing efforts, to inform you of new products and Services, to run contests and promotions, and to conduct research and analysis for marketing, business, and other operational purposes.
• Fraud, Security, Legal Enforcement and Compliance: We use your information to protect the security and integrity of our business, the Site, App, and our Services, such as to enforce our agreements with you, to comply with federal, state, or local laws; to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons; to cooperate with law enforcement agencies concerning conduct or activity that we may believe violates applicable law; and to establish, exercise, defend legal rights or claims, whether in court, administrative, or other proceedings.

We may also use your information to accomplish any other purpose related to and/or ancillary to any of the purposes described in this Policy, for which your personal information was provided to us, or for which we have a legal basis under applicable law.  We may combine personal information about you with other information we have acquired from third parties in accordance with applicable law and will treat the combined information as personal information under this Policy. 

We may create, disclose, and otherwise use information as de-identified or aggregated data which, upon aggregation and de-identification, are no longer treated as personal information subject to this Policy. 

4. HOW WE MAY DISCLOSE YOUR INFORMATION

We may disclose or share your personal information described above to the following types of third-parties:

• Service Providers: We may share your personal information with our third-party service providers and other parties who perform a variety of functions on our behalf or at your direction for the purposes described in this Policy. This includes, but is not limited to, development,  administration, and maintenance of the Site and App, support our provision of Services requested by you, provide technical support, sending marketing, promotions, and communications to you about our Services, provide payment processing, enhance the security of our Site or App, marketing or advertising services, and assisting with other legitimate purposes permitted by law.

These service providers may include, for example, PayNet or Equifax for credit checking, as well as technology platforms such as Google APIs and Microsoft Azure, which support integrations, data processing, authentication, and other operational needs. We only share your information with these third parties to the extent necessary to deliver our Services, ensure security, or fulfill other legitimate business purposes permitted by law.

We may also disclose the personal information we collect to our analytics vendors and partners, including social media companies such as Facebook, to develop aggregate analytics and business intelligence for our advertising and marketing purposes.  For example, we use personal information to create custom audiences and measure the success of promotions. 

When you watch videos on the Site or App, you agree that we may disclose your video viewing to or obtain information about your video viewing from analytics service providers, advertising partners, and social media platforms. 

• Corporate Affiliates: We may share your personal information with our subsidiaries or affiliates, and with their respective officers, directors, employees, accountants, attorneys, and agents.
• Acquisition and Similar Transactions: If we sell, transfer, or otherwise share some or all of our assets in connection with a merger, reorganization, liquidation, dissolution, bankruptcy, or sale of assets, we may disclose your personal information as a part of the assets transferred as a result of the transaction. For example, if another company acquires us, we will share your personal information with that company.
• In Response to Legal Process or Defending Legal Claims: We may disclose personal information as required by law, court orders, subpoena, or other legal process or if we reasonably believe such action is necessary to comply with the laws.
• Professional Advisors: We may share your personal information with our attorneys, accountants, and/or other fiduciaries and consultants that need access to your information to provide operational or other support on our behalf.
• With Your Consent or at Your Direction: We may ask, from time to time, if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We may disclose your information in this context with your permission or upon your direction. 
• Third Parties: We may provide personal information about you to third parties that may offer services specifically requested by you.
• Deidentified or Aggregated Data: We may share aggregated information, and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, (i) for compliance with reporting obligations; (ii) for business or marketing purposes; and (iii) to assist us and others in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, marketing, and/or functionality.

5. COOKIES AND SIMILAR TECHNOLOGIES

Cookies

A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your device and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your device until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

Other Similar Technologies

In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons, pixels (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, pixels are small images on a web page or in an email that collect information about your browser or device and can set cookies.  Web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.

What Cookies and Similar Technologies Do We Use and Why Do We Use Them?

We use certain cookies and similar technologies to operate the Site and App, to measure and track how you interact with the Site and App, to ensure the privacy and security of our Site and App, to enhance your experience and provide you with a more personal and interactive experience, to market to you, to track ad-driven activity, to perform usage analytics, and to otherwise tailor our communications to you. 

The cookies and similar technologies used on the Site and App include the following:

Essential: Essential cookies are necessary for basic features and functionality of the Site.  Without these essential cookies, the Site will not perform properly, and we may not be able to provide you with certain Services you have asked for, provide access to secure areas, and choices you have made for better functionality cannot be provided.

Functionality: Functionality cookies help us customize content on the Site based on your preferences.  We use functionality cookies to remember choices you’ve made or information you’ve provided, such as your username or the region you are in.  This allows us to tailor your experience on the Site or App to your preferences.  For example, authentication cookies are functionality cookies that are used for the duration of a session (or persistent, if you agree to the “remember me” function) to allow users to authenticate themselves on subsequent visits or gain access to authorized content across pages on the Site or App. 

Analytics and Performance: We use analytics and performance cookies to collect information about how you use the Site, including which pages you go to most often and if users receive error messages from certain pages in order to help us fix technical issues or errors and highlight areas where we can improve the Site.  We also use these cookies to detect the most searched for words in search engines that lead to the Site.  These cookies are not used to target you with online marketing and advertising.  You may also encounter third-party analytics and performance cookies on our Site which may gather browsing activity (such as information you have entered or choices you have made) across numerous websites that you visit and across numerous browsing sessions.  These cookies also help improve how our Site functions and performs, customizes your interaction with our Site, and helps provide more relevant messaging and marketing communications to you.   

Advertising: Advertising cookies and other similar technologies are used by us to enable us to understand your interests and tailor marketing to you and your interests and provide you with a more personalized service.  These cookies remember that you visited our Site and we may share this information with third-parties, such as advertising platforms, so that we can show you relevant offers and direct personalized advertising to you.  We may also use these cookies to target and re-target visitors to our Site with digital advertising that is most relevant to the user.  These cookies are also used to limit the number of times you see an advertisement or particular content, as well as help measure the effectiveness of an advertising or marketing campaign.

We do not control third parties’ collection or use of your information to serve interest-based advertising.  However, these third parties may provide you with ways to choose not to have your information collected or used in this way.  You can read more about how companies use cookies to conduct targeted or retargeted advertising, and ways to opt-out of receiving targeted ads from members of the National Advertising Initiative (“NAI”) on its website at: www.networkadvertising.org.  We do not set advertising cookies through our merchants’ storefronts ourselves, though merchants may choose to do so independently.

Social Media: Finally, Social and Content cookies are placed by many social media plugins (for example the Facebook ’like’ button), and other tools meant to provide or improve the content on a website (for example services that allow the playing of video files, or that create comments sections). We integrate these modules into our Site to improve the experience of browsing and interacting with our Site. Please note that some of these third-party services place cookies that are also used for things like behavioral advertising, analytics, and/or market research. If you would like more detailed information about first party and third-party cookies in use on or related to the Website, please contact us. You may also learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/.

We also use third-party digital tracking technologies and receive data from such technologies including, but not limited to, the following:

Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and to better understand how they find and use the Site. The data collected includes data related to your device/browser, your IP address, and on-site activities, such as what pages were visited or how often, to measure and report statistics about user interactions. The information stored is reduced to a random identifier. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting:

https://www.google.com/policies/privacy/partners/and https://support.google.com/analytics/answer/6004245.

You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy located at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page located at https://support.google.com/analytics/answer/181881?hl=en.

Google Tag Manager. We may use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) does not use cookies and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal information under certain circumstances. Google Tag Manager does not access this information.  Google Tag Manager is subject to the Google Privacy Policy located at: https://www.google.com/intl/en/policies/privacy.

Meta Pixel. We may use Meta Pixel to customize and display advertisements only to Facebook users who have shown an interest in our Site or who have specific characteristics (e.g., certain demographics or interests in certain topics or products determined by websites visited) that we submit to Facebook.  The use of Meta Pixel helps ensure that our advertisements are in line with the potential interests of users and do not have a nuisance effect.  Meta Pixel also allows us to track the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether uses have been redirected to our Site after clicking on a Facebook advertisement.   The Meta Pixel is directly integrated into our Site by Meta and can store a cookie on your device.  The information collected about you is anonymous for us.  However, the information collected via the Meta Pixel, on the Site as well as other websites on which Meta Pixel is installed, is also stored and processed by Meta.  Meta may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy.

To understand more about Facebook advertising please visit: https://www.facebook.com/about/ads.  You may deactivate Meta Pixel via the Cookie Settings on Facebook.  The Settings are located at the bottom of the main page for logged in users at: https://www.facebook.com/settings/?tab=ads#.

How Do Our Advertising and Marketing Partners Use Cookies for Interest-Based Advertising?

We may use third parties such as advertising networks and other content providers to serve targeted ads on our Site and on other websites like social media sites.  This practice is referred to as interest-based advertising or cross-context behavioral advertising.  These advertising networks and/or content providers may use cookies and similar tracking technologies to uniquely distinguish you, your web browser, or your device and report certain information about your visits to our Site and other websites (e.g., web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant to you, both on and off the Site and across your devices, including on social media sites.  This information may also be used to evaluate our online advertising campaigns. 

Some third parties may use data collection technologies to collect information from our Site and combine it with other information they have collected relating to your web browser’s activities across their network of websites, where permitted.  We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.  Please see examples of the opt-outs offered below.

How Can You Opt-Out from Interest-Based Advertising?

There are a variety of methods available to you to opt-out of certain third-party tracking technologies, including using tools provided within your device, browser, or the settings menu within a mobile application which may include an option that allows you to refuse the placement of certain tracking technologies.  Some advertising networks we may use for these purposes may be members of the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”).  Please visit the websites below to learn more about interest-based advertising and to opt out of receiving personalized advertising or content from participating third-party advertising companies:

Digital Advertising Alliance: https://optout.aboutads.info/?lang=EN&c=2#!%2F

National Advertising Initiative: https://optout.networkadvertising.org/?c=1#!%2F

Please note that if you opt-out, you may still receive online advertising from us, but it will not be tailored to your interests based on online behavioral information about you.  To successfully opt-out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them).  Your opt-out only applies to the web browser you use, so you must opt-out of each web browser on each computer you use.  Once you opt-out, if you delete your browser’s saved cookies, you will need to opt-out again. 

Other Third-Party Technologies

Some third parties may use data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

Choices About Cookies

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being stored. These settings may affect your enjoyment of the Site’s and App’s functionality. Adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings.

The links below provide additional information about how to disable cookies or manage the cookie settings.  PLEASE NOTE: These third-party links are provided for your convenience and we may not actively monitor the content of these links.

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies

Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265

For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at https://youradchoices.com/control, https://thenai.org/about-online-advertising/faq, and http://www.networkadvertising.org/choices.

6. CHATBOT TECHNOLOGY

            We may use chatbots to help provide customer service and support, including the use of a virtual assistant.  A chatbot is a software application that mimics human conversations in text or voice interactions on our Site or App.  It enables the communication between a human and a machine, which can take the form of messages or voice commands.  The chatbot is designed to work without the assistance of a human operator and is designed to respond to questions posed to it in natural language as if it were a real person using a combination of pre-programmed scripts and machine learning algorithms.  While a chatbot aims to offer accurate and helpful responses, its information may not always be exhaustive, up-to-date, or tailored to individual circumstances. If you use a chatbot on our Site or App, we will collect any personal information you provide to us.  We will also create and store a transcript of your chat interaction with us which will be shared and stored with our third-party service provider for the chatbot service.  We use these transcripts for quality control, customer service, fraud prevention, and security.  We do not assume any liability for actions taken based on the chatbot’s responses.  By using our Site, App, or Services and our chatbot, you acknowledge and agree to these terms.

7. Visual Materials and Consent to Collect, Use, and Disclose Video Viewing History

The Site and App may display live or prerecorded videos or similar audio-visual materials (“Videos”).  We are not in the business of delivering audiovisual materials.  Rather, the display and use of Videos on the Site and App is incidental to our business and merely a peripheral part of our marketing strategy.  The provision of Videos on our Site and App is not an admission by TEL and it shall not otherwise be interpreted, in any form or manner, to mean that TEL is a “video tape service provider” for purposes of the Video Privacy Protection Act (codified as amended at 18 U.S. Code § 2710) (the “VPPA”) or that TEL is otherwise subject to the VPPA.

We may collect personal information with respect to you viewing, streaming, or otherwise accessing such Videos and we may disclose such personal information regarding your video-viewing history on the Site and App to third parties through the use of cookies, pixels, or other tracking technologies, to facilitate or assist with our marketing and advertising campaigns. By viewing, streaming, or otherwise accessing Videos on the Site or the App, you hereby acknowledge, agree, and consent to our collection, use, and disclosure of such personal information regarding your video-viewing history on the Site and/or App.

8. RETENTION OF PERSONAL INFORMATION

We retain and use your personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements.

We take reasonable steps to delete the personal information we collet when: (1) we have a legal obligation to do so; (2) we no longer have a purpose for retaining the information; or (3) if you ask us to delete your personal information unless we determine that doing so would violate our existing, legitimate, legal, regulatory, dispute resolution, contractual, or similar obligations.  We may also delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

We may retain and use anonymous, de-identified, and/or aggregated information for as long as is permitted under applicable law.

9. SECURITY AND PROTECTION OF PERSONAL INFORMATION

We recognize the importance of safeguarding your personal information and we endeavor to maintain reasonable and appropriate physical, technical, and organizational safeguards to protect your personal information against accidental loss and unauthorized access, use, alteration, or disclosure, and to detect fraudulent identity verification activity and mitigate risks concerning your personal information.

While our security measures seek to protect your information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the Site, App, or otherwise through our Services.  Where you use a password for access to restricted parts of our Site or App, you are responsible for keeping your password confidential.  Do not share your password with anyone. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site, App, and Services.

10. YOUR RIGHTS AND CHOICES REGARDING YOUR PERSONAL INFORMATION

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor requests when we are required to do so under applicable law.

Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails, and you may opt-out of other communications by contacting us via the “Contact Us” details at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process.  Once we receive your instruction, we will promptly take corrective action.

Text Messages (SMS) Opt-Out.  We may ask for your consent to receive text messages (including messages related to the Services or transaction requested by you or our other products or Services that may be of interest to you).  Certain text messages may be sent by automated systems or technology.  You may unsubscribe from marketing text messages at any time by replying STOP or clicking the unsubscribe link (where available) in the text messages. 

Cookies and Other Tracking Technologies: You may be able to set your browser to refuse all or some browser cookies or to alert you when cookies are being sent.  You may also adjust your cookie preferences by using the cookies consent banner, if available.  You can also opt-out of these technologies (unless they are essential for the operation of the Site and App) by contacting us via the “Contact Us” details at the end of this Policy and providing your name and email address so that we may identify you in the opt-out process.  Once we receive your instruction, we will promptly take corrective action.

Accuracy and Updating Your Information. Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please update it in your user/account profile, or let us know via the “Contact Us” details at the end of this Policy. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete personal information that you provide to us.

Do Not Track.  Some web browsers may transmit “do not track” signals to the websites and other online services with which the browser communicates.  We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

California Residents. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once each calendar year information about the information we shared, if any, with other businesses for direct marketing uses. We do not currently share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by California’s “Shine the Light” requirements, and only information regarding covered sharing (if any) will be included in our response. As a part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at tel.legal@tel360.com.

Nevada Residents. Nevada residents have the right to submit a verified request to an operator (as defined by Nevada law) directing the operator not to make any sale (as defined by Nevada law) of any covered information (as defined by Nevada law) that the operator has collected or will collect about the Nevada consumer.

As defined under Nevada law, we do not sell any covered information. Nor do we have any plans to do so in the future. However, Nevada residents may submit a verified request to us at any time at tel.legal@tel360.com directing that we not make any sale of covered information that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.

11. INDIVIDUAL RIGHTS

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

To the extent you are a resident of certain U.S. states with comprehensive state privacy laws, you may be eligible for one or more of the following consumer rights where authorized by applicable U.S. state privacy laws.  This section provides an overview of these rights which we honor where required by applicable law:

• Right to Access.Subject to certain conditions set forth in the applicable U.S. state privacy laws, you have the right to know and see what personal information we have collected about you and receive a copy of such information in a portable format, purposes for which we collect your personal information, recipients of your personal information to whom we disclose or share, which in some states may include categories of personal information collected, categories of sources of collection, business or commercial purposes for data processing, and categories of third parties with whom we disclose that information. 
• Right to Correct.Subject to certain conditions and exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we correct any inaccurate personal information that we have collected about you.
• Right to Delete.Subject to certain conditions and exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we delete the personal information we have collected about you.
• Rights Regarding Sensitive Data. We only process sensitive data with your consent or where otherwise permitted by applicable law. Where you have provided consent to this processing, you may revoke your consent or opt out of the processing of your sensitive data at any time. For residents of California, this includes your CCPA right to limit the processing of sensitive personal information to that processing permitted by the CCPA.
• Right to Opt-Out.Residents of certain states have the right to direct us to stop selling, and for residents of California, sharing, your personal information to third parties and to refrain from doing so in the future. Residents of certain states also have the right to opt out of targeted advertising and profiling based on your personal information.
• Right to Non-Discrimination. You have the right not to be discriminated against for exercising any of your rights under any applicable U.S. state privacy laws.
• Right to Appeal. To the extent the applicable U.S. state privacy laws provide such rights, you may appeal our denial to act on your consumer rights under the applicable state privacy laws within a reasonable time. We will respond within designated period for responding to U.S. data subject requests and may exercise the right to extend this response period (to the extent authorized by applicable state privacy laws).

How to Exercise Your Rights

Submission Process

You may submit a request to exercise one of the above rights by calling (423)214-3910, emailing tel.legal@tel360.com, or through the online submission form on our Site. If a request is submitted in an incorrect manner or if it is deficient, we will either: (1) treat the request as if it had been submitted via the designated manner; or (2) provide you with specific directions on how to submit the request or remedy any deficiencies, as applicable.

Verification Process

We are required to verify the identities of those who submit requests to exercise certain of the above rights. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, email address, address, and/or telephone number. We will inform you if we cannot verify your identity.

If we cannot verify the identity of the person making a request, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.  If we cannot verify the identity of the person making the request, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.

If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor. In such cases we may not be required to comply with the request or may request additional information reasonably necessary to verify the request.

Authorized Agents

Authorized agents may submit requests via the methods identified above. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and/or (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we may not require these actions with respect to confirmed guardianship, conservatorship, power of attorney, or other protective arrangement in accordance with applicable law.

Non-Discrimination

You have the right not to receive discriminatory treatment by us due to your exercise of any of the above rights. However, we may still offer business customers certain financial incentives permitted under applicable law, such as rewards, premium features, loyalty accounts, or club card programs that can result in different prices, rates, or quality levels.

Excessive Requests

If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive nature, we may either: (1) charge a reasonable fee; or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Appeals Process

Residents of certain states have the right to appeal a refusal to take action on a request within a reasonable time after your receipt of the decision. If your request is denied, you may appeal our decision by contacting us at tel.legal@tel360.com and attaching both the original communication from us explaining why we were unable to fulfill your request, as well as your response to the reasons stated for our denial in the original communication. We will respond to your appeal within the time required by applicable law.

12. CALIFORNIA RESIDENTS

All terms used in this section shall have the meanings given in the California Consumer Privacy Act (“CCPA”), where applicable.

CCPA Notice at Collection

We collect and process personal information as described in the above Personal Information We Collect & How We Use Personal Information section of this Policy. The relevant CCPA categories for this information are listed below. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes.

Category	CCPA Categories
Contact Information	For purposes of the CCPA, Contact Information includes the following categories of personal information: ·       Identifiers ·       Categories Described in the Customer Records Statute
Communications and Inquiries	For purposes of the CCPA, Communications and Inquiries includes the following categories of personal information: ·       Identifiers ·       Categories Described in the Customer Records Statute ·       Commercial Information ·       Audio, Electronic, Visual, or Similar Information ·       Professional or Employment-Related Information
Order and Payment Information	For purposes of the CCPA, Order and Payment Information includes the following categories of personal information: ·       Identifiers ·       Categories Described in the Customer Records Statute ·       Commercial Information ·       Audio, Electronic, Visual, or Similar Information
Business Information	For purposes of the CCPA, Order and Payment Information includes the following categories of personal information: ·       Identifiers ·       Categories Described in the Customer Records Statute ·       Commercial Information ·       Audio, Electronic, Visual, or Similar Information ·       Professional or Employment-Related Information
Cookies and Similar Technologies	For purposes of the CCPA, Cookies and Similar Technologies includes the following categories of personal information: ·       Identifiers ·       Internet or Other Electronic Network Activity Information ·       Geolocation Data
Device and Usage Information	For purposes of the CCPA, Device and Usage Information includes the following categories of personal information: ·       Identifiers ·       Internet or Other Electronic Network Activity Information ·       Geolocation Data
Location Information	For purposes of the CCPA, Location Information includes the following categories of personal information: ·       Identifiers ·       Internet or Other Electronic Network Activity Information ·       Geolocation Data

Data Practices During the Last 12 Months

The disclosures below describe our data practices during the last twelve months.

Personal Information Collected: We may have collected the following categories of personal information during the preceding 12 months:

• Identifiers
• Categories of Personal Information Described in the California Customer Records Statute
• Commercial Information
• Internet or Other Electronic Network Activity Information
• Professional or Employment-Related Information
• Education Information
• Geolocation Data
• Audio, Electronic, Visual, Thermal, or Similar Information
• Sensitive Information

Categories of Sources. We have collected the personal information identified in this Policy from you.

Business and Commercial Purposes for Collection/Selling/Sharing/Disclosing. We may have collected, sold, shared, or disclosed the categories of personal information identified above for the following purposes:

• to operate our Site and business;
• to provide our products and services to you;
• to provide customer support;
• to ensure the privacy and security of our Site, products, and services;
• to administer promotions, contests, surveys, and other customer engagement features;
• to maintain our databases and back-ups;
• to manage our relationships with you;
• to serve you the content and functionality you request;
• to enhance your experience and provide you with a more personal and interactive experience;
• to communicate with you;
• to keep records of our communications with you;
• to determine user interests;
• to develop new products and services;
• for usage analytics purposes;
• to process and complete payments and other transactions, including refunds, returns or, payment of eligible warranty claims;
• to detect fraud and prevent loss;
• for recruitment or human resources purposes;
• to carry out our obligations under employment law, for the performance of the employment relationship, or as permitted by applicable law;
• to facilitate reimbursements and to prevent fraudulent payments;
• to manage the applicable marketing and advertising platform and provide related electronic commerce products and services;
• to monitor, process, and support transactions;
• to comply with legal or regulatory obligations applicable to the processing and retention of payment data; and
• to improve products and services.

Personal Information Sold, Shared, or Disclosed. We may have sold, shared, or disclosed the following categories of personal information, including for a business purpose, during the preceding 12 months:

• Identifiers
• Categories of Personal Information Described in the California Customer Records Statute
• Commercial Information
• Internet or Other Electronic Network Activity Information
• Professional or Employment-Related Information
• Education Information
• Geolocation Data
• Audio, Electronic, Visual, Thermal, or Similar Information
• Sensitive Information

We may have sold or shared each category of personal information identified above to the following categories of third parties: (1) subsidiaries and affiliates; (2) distribution partners; (3) advisors (accountants, attorneys); (4) service providers and contractors (data analytics, data storage, mailing, marketing, shipping fulfillment, payment processing, Site administration, technical support); and (5) operating systems and platforms.

We do not knowingly sell or share the personal information of consumers under 16 years of age.

Financial Incentives. We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your Personal Information.

13. RESIDENTS OF MEXICO

If you are located in Mexico, you have the following rights under the Federal Law on the Protection of Personal Data Held by Private Parties (“LFPDP”). All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.  We store your Personal Information in the United States and may be subject to United States laws, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies in the United States, pursuant to applicable law.  By using our App and Site, you consent to the collection, storage, and processing of your information in the United States and in any country to which we may transfer your information in the course of our business operations. All of our service providers are required to maintain the confidentiality and security of your personal information and to use it only in compliance with applicable data privacy laws and are prohibited from using or disclosing your personal information for any purpose other than providing the services on our behalf or as otherwise required by applicable law.

Right of Access. To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.

Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.

Right to Cancellation. In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the personal information has been unlawfully processed, (5) the personal data have to be erased for compliance with a legal obligation; and (6) the personal data were collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases as well as the App and Site but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.

Right to Object. In certain circumstances, you have the right to object to the processing of your personal information where (1) your situation so requires in order to avoid damage to you, or (2) required to declare your objection or revocation of consent, to avoid processing for specific purposes.

Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.

Process. You or your representative may establish your legal right to exercise the above rights by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, email address, address, and telephone number. Within 20 days of your request, we will provide you notice of our determination regarding your ability to exercise these rights. We will then act as required under your exercise of rights within the time frame required by law. Where applicable, we will provide a copy of your personal information in compliance with applicable law.

14. INTERNATIONAL DATA TRANSFERS

Personal Information collected by TEL 360 in one country may be transferred to, stored, or processed in another country, the data protection, privacy and other laws of which might not be as protective or comprehensive as those in your country. TEL 360 also may share Personal Information with organizations and entities that perform services on its behalf, and these organizations and entities may be located in countries other than the country in which the Personal Information was first collected.  TEL 360 will endeavor to obtain appropriate and reasonably enforceable assurances from third parties, including its subsidiaries and affiliates, to which it discloses or transfers Personal Information that these third parties will safeguard Personal Information in a manner consistent with this Policy.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to these transfers.

15. THIRD-PARTY SITES

This Policy only applies to the Site, App, and Services, and it does not apply to any third-party websites or applications.

The Site or App may contain links to, and media or other content from, third parties. These links are to external resources and third parties that have their own privacy policies. Because of the dynamic media capabilities of the Site and App, it may not be clear to you which links are to external, third-party resources. If you click on an embedded third-party link, you will be redirected away from the Site or App to the external third-party website. You can check the URL to confirm that you have left the Site or App.

We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on the Site or App.

Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use.

16. CHILDREN’S PRIVACY

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet.    Our Site, App, and Services are not directed to children under the age of 13, nor is information knowingly collected from children under the age of 13.  No one under the age of 13 may access, browse, or use the Site or App or provide any information to us.  If you are under 13, please do not use or provide any information on the Site or App (including, for example, your name, telephone number, or email address).  If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 13, please contact us via the “Contact Us” details provided at the end of this Policy.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

17. UPDATES AND CHANGES TO THIS POLICY

We may add to, change, update, or modify this Privacy Policy from time to time.  Should this Privacy Policy change, we will post all changes to this Privacy Policy on this page and any such changes, updates, or modifications will be effective immediately upon posting. If we make material changes, we will also notify you through a notice on the homepage of the Site and App for a reasonable period of time.  We may also, in our discretion, notify you of changes to this Privacy Policy via email.  The date on which this Privacy Policy was last modified is identified at the beginning of this Privacy Policy.

You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site and App, and from time to time, so that you are aware of any changes. Your continued use of the Site and App after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your information according to the terms of the then-current Privacy Policy.  If you do not agree with this Policy and our practices, you should not use the Site or App.

18. CONTACT US

For more information, or if you have any questions or concerns regarding this Privacy Policy, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail.

In Writing: Transport Enterprise Leasing, LLC

                Attn: Legal

               400 Birmingham Hwy
               Suite 350
               Chattanooga, TN 37419

               United States

By Email:  tel.legal@tel360.co