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Privacy Shield Policy

Last Updated: June 15, 2017


Airbiquity Inc. (“Airbiquity”) respects the privacy of all our clients, their customers and our customers, particularly as it relates to maintaining the confidentiality of any personally identifiable information that we receive. This Privacy Shield Policy (this “Privacy Policy”) covers the privacy practices Airbiquity employs when Airbiquity clients and their customers use our Choreo Service Delivery Platform or other telematics services (the “Services”) in the Europe Economic Area (“EEA”) and Switzerland. The EEA includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein, and Norway. This Privacy Policy also covers the privacy practices that Airbiquity employs with respect to transfer of Personal Information between the United States and the EEA and Switzerland. This Privacy Policy does not cover any information or data collected by Airbiquity through its websites or for other purposes, such as information collected for marketing purposes. Please refer to the website Privacy Policy for more details. The terms “we,” “our,” and “us” in this Privacy Policy refer to Airbiquity.

“Personal Information” or “Information” means information that (1) is transferred from the EEA to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual. Our definition of Personal Information does not include “aggregate” information, information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information. Aggregate information is data we collect about a group or category of services or customers, from which individual identities have been removed.

In the normal course of using the Services, clients and their EEA and Swiss customers will input into or provide Personal Information for the Services (“Customer Data”). As a general matter, Airbiquity may receive the following types of information: contact information (name, email address, mailing address, telephone number); vehicle identification and location information; and vehicle systems status and usage data. Any Customer Data collected by Airbiquity will be considered as if collected by our clients, and provided to us as a third-party processor. Airbiquity processes Customer Data under the direction of its clients pursuant to a written agreement, and has no direct control or ownership of the Customer Data it processes. Airbiquity may collect, use, access or share Customer Data for the purposes of providing the Services, preventing or addressing service or technical problems, responding to support issues, responding to a client’s or customer’s instructions, or as may be required by law, all in accordance with the agreement between the client and Airbiquity. Clients are responsible to maintain their own privacy policy and for complying with any regulations or laws that require providing notice, disclosure and/or obtaining consent prior to providing any data to, or allowing the collection or use of such data by Airbiquity for processing purposes.

Compliance with EU-US and Swiss-US Privacy Shield Principles

Airbiquity complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. Airbiquity has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit

Airbiquity uses a self-assessment approach to assure compliance with this Privacy Policy and Privacy Shield Principles, and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Privacy Shield Principles. Airbiquity notifies its clients and customers about its adherence to the Privacy Shield Principles through its publicly posted privacy policy, available at  

When Airbiquity receives Customer Data, we are acting as third-party processor and do not provide notice to individuals regarding the collection and use of their personal data. Our clients remain responsible for providing notice, if and to the extent they believe such notice is necessary under applicable law. If Airbiquity were to have direct control or ownership of personal data from individuals in the EEA and Switzerland, it will inform the individuals about the purposes for which it collects and uses Personal Information about them, the types of non-agent third parties to which Airbiquity discloses that information, and the choices and means, if any, Airbiquity will offer individuals for limiting the use and disclosure of their Personal Information. In such circumstances, notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Airbiquity, or as soon as practicable thereafter, and in any event before Airbiquity uses the information for a purpose other than that for which it was originally collected.

Customer Data processed or stored by Airbiquity may be subject to contractual agreements with our clients that require more stringent privacy and security safeguards than the requirements in the EU-US and Swiss-US Privacy Shield Frameworks. At a minimum, however, Airbiquity handles Customer Data in accordance with this privacy policy.

Accountability for Onward Transfers

Airbiquity recognizes potential liability in cases of onward transfer of Personal Information to third parties. Airbiquity does not transfer Customer Data to unrelated third parties, unless lawfully directed by a client, or in certain limited or exceptional circumstances in accordance with the applicable EU-US or Swiss-US Privacy Shield Framework. For example, such circumstances would include disclosures of Personal Information (a) if required by a subpoena or other judicial or administrative order, (b) where required by law, to meet national security or law enforcement requirements, or (c) at our sole discretion, where we deem it necessary to protect the safety of any individual or the general public. If Airbiquity ever were to engage in any onward transfers of Personal Information with third parties other than agents, Airbiquity would provide the individual with an opt-out choice to limit the use and disclosure of the Personal Information.

In the event Airbiquity is requested to transfer Personal Information to an unrelated third party, Airbiquity will enter into a written agreement with the third party requiring them to provide protections consistent with the EU-US and Swiss-US Privacy Shield Frameworks, as applicable, and this Privacy Policy. Should Airbiquity learn that an unrelated third party to which Personal Information has been transferred is using or disclosing Personal Information in a manner contrary to this Policy, Airbiquity will take reasonable steps to prevent or stop the use or disclosure.

Personal Information is accessible only by those Airbiquity employees and consultants who have a reasonable need to access such information for us to fulfill contractual, legal and professional obligations. All our employees and consultants have entered into strict confidentiality agreements requiring that they maintain the confidentiality of Personal Information. In the event Airbiquity goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, Personal Information may be among the assets transferred. Clients and customers will be notified via writing or prominent notice on our website of any such change in ownership or control.


Airbiquity employs appropriate physical, electronic and managerial procedures to protect from loss, misuse, unauthorized access or disclosure, alteration or destruction of Personal Information under our control. Although we make good faith efforts to store the information collected by Airbiquity in a secure operating environment that is not available to the public, Airbiquity cannot guarantee complete security or the security of any information transmitted via the Internet or telecommunications networks.

Access and Enforcement

Airbiquity acknowledges an individual’s right to access their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. An individual who seeks access to, or who seeks to correct, amend, or delete inaccurate data, should direct his or her request or questions to the appropriate Airbiquity client (the data controller). If the client or customer requests Airbiquity to access or delete an individual’s personal data, Airbiquity will respond to that request within 30 business days.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Airbiquity commits to resolve complaints about your privacy and our collection or use of your Personal Information. EEA and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Airbiquity: by email at, or in writing at Airbiquity Inc., Legal Department, 1011 Western Avenue, Suite 600, Seattle, WA 98104.

Airbiquity has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Airbiquity is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy. If we do change our privacy practices, we will post those changes on this page. If we make any material changes to this Privacy Policy, we will notify you by means of a notice on this website prior to the change becoming effective. Please check from time to time to make sure that you are away of any changes.