Privacy Policy
What we do
ORIGOInspect and ORIGOTrack are products of Mill Mountain Capital, LLC d/b/a ORIGO (collectively the “Company”). This privacy policy explains how the Company uses the personal data we collect from you when you access our website, application software, use one of the Company’s devices or access the Company’s software and information by other portals provided by the Company.
This Privacy Policy is effective as of January 7, 2021 and is subject to change as noted below.
This Privacy Policy is applicable to all means of entry when you access any information, website or application software of the Company or use any device sold or provided by the Company.
Topics:
1. What data do we collect?
2. How do we collect your data?
3. How will we use your data?
4. How do we store your data?
5. Marketing
6. What are your data protection rights?
7. What are cookies?
8. How do we use cookies?
9. What types of cookies do we use?
10. How to manage your cookies
11. Privacy Policies of other websites
12. Changes to our privacy policy
13. How to contact us
14. How to contact the appropriate authorities
15. Law Enforcement and Protection of Users
16. Business Transfer
17. No Guarantee of Continued Availability
18. Children’s Online Policy
19. Governing Law
20. Security
21. Protection of IP Rights
22. European Economic Area Provisions
23. California Consumer Privacy Acts Disclosures
1. What do we collect?
The Company collects the following data:
Information you give us: ORIGO collects any information, which you enter on our Web site or enter into any ORIGO application. This information is normally provided when you search, buy, participate in a contest, sweepstakes or on-line survey, or when you communicate with any of our departments such as customer service, sales or technical services through our Web site, telephone, mail or fax. You also provide information when you establish an account with us. Examples of the type of information you may supply us with include your name, address, telephone number, and e-mail addresses.
Automatic Information from Web site collected by us: Whenever you visit our Web site we collect and store information such as “cookies” which remember information about a visitor from one page to the next and from one visit to the next. We collect and analyze the IP address used to connect your computer to the Internet; login; password; computer and connection information such as your browser type and version; operating system and platform; purchase history; confirmation when you open e-mail that we send you; the URLs which lead you to and around our Web site and other sites on the World Wide Web, including the date and time; the pages and or products you viewed or searched for and the phone number used to call our voice telephone numbers. Your browser allows you to reject cookies, and software is available from third parties that can allow you to visit our Web site without providing this information. You are welcomed at our Web site if you use this software, but we will not be able to offer you our personalized services.
Orders: If you place an order we use a secure order form, which requires you to provide contact, billing, and financial information. This information is transmitted to your credit card company to authorize your purchase. Orders placed from California comply with California collection and use of personally identifiable information laws. All orders placed on the website are governed by ORIGO’s Standard Terms and Conditions which can be found here.
Device and Vehicle Data: If you drive a vehicle connected to an ORIGO device, we may receive personal data about you to the extent you provide such personal data to us or to the extent the ORIGO device sends personal data to us. To the extent that personal data about you may be inferred from technical vehicle information collected from an ORIGO device, we process such personal data in accordance with this Policy.
ORIGO devices include a software platform and a physical hardware device to enable Customers to collect vehicle data. The physical hardware device is installed into a vehicle’s on-board diagnostic port (also called the OBDII port) that facilitates the extraction of data about the vehicle and its use. Any data that is temporarily stored on the device is encrypted. The vehicle data on a device is then transmitted to ORIGO’s servers, or a server of a third party working with ORIGO, through secured wireless telecommunications networks and stored on encrypted cloud servers, in accordance with the applicable providers’ respective privacy, data handling and data usage policies. For more information, see the ORIGO End User License. To the extent such data includes personal data about you, we only use such data at the direction of the Customer who uses the software to collect personal data about you.
2. How do we collect your data?
You directly provide the Company with most of the data we collect. We collect data and process data when you:
a. Register online or place an order for any of our products or services.
b Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
c. Use or view our website via your browser’s cookies.
d. Use a mobile device or a vehicle, or both, connected to an ORIGO device.
The Company may also receive your data indirectly from the following sources:
Device and Vehicle Data: If you drive a vehicle connected to a third party device that includes, or uses, an ORIGO device, we may receive personal data about you to the extent you provide such personal data to the third party device. To the extent that personal data about you may be inferred from technical vehicle information collected from a third party device, we process such personal data in accordance with this Policy.
3. How will we use your data?
The Company collects your data so that we can:
a. Process your order, manage your account.
b. Provide customer support for ORIGO applications.
c. Provide software updates for ORIGO applications.
If you agree, the Company will share your data with our partner companies so that they may offer you their products and services.
ORIGO may share information, including personal data, with our third party service providers that we engage for providing hosting, for maintenance of our websites, applications, backup, storage, payment processing, analytics, and other services. We do not allow our service providers with whom we share personal data to use that information for marketing or any other purpose other than in connection with the services they provide to ORIGO. See Exhibit A below for more information.
When the Company processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.
Independent Contractors: The Company employs other companies or individuals to provide certain services to us such as sending e-mail, providing click to call telephone-calling services, analyzing customer lists and data, providing marketing assistance, or consulting services. These third parties will have access to the information needed to perform their functions but cannot use that information for any direct marketing purpose.
Aggregate information: The Company provides aggregate information to some of our business partners. This information does not allow them to identify you individually.
Vendors: The Company provides some of our vendors with your contact information so that they may contact you directly with product support information. For example, we may supply your contact information to a Vendor if they request it in order to provide you with recall information about a product you have purchased from us.
Credit card companies, other Payors and shippers: When you buy something from us we send your credit card information, name, billing address and the amount of your purchase to your credit card company to verify and authorize the purchase. We will also send the same information (name, billing address and amount of your purchase) for other payment types which we may offer such as PayPal. Your name, telephone number and shipping information must be provided to third party shippers such as UPS, Freight companies, Federal Express and the United States Postal Service to deliver your purchase.
Third Party Checkout Links: If you use a third party checkout link on our site such as PayPal or BillMeLater your name, billing and shipping addresses and other information requested by that payment service is transferred to us from your account with the third party to enable you to check out of our site without having to re-enter certain information.
4. How do we store your data?
The Company securely stores your data on Amazon AWS servers with their proprietary security protocols.
The Company will keep your PII (Personally Identifiable Information) for up to 95 days. Once this time period has expired, we will delete your data by a daily purge routine.
5. Marketing
The Company would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies including: Geotab.
If you have agreed to receive marketing, you may always opt out at a later date.
You have the right at any time to stop the Company from contacting you for marketing purposes or giving your data to other members of the Company.
If you no longer wish to be contacted for marketing purposes, please click here.
6. What are your data protection rights?
7. What are cookies?
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information, When you visit our websites, we may collect information from you automatically through cookies or similar technology.
For further information, visit allaboutcookies.com
8. How do we use cookies?
The Company uses cookies in a range of ways to improve your experience on our website, including:
a. Keeping you signed in
b. Understanding how you use our website
9. What types of cookies do we use?
There are a number of different types of cookies, however, our website uses:
a. Functionality – The Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
b. Advertising — The Company uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. The Company sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website,
10. How to manage your cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser, However, in a few cases, some of our website features may not function as a result.
11. Privacy policies of other websites
The Company website may contain links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, then you should read their privacy policy.
12. Changes to our privacy policy
The Company keeps its privacy policy under regular review and places any updates on this web Page. This privacy policy was last updated on the 4th of April 2024. The Company retains all right and ability to update this Privacy Policy as needed.
13. How to contact us
14. How to contact the appropriate authority
Should you wish to report a complaint or if you feel that the Company has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office (in the European Union), the Federal Trade Commission (in the United States), your state Attorney General’s office or other designated state or country authority.
15. Law Enforcement and Protection of Users
We will release personally identifiable information to third parties and organizations when we believe it is appropriate for us to do so to comply with the law. We will also do so to cooperate with law enforcement investigations, comply with court orders or subpoenas, protect the legal rights of our users, and us or when we believe it is needed for fraud protection and/ or credit risk reduction.
16. Business Transfer
ORIGO has been in business independently for years, and our intent is to continue in this manner. However, in the unlikely event that ORIGO is sold, has substantially all of its assets acquired or merges or becomes affiliated with any other individual or entity any customer information owned or under the control of ORIGO may be one of the transferred assets.
17. No Guarantee of Continued Availability
ORIGO provides access to certain services and application software based, in part, on licenses from third parties. ORIGO does not guarantee that any of its application software will be available for any period or on a continuing basis. Third party licensors may revoke the licenses to ORIGO at any time, which could preclude certain services, application software or other information from being available in the future.
18. Children’s Online Policy
ORIGO is committed to the preservation of online privacy for all of its web site visitors, including children. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any personally identifiable information from children under the age of 13. ORIGO and Origosafety.com sells products intended for purchase by adults. If you make a purchase on Origosafety.com, you are representing that you are an adult. If you are a child under the age of 13, you must ask your parent or guardian to assist you in using Origosafety.com or any other products offered by ORIGO.
19. Governing Law
This privacy policy is governed by the laws of the Commonwealth of Virginia.
20. Security
Our Web site protects the security of personal information you transmit to us by using Secure Sockets Layer (SSL) software, which encrypts the information you input during the transmission to us. We do not reveal your credit card number when we confirm your order. In order to protect against unauthorized access to your account you should sign off when you finish visiting our site.
21. Grant of Non-Exclusive License to IP Rights
By posting messages, uploading files, inputting date or engaging in any other form of communication with the Company, you hereby grant to the Company a non-exclusive, royalty free, fully paid up, worldwide, irrevocable, unrestricted license, to use, copy, license, sublicense, adapt, distribute, display, publicly perform, reproduce, transmit, modify, edit and otherwise exploit any information that you provide to the Company.
22. European Economic Area Provisions
If you are located in the European Economic Area (EEA), ORIGO’s legal basis for processing the personal data we receive depends on the context in which it is provided to us. In our normal course of business, we will only process personal data that has been sent to us by you or our Customer through: our website, application software, use one of the Company’s devices or access the Company’s software and information by other portals provided by the Company. We will process the personal data sent to us where you have provided your consent (based on Art. 6 of the GDPR) to your data controller or where the processing of the information is necessary for the purposes of the legitimate interests pursued by the controller or by a third party and not overridden by your data protection interests or fundamental rights and freedoms (based on Art. 6 of the GDPR). We may also process your personal data where we have a legal obligation to collect and process personal data and are the controller in respect of such data (based on Art. 6 of the GDPR), or where the processing is necessary to protect your vital interests or that of another natural person (based on Art. 6 of the GDPR).
In circumstances where we rely on your consent to process the personal data, you have the right to withdraw your consent at any time. However, this may not affect the lawfulness of the processing based on the consent ORIGO has received prior to the withdrawal of consent.
If you provide ORIGO your personal data to comply with a legal requirement (e.g., Hours of Service) or to perform a contract (e.g., End User Agreement), we will make this clear to you at the relevant time. ORIGO recommends that Customers, users, and resellers take steps to minimize the personal data they ask ORIGO to process.
To the extent ORIGO is a controller of your personal data and you reside in the EEA, please note the following information. We may transmit some of your personal data to an international organization or a country where the data protection laws may not provide a level of protection equivalent to the laws in your jurisdiction. As required by applicable law, we will provide an adequate level of protection for your personal data using various means, including, where appropriate:
● relying on a formal decision by the European Commission that a certain country ensures an adequate level of protection for personal data (a full list of such decisions may be accessed online here);
● entering into appropriate data transfer agreements based on language approved by the European Commission, such as the Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC);
● implementing appropriate physical, technical and organizational security measures to protect Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing; and
● taking other measures to provide an adequate level of data protection in accordance with applicable law.
Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.
If you reside in the EEA or certain other jurisdictions, you have the right to exercise additional rights available to you under the local law that applies to you:
● Right of erasure: you may have a broader right to have personal data that we hold about you erased or deleted.
● Right to object to processing: you may have the right to request that ORIGO stop processing your personal data.
● Right to restrict processing: you may have the right to request that ORIGO limit the processing of your personal data in some circumstances (e.g. where you believe that the personal data we hold about you is inaccurate or was obtained unlawfully).
● Right to data portability: in some limited circumstances, you may have the right to receive a copy of your data in machine readable, commonly used format and to request that we transfer personal data to another controller.
Please contact us at info@origosafety.com to exercise any of these rights.
23. California Consumer Privacy Acts Disclosures
If you are a resident of California, please review the Supplemental California Consumer Privacy Act Disclosures listed in Exhibit B.
EXHIBIT A – Sub-Processors
Sub-Processors used by ORIGO to support ORIGO devices include
| Sub-Processors Used by ORIGO to Support the ORIGOInspect or ORIGOTrack Solution | |
|---|---|
|
Solution/Product Support |
Amazon AWS Cloud Services |
|
|
Zoho CRM |
|
|
Mandrill |
|
Customer Support |
Zoho Desk |
Exhibit B – Supplemental California Consumer Privacy Act Disclosures
The following California Consumer Privacy Act Disclosures (“CCPA Disclosures”) supplement the ORIGO Privacy Policy in order to disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”). These CCPA Disclosures are effective January 1, 2020.
I. Who We Are and Scope of this Privacy Policy
California residents are protected as “consumers” by the California Consumer Privacy Act of 2018 with respect to personal information.
Certain categories of personal data are statutorily excluded from the CCPA and these CCPA Disclosures, including the following:
(1) personal information reflecting a written or verbal communication or a transaction between a business and a consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transaction with the business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency;
(2) personal information that is collected by a business about a natural person in the course of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the natural person’s personal information is collected and used by the business solely within the context of the natural person’s role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or a contractor of that business;
(3) personal information that is collected by a business that is emergency contact information of the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of having an emergency contact on file; and
(4) personal information that is necessary for the business to retain to administer benefits for another natural person relating to the natural person acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or contractor of that business to the extent that the personal information is collected and used solely within the context of administering those benefits.
II. How can a consumer with a disability access these CCPA Disclosures?
Consumers who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this notice. You may also contact info@origosafety.com if you wish to obtain a copy of these CCPA Disclosures in an alternative format.
III. CCPA Notice at Collection Online
ORIGO addresses “at collection” disclosure requirements in our Privacy Notice (see Section I., “Who and what information is subject to these CCPA Disclosures”).
IV. CCPA Privacy Policy
Beyond the disclosures in the preceding “CCPA Notice At Collection Online” section, ORIGO is providing additional disclosures about consumer rights and our personal information handling practices in the preceding twelve (12) months, as required by the CCPA.
1. Right to Know About Personal Information Collected, Used, or Disclosed
This CCPA Privacy Policy describes the personal information we generally collect, use, and disclose about California residents. You have the right to request that we disclose what personal information we collect, use, and disclose about you specifically (“right to know”). To submit a request to exercise the right to know or for information on self-service procedures (where available), please visit us at www.origosafety.com, call our phone number at 540-685-2282 or submit an email request to info@origosafety.com and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.
We may ask that you provide certain information to verify your identity. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny requests, we will explain why.
2. Our Personal Information Handling Practices in 2024
We have set out below the categories of personal information we have collected about California residents in the preceding twelve (12) months and, for each category of personal information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared the personal information.
| Category of personal information; | Purpose Information was Collected; | Source of information; | What entities the information was shared with; |
|---|---|---|---|
|
Identifiers such as real name, unique personal identifier, email address, driver’s license number, or other similar identifiers |
* To create and manage user accounts on our products and services * To communicate with customers in relation to their account * To provide customers with assistance in connection with our products and services * To respond to customers’ comments, questions, and requests * To perform our obligations and exercise our rights under contracts * To perform activities necessary to ensure compliance with applicable laws and respond to requests from government authorities * To market to individuals, as permitted by applicable law. |
Directly from drivers of vehicles that are subscribed to the Geotab solution, your employer/fleet owner that a driver drives a vehicle for, a vehicle leasing company, a car sharing company or the California resident |
* Cloud hosting and internet service providers * Government entities (including law enforcement agencies) and court orders * Operating systems and platforms * Data analytics providers |
|
Geolocation Data |
Same as above |
Same as above |
Same as above |
3. Disclosures of Personal Information; No Sale
Over the preceding twelve (12) months, we disclosed certain categories of California residents’ personal information to the categories of third parties as shown in the table above.
We do not sell and will not sell California residents’ personal information. This includes the personal information of minors under sixteen (16) years of age.
4. Right to Request Deletion of Personal Information
You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information or for information on our self-service data deletion procedures (where available), please visit our ORIGO Support portal or submit an email request to info@origosafety.com and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.
We may ask that you provide certain information to verify your identity. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we have verified your identity, we will ask you to confirm that you wish to have your personal information deleted. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
5. Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information by a business. We have not and do not sell your personal information.
6. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code §1798.125.
7. Authorized Agent
You can designate an authorized agent to make a request under the CCPA on your behalf if:
The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
You sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described above:
Mail your written declaration authorizing the authorized agent to act on your behalf, certified by a California notary public, to Attn: ORIGO Legal Department (Privacy Team), 6536 Commonwealth Dr. Roanoke, VA 24018 US with an e-mail cc: to info@origosafety.com; and
Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.
If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
8. Contact for More Information
If you have questions or concerns regarding these CCPA Disclosures, our Privacy Policy or practices, you may contact us using the following details:
Email address: info@origosafety.com
Postal address: Attn: ORIGO, 3735 Franklin Rd SW, PMB 221, Roanoke, VA 24018 US with an e-mail cc: to info@origosafety.com
Personally Identifiable Information (PII) Request
If you wish to formally request the removal of any of your own PII we may have in our records, please click here.