Last Updated: October 13, 2022

This privacy policy is to inform you of the privacy practices on the collection, use, sharing, and processing of data by True Fuel, a division of Tenstreet, LLC., (“True Fuel“) related to its partnership with Trimble, Inc. and its affiliates (“Trimble”) in providing fuel optimization services.

This Privacy Policy applies only to information collected on the True Fuel application which runs on the Trimble offerings and services. The data collected, used, shared, and processed is related to the use of the Trimble offerings and services by a company through which you are employed or contracted (“Employer”). The Employer has contracted with Trimble for the provision of the True Fuel services which are provided by True Fuel through the application.

All the personal information collected, used, and processed by True Fuel has been provided by Employer to Trimble and then to True Fuel. This Privacy Policy does not cover the Employer’s handling of your personal information. True Fuel does not share your personal information with any parties other than Trimble and Employer, except in limited circumstances as set forth herein. Please refer to the Employer’s privacy policy or contact the Employer with any questions about the Employer’s use and disclosure of your personal information. Please refer to Trimble’s privacy policy or contact Trimble with questions about Trimble’s use and disclosure of your personal information.

If you are a customer of True Fuel or a user of the True Fuel Trimble Services (“Client”), the terms governing the use of your data are governed by the Agreement with Trimble and our Terms of Service.

This True Fuel Trimble Privacy Policy is intended for a U.S. or Canadian audience. Any information collected, used, shared, or processed by True Fuel via Trimble’s offerings, including any personal information, will be transferred to, and processed by, a computer server located within the United States and will be handled in accordance with this Privacy Policy.

True Fuel does not control the privacy practices of any third-party and is not responsible for any information they may collect. The information collection practices of any third party are not governed by this privacy policy but by the privacy policies and/or practices of other third parties. We recommend that you read the applicable privacy policy for information as to other third party sites.

1. WHAT INFORMATION WE COLLECT

   We collect many types of information from and related to the vehicle and the operation of the vehicle. We collect personal information provided from your Employer via Trimble offerings including your Employer, your name, your email address, the location of the vehicle utilizing the True Fuel services and therefore your location if you are in the vehicle, behavioral information related to your operation of a vehicle, and your interaction with the True Fuel services. If applicable, we may collect information from the Employer about points awarded in any applicable rewards program.

2. HOW WE USE THE INFORMATION WE COLLECT

   We use the information we collect to provide services our customers. Trip level data from the vehicle is used to analyze fuel usage, including trip level assessment of fuel usage and waste, for purposes of fuel optimization. Personal Information is used to associate you with the trip data for analyzing and optimizing fuel usage as well as for offering account management services to you and your Employer. The association of you with the trip data is a part of the service provided to your Employer allowing your Employer to understand your performance and coaching needs.

   Some specific ways in how we use information, includes:

   • Assess fuel performance at the trip level on each truck
   • Provide useful fuel analytics for assessing driver and truck performance
   • Assisting clients with useful coaching data to improve driver performance
   • Provide controlled access to fuel metrics for fleet clients and drivers
   • Reports that allow fleets to understand at a high level the causes of their fuel spend
   • Responding to questions and feedback
   • Continuously evaluating and improving the online user experience
   • Troubleshooting technical problems on the Tenstreet True Fuel Platform
     
     
     

   Data Retention
   We retain all information, including personal information as required by law.

3. HOW WE SHARE THE PERSONAL INFORMATION WE COLLECT

   We do not rent, lease, or sell your personal information to third parties. The following are some of the ways we share your information:

   • The Employer: As noted above, we share information, including personal information, collected through the True Fuel services with your Employer to provide the True Fuel services.
   • Trimble: We provide information, including personal information, collected through the True Fuel services to Trimble as a part of the services agreed upon.
   • Third-Party Service Providers: We may share your personal information with third-party service providers under contract with True Fuel to help us provide services to you and our Clients. The following are some examples of the types of third-party service providers with which we may share your personal information and our purpose for doing so:
     • Reward Redemptions: If the Employer uses the Tenstreet Platform for its rewards program, we may disclose your personal information to third-party service providers related to ordering and shipping merchandise in fulfillment of the rewards program.
     • Data Analytics: We may retain third-party service providers to help us perform data analytics.
     • Legal Advice: We may disclose your personal information to an attorney in the process of obtaining legal advice.

     We require these third-party service providers, by written agreement, to provide safeguards for your personal information similar to the ones that we provide.

   • Aggregated data. We may share aggregated data with third parties when the data has been de-identified or otherwise anonymized in such a manner that the information would not be able to identify you.
   • Required Disclosures: We may be required to share personal information in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
   • Legal Compliance and Protections: We may disclose account and other personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of True Fuel, our users, or others. This includes exchanging personal information with other companies and organizations for fraud protection and credit risk reduction.
   • Corporate Transactions: We reserve the right to disclose and transfer your information, including your personal information:
     • To a subsequent owner, co-owner, or operator of True Fuel or successor database.
     • In connection with a corporate merger, consolidation, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

     
     
     
     

   CHILDREN’S ONLINE PRIVACY PROTECTION ACT COMPLIANCE
   We do not collect any information from anyone under 13 years of age. The True Fuel products and services are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorized to use the True Fuel Trimble app or services.

4. HOW WE PROTECT THE PERSONAL INFORMATION WE COLLECT

   The security and confidentiality of your personal information is important to us. We have technical, administrative, and physical security measures in place to protect your personal information from unauthorized access or disclosure and improper use. We have a comprehensive written information security program that complies with applicable law and generally accepted industry standards.

   For example, we use TLS encryption to protect the data collection forms on our website. In addition, access to your personal information is restricted in our offices. Only employees who need the personal information to perform a specific job (for example, a customer service representative) are granted access to personal information. Employees with access to personal information are kept up-to-date on our security and privacy practices.

   Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the security of your personal information.

5. REGION-SPECIFIC INFORMATION

   1. INFORMATION SPECIFIC TO CALIFORNIA RESIDENTS

      Assistance For The Disabled
      Alternative formats of this Section 5.A are available to individuals with a disability. Please contact 585-377-9700 or [email protected] for assistance.

      Scope:
      This Section 5.A only applies to the personal information of residents of the U.S. state of California in their capacity as consumers (“California consumers”).

      “California consumer” does NOT include:

      • Individuals in their capacity as human resources with respect to True Fuel, e.g., employees who work at True Fuel, Tenstreet, or applicants to jobs at True Fuel or Tenstreet (collectively, “HR individuals”);
      • Individuals in their capacity as emergency contacts, dependents, or beneficiaries of HR individuals;
      • Individuals in their capacity as employees, contractors, or other agents of True Fuel partners, service providers, or vendors; or
      • Individuals whose personal information is handled by True Fuel purely in its capacity as a service agent of its customers.
        
        

      This Section 5.A applies to all personal information of California consumers collected or disclosed for business purposes by True Fuel, regardless of whether the personal information is collected or disclosed through True Fuel’s website. As set out below, True Fuel does not sell California consumers’ personal information.

      1. How We Collect the Personal Information of California Consumers
         

         Categories Of Personal Information Collected In The Last 12 Months	Sources of Personal Information	Business Purposes and Commercial Purposes For Collecting Personal Information
         Identifiers: real name, email addressProvided directly from Employer through Trimble. Providing services for True Fuel’s clients. Analyze fuel usage, including trip level assessment of fuel usage and waste, for purposes of fuel optimization. Associate driver with the trip data for analyzing and optimizing fuel usage. Offering account management services to drivers and customers. Providing Employer with driver performance and coaching needs.
         Professional or employment-related information: name and address of current employers.
         Internet or other electronic network activity information: frequency of visits to the app, behavior in operation of the vehicle.

      2. How We Share The Personal Information Of California Consumers

         Categories Of Personal Information Collected In The Last 12 MonthsCategories Of Third Parties With Which Tenstreet Shared That Personal Information For all categories: Tenstreet may disclose personal information to government agencies, law enforcement, and other parties as required by law and as necessary to protect the rights, property, or safety of True Fuel, its subsidiaries or affiliates, employees, customers, users, and public at large. Tenstreet also discloses Personal Information to vendors and service providers, as necessary for the business and commercial purposes listed above.
         Categories described in Cal. Civ. Code § 1798.80(e) (except those already listed in “Identifiers” above)	Employer and Trimble
         Internet or other electronic network activity information	Employer and Trimble

         Disclosure of Personal Information for a Business Purpose or a Commercial Purpose: True Fuel discloses all the categories of Personal Information in the table above for a business purpose or a commercial purpose.

         Sale of Personal Information: In the last 12 months, True Fuel has NOT sold California consumers’ personal information and True Fuel will not sell California consumers’ personal information. True Fuel does not sell the personal information of minors under 16 years of age.

      3. Your California Privacy Rights and How To Exercise Them
         • Your California Privacy Rights
           • Right to Know: Subject to applicable law, California consumers have the right to submit a verifiable request to know what personal information True Fuel collects, uses, and discloses. As noted above, True Fuel did not sell California consumers’ personal information during the last 12 months and will not do so.
           • Right To Delete: Subject to applicable law, California consumers have the right to submit a verifiable request for deletion of their personal information that True Fuel has collected or maintains.
           • Right to Opt Out of Sale: California consumers have the right to opt out of the sale of their personal information. California consumers under the age of 16 must opt in to the sale of their personal information, or their parent or guardian must opt in on their behalf. As noted above, True Fuel did not sell California consumers’ personal information during the past 12 months and will not do so.
             
             
         • How to Exercise Your Rights
           True Fuel will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California consumers can exercise their rights to know and to delete in the following ways:
           • Contact 585-377-9700 or [email protected].

         • How We Will Verify Your Request:

           The processes that we follow to verify your identity when you make a request to know or a request to delete are described below.

           1. Requests To Know Categories Or Purposes: If you request to categories of Personal Information collected, sources, sales, or True Fuel’s business or commercial purposes for use of your Personal Information, we will match at least two data points that you provide with your request to know, or in response to our request for verification information, against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. Examples of relevant data points include your name, email address, and Employer.
           2. Requests To Know Specific Pieces Of Personal Information: We will match at least two data points that you provide with your request to know, or in response to our request for verification information, against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we may require you to sign a declaration under penalty of perjury that you are the California consumer whose personal information is the subject of the request.
           3. Requests To Delete Personal Information: We will require a match of two data points as described in Point No. 1, above.
              
              

           We have implemented the following additional procedures when verifying the identity of requestors:

           1. If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will permanently delete the verification information that you provide promptly after we have completed the verification process. We will not use that information for any purpose other than verification
           2. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.
              
              
         • Authorized Agents

           You may designate an authorized agent to exercise your right to know or your right to delete by submitting to us a completed “Authorized Agent Designation” form.

           If an authorized agent submits a request to know or a request to delete on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity.

         • Tenstreet’s Non-Discrimination Policy

           California consumers have the right not to be subject to discriminatory treatment by True Fuel for exercising their privacy rights under the California Consumer Privacy Act, and True Fuel will not discriminate on that basis.

   2. INFORMATION SPECIFIC TO USERS IN CANADA

      You may contact us by email at [email protected] or by telephone at 585-377-9700 to access, correct or delete your personal information. Please note that although True Fuel can provide access or correct or delete its copy, if any, of your personal information in response to your request, True Fuel cannot provide access or correct or delete personal information that it maintains on behalf of the Employer. Please contact the Employer directly to request the access to or correction or deletion of the Employer’s copy of your personal information.

      True Fuel’s Executive Vice President of Operations manages our privacy program and can be reached at [email protected].

6. HAVE QUESTIONS?

   If you have any questions about this Privacy Policy, we’ll do our best to answer them promptly. Here’s how to contact us:

   • Tenstreet, LLC
     Attn: Consumer Department
     120 W. 3rd Street
     Tulsa, OK 74103
   • Email: [email protected]
   • Toll free Telephone Number: 877-219-9283, option 1
     
     

7. PRIVACY POLICY UPDATES

   If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal information, we will notify you by prominently posting a notice of such changes before making them and by stating the effective date of the changes.