Fleet management solutions
Vehicle TrackingTrack your trucks, vans, cars, trailers and assets with GPS tracking
Safety and protectionProtect your drivers, vehicles, assets and cargo with driver coaching, video telematics and driver support
Workflow managementBoost productivity via professional navigation, route optimisation and order management
ComplianceTrack vehicle inspection, logbook, and coldchain management
Sustain­ab­ility and electric vehiclesReduce CO2 with green driving and EV optimisation
Maintenance and uptimeMaximise vehicle uptime with Vehicle Diagnostics, TPMS and Service Planner for a task-ready fleet 24/7

Individual recom­mend­ation
Solution AdvisorFind out which solution fits your business best
Savings CalculatorFind out how much you can save with fleet management
3G to 4G Migration GuideUpgrade from 3G to 4G. Fleet transition tips.
Platform and apps
Webfleet platformSaaS solution to connect you, your driver and your vehicles
Mobile appsA full suite of on-the-go applications
Webfleet Fleet AdvisorSmarter fleet insights instantly and accurately with generative AI, now on OptiDrive 360
In-vehicle
Vehicle tracking devicesTrack your vehicles and gain insights with LINK series
Driver TerminalsNavigate, communicate and report your operation with PRO driver terminal series
Fleet dash camsProtect your fleet and drivers while reducing claims with Webfleet Video telematics
Integrations
Business integrationBy Webfleet and third-party solutions
Our partner ecosystem
Sales partnersFind your local Webfleet sales partner
If you are are a partner
Partner PortalAccess your Partner Portal
Developer resourcesStart building with our API
Become a partner
Become a sales partnerSell Europe's market-leading fleet management solution
Become an integration partnerIntegrate into Europe's most innovative fleet management solution
Resources
ResourcesExplore our extensive range of whitepapers, case studies, webinars, videos and more
White papersTake a deep dive into the hottest and most important topics facing your industry with our in-depth reports
Case studiesWhat does Webfleet do for a business like yours? Find out what our customers have to say
GlossaryAll the fleet management lingo explained in our comprehensive glossary

Data Processing Addendum

WEBFLEET Service & Products

data securitydata securitydata securitydata securitydata securitydata security

Version: September 2026

Contents

Introduction & Definitions

  • This Data Processing Addendum (including its appendices, collectively the DPA) supplements and is subject to the provisions of the agreement and any other terms and conditions binding the Controller and the Processor (collectively, the Parties, and, individually, each Party) in connection with Processor's provision of the WEBFLEET Service and Products to Controller (the Agreement). For the purposes of this DPA, Client (as defined in the Agreement) shall be deemed the Controller, and Webfleet Solutions B.V. shall be deemed the Processor.
  • This DPA describes the Parties' obligations with respect to the processing and security of Client Data (defined below), including under applicable privacy, security, and data protection laws. This DPA constitutes an integral part of the Agreement and replaces any terms previously applicable to the processing and security of Client Data.
  • Any capitalized term not defined herein shall have the meaning given to it in the Agreement and its schedules. To the extent the language in this DPA conflicts with the Agreement, this DPA shall control. For the purposes of this DPA:
    • Applicable Privacy Law(s) means binding national, state, European Union, or provincial laws or regulations in force concerning privacy, security, or data protection and applicable to the processing of Client Data;
    • Client Data means all (personal) data generated, collected, provided, or otherwise processed by Processor on behalf of and under the instructions of Controller for the provision of the WEBFLEET Service and Products;
    • GDPR collectively means both the United Kingdom's and the European Union's GDPR Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC;
    • Processor Security Incident means an event affecting Processor's security and leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Client Data on systems managed by or otherwise maintained by Processor;
    • Sub-Processor means a third party engaged by Processor to carry out a specific part of the Client Data processing activities necessary for the provision of the WEBFLEET Service and Products;
    • Supervisory Authority means a competent authority that is expressly vested with powers and authority to monitor compliance with and enforce any Applicable Privacy Laws; and
    • The terms personal data, data subject, processing, controller, processor, special categories of personal data, personal data breach, and anonymization as used in this DPA have the meanings given by the Applicable Privacy Law or, absent any such meaning or law, by the GDPR.

Data Processing Overview

This DPA governs the Parties' commitments with respect to the processing of personal data in the WEBFLEET Service and Products. For a comprehensive overview of the WEBFLEET Service and Products, Appendix 1 (Description of Processing) includes information relating to the processing of all categories of Client Data, including non-personal data.

Overview of Processing (Personal Data)
Subject MatterThe subject matter of data processing under this DPA is personal data collected, generated or otherwise processed in the context of Controller's use of the WEBFLEET Service and Products.
DurationPersonal data will be processed for as long as the Agreement and this DPA remain in force. For the specific data points detailed in the Appendix 1 (Description of Processing), the granular retention periods indicated in the relevant table shall apply, also after termination of the Agreement for any reason. At Controller's express request and subject to the applicable commercial conditions, such retention periods may be extended, thereby superseding the relevant retention schedule defined in this DPA. Controller is also entitled to request erasure of (portions of) Client Data while this DPA remains in force.
Purposes

The purpose of the processing of personal data under this DPA is the provision of the WEBFLEET Service and Products as initiated by Controller, as further outlined in Section 1.2 of this DPA and in accordance with the Agreement.

As between Controller and Processor, Controller's use of the WEBFLEET Service and Products may have, as the case may be and depending on the contracted scope under the Agreement, the essential purposes of carrying out (real-time) vehicle tracking, bi-dir­ec­tional communication between fleet managers and drivers, management of fleet workflows, maintenance, sustain­ab­ility and costs, assessment of driver performance and behavior, driving time management and recording, and integration with third-party solutions selected by Controller. Processor shall also render data non-personal for the purposes of Processor's further processing of anonymized and aggregated System Data in accordance with the Agreement.

The processing of personal data made available to Processor hereunder is intended to enable Controller to access strategic data to make informed decisions about productivity, maintenance, compliance, safety, sustain­ab­ility, and cost-ef­fi­ciency of its fleet operations.

Nature of ProcessingData recording, retrieval, collection, storage, organization, combination, analysis, disclosure, erasure and any such other activities and services as initiated by Controller, according to the descriptions in the documentation of the relevant WEBFLEET Service and Products. For the purposes of anonymization, Processor shall ensure Client Data de-iden­ti­fic­ation (removal, trans­form­ation, aggregation of identifiers) so that it is no longer attributable to a data subject.
Categories of DataThe categories of personal data specified in Appendix 1 (Description of Processing).
Categories of Data Subjects

Personal data processed in the WEBFLEET Service and Products will generally relate to the following categories of individuals:

  • Drivers of Vehicles managed through the WEBFLEET Service and Products.
  • Users of the WEBFLEET Service and Products.
  • Other individuals whose personal data is included in the WEBFLEET Service and Products by Controller and its authorized users, either by direct input or as a result of the deployment of the specific WEBFLEET Service and Products used by Controller.

1. Processing of Client Data

1.1. Appointment of Processor. Controller appoints Processor to process Client Data on its behalf and under its documented instructions under the Agreement, this DPA and throughout Controller's deployment, configuration, and use of the WEBFLEET Service and Products. To the extent required by Applicable Privacy Laws, where the Processor processes Client Data that qualifies as personal data, the Controller shall be deemed the controller and the Processor the processor of such personal data.

1.2. Purpose Limitation. The processing of Client Data is granularly detailed in Appendix 1 (Description of Processing), including all the types of personal data involved, as well as the duration and context of such processing in connection with each portion of the WEBFLEET Service and Products. Except as otherwise expressly agreed upon in the Agreement, Processor will only process personal data in the Client Data as described in this DPA as strictly necessary to provide the WEBFLEET Service and Products. The following groups of activities are considered strictly necessary to that end:

  1. Enabling and delivering the requested functional capabilities of the WEBFLEET Service and Products as licensed to, configured, and used by Controller and its users;
  2. Troubleshooting (preventing, detecting, investigating, mitigating, and repairing problems, including Processor Security Incidents and issues identified in the WEBFLEET Service and Products), providing customer (technical) support, advice on deployment and usability of the WEBFLEET Service and Products; and
  3. Keeping the WEBFLEET Service and Products up to date and performant, and enhancing user productivity, reliability, efficacy, quality, and security.

1.3. Anonymization of Client Data. Controller authorizes Processor to anonymize Client Data processed under this DPA with a view to enable its further processing as permitted under the Agreement and Applicable Privacy Law. Anonymized data does not constitute personal data, shall not be deemed Client Data, and is not subject to this DPA. Processor may process anonymized data in the form of System Data, as governed by the Agreement.

1.4. No Automated Decision-­Making. To the extent that Controller's contracted scope for WEBFLEET's Service and Products include automated processing as specified in Appendix 1 (Description of Processing), the Parties hereby acknowledge that Processor (by means of the WEBFLEET's Service and Products or otherwise) is incapable of making decisions that produce legal effects concerning individuals. Controller is solely responsible for interpreting the Client Data generated throughout the use of the WEBFLEET's Service and Products by its authorized users as well as for making and documenting its own independent decisions.

1.5. Engagement of Third Parties. Controller acknowledges and agrees that the processing of Client Data relies on Sub-Pro­cessors providing services that are necessary for the WEBFLEET Service, as set forth in Section 3 below and further detailed in Appendix 2 (Sub-Pro­cessors). Furthermore, and to the extent that Controller elects to connect either (a) Vehicles to the WEBFLEET Service by means of an OEM Onboard Unit; or (b) the WEBFLEET Service and Products to technologies provided by other independent service providers with the intention to establish shared processing of Client Data between Processor and those independent service providers for purposes defined by Controller in agreement with such service providers, then the provisions of Appendix 3 (OEM & Third-Party Integrations Data Processing Terms) will apply.

1.6. This DPA is incorporated by reference into the Agreement and will take effect on the date in which the Parties entered into the Agreement. If an Agreement was already in place upon receipt of this DPA by Controller, then this DPA will take effect as of the date communicated by Processor in its notice to Controller.

2. General Obligations of the Parties

2.1. Controller's Obligations. In addition to its other obligations under the Agreement and this DPA, the Controller shall comply with the Applicable Privacy Laws and:

  1. Ensure that the processing of Client Data is lawful and that the processing of personal data is grounded on a valid legal basis under Applicable Privacy Law;
  2. Be transparent about the processing of personal data towards data subjects and provide the necessary information about such processing and data subjects rights as required under Applicable Privacy Laws;
  3. Ensure the security of Client Data when using the WEBFLEET Service and Products and when storing or otherwise using Client Data outside Processor's or Sub-Pro­cessors' systems, including by: (1) using adequate controls to ensure a level of security appropriate to the risk to the Client Data, (2) securing account authen­tic­ation credentials, systems and devices Controller uses to access the WEBFLEET Service and Products, and (3) backing up or retaining copies of Client Data as appropriate;
  4. Provide adequate training on privacy, data protection and information security to its staff and contractors with respect to the processing and adequate protection of Client Data;
  5. To the extent required under Applicable Privacy Laws, ensure that Controller's account­ab­ility obligations relating to the processing and protection of Client Data are met, including keeping accurate and up-to-date records about the decisions made relating to its own activities; and
  6. Make lawful use of the WEBFLEET Service and Products and only provide instructions for the processing of Client Data in compliance with Applicable Privacy Laws.

2.2. Processor's Obligations. In addition to its other obligations under the Agreement and this DPA, the Processor shall comply with the Applicable Privacy Laws and:

  1. Process personal data only on documented instructions from the Controller, unless required to do so by force of a binding legal obligation for the Processor, in which case Processor shall inform the Controller of that legal requirement before processing, unless applicable law prohibits Processor from disclosing such information;
  2. Subject to the product- and service-spe­cific conditions on data retention laid out in Appendix 1 (Description of Processing), and unless Applicable Privacy Laws prevent Processor from doing so, irreversibly anonymize or delete personal data in the Client Data at the end of the applicable retention periods, as well as allow Controller to export, retrieve or otherwise access Client Data in accordance with the provisions of Section 5 below while this DPA remains in force;
  3. Only engage Sub-Pro­cessors and transfer Client Data across jurisdictions in accordance with the requirements set forth in Section 3 below;
  4. Provide adequate training on privacy, data protection and information security to its staff and contractors with respect to the processing and adequate protection of Client Data;
  5. Maintain an appropriate level of security for Client Data in accordance with the provisions of Section 4 below by implementing appropriate technical and organ­iz­a­tional measures to that effect and ensure that Sub-Pro­cessors, employees and other persons authorized to process the Client Data have committed themselves to confid­en­ti­ality or are under an appropriate statutory obligation of confid­en­ti­ality.
  6. To the extent required under Applicable Privacy Laws, ensure that accurate and up-to-date records of the activities it carries out involving the processing of Client Data are maintained; and
  7. Where Processor becomes aware that an instruction clearly infringes Applicable Privacy Laws, it shall immediately notify Controller, who may then withdraw or modify its instructions accordingly. For the avoidance of doubt, and in particular due to the nature of Controller's instructions to Processor as referred to in Section 1.1 above, Controller understands and agrees that (1) it is unlikely that Processor can form an opinion on whether instructions from Controller infringe Applicable Privacy Laws; (2) Processor is under no obligation to actively monitor or audit Controller's instructions or deployment decisions; and (3) Processor is not responsible for providing legal advice to Controller.

3. Sub-Pro­cessing & Cross-Border Data Transfers

3.1. Authorization to Engage Sub-Pro­cessors. Controller acknowledges that the provision of the WEBFLEET Service and Products requires Processor to put in place complex technical and organ­iz­a­tional arrangements for the adequate processing and protection of Client Data, including with specific Sub-Pro­cessors providing specialized services. Controller therefore gives general authorization for Processor to engage Sub-Pro­cessors under the terms of this DPA. The entities listed in Appendix 2 (Sub-Pro­cessors) are the Sub-Pro­cessors engaged by Processor for the provision of the WEBFLEET Service and Products to Controller. Controller further authorizes Processor's engagement of other third parties as Sub-Pro­cessors provided that such engagement is strictly necessary for the adequate provision of the WEBFLEET Service and Products. Processor shall notify Controller of intended changes to Appendix 2 (Sub-Pro­cessors) in accordance with Sections 3.2 and 6.4 below.

3.2. Controller's Objection to Sub-Pro­cessors. When Processor engages any new Sub-Processor not listed in Appendix 2 (Sub-Pro­cessors), Processor will, at least 30 days before the new Sub-Processor starts processing any Client Data, update Appendix 2 (Sub-Pro­cessors) accordingly, including the name, location and activities of the new Sub-Processor. Controller may, within 15 days after the publication of the updated Appendix 2 (Sub-Pro­cessors), object to the appointment of the new Sub-Processor(s) by notifying Processor in writing. When objecting to new Sub-Pro­cessors, Controller will include a documented explanation of the grounds for non-approval together with the termination notice to permit Processor to re-evaluate any such new Sub-Processor based on the concerns expressed by Controller. Upon receipt of such an objection by Processor, the Parties shall discuss in good faith and attempt to find a commercially reasonable resolution. If after such discussion Controller does not approve the new Sub-Processor, then Processor may, at its sole discretion, either (a) refrain from appointing the objected Sub-Processor; or (b) allow Controller to (partially) terminate any subscription for the affected portion of the WEBFLEET Service and Products which would otherwise rely on that Sub-Processor, without liability to either Party.

3.3. Conditions Applicable to Sub-Pro­cessors. Where a Sub-Processor fails to fulfill its data protection obligations, Processor shall remain liable to Controller for the performance of that Sub-Processor's obligations. Processor shall ensure that, as between Processor and each Sub-Processor, a written contract is in place whereby:

  1. Sub-Processor undertakes to process personal data in the Client Data only to the extent required to perform the specific obligations subcontracted to it; and
  2. To the extent required under the Applicable Privacy Laws, Sub-Processor abides to data protection obligations in a manner that is substantially consistent with Processor's obligations under this DPA. This shall include, in particular, Sub-Processor's obligations to implement appropriate technical and organ­iz­a­tional measures to ensure the security of Client Data.

3.4. Cross-Border Processing of Client Data. Controller is solely responsible for defining where the WEBFLEET Service and Products will be used by authorized users, including the geographic locations where Controller's vehicles managed with the WEBFLEET Service and Products will be moved through. Controller acknowledges that the provision of the WEBFLEET Service and Products requires Processor to process Client Data in different jurisdictions, because of the physical location of the processing facilities used by Processor and Sub-Pro­cessors. Data processing activities carried out by Processor will generally take place within the European Economic Area. Other jurisdictions on which Client Data will be processed, as well as the specific conditions applicable to such cross-border processing under Applicable Privacy Laws, if any, are laid out in Appendix 2 (Sub-Pro­cessors). Controller shall inform Processor in advance in case it intends to use the WEBFLEET Service and Products in a jurisdiction that imposes privacy obligations that add to or conflict with those considered in this DPA. If additional or conflicting obligations are communicated by Controller, then the Parties shall engage in good faith negotiations about (1) the necessary amendments to this DPA to address said obligations, and (2) the potential impacts to the commercial conditions applicable to the WEBFLEET Service and Products as a result of such amendments in a way that meets Controller's requirements and maintains the commercial balance of the Agreement.

3.5. Non-EEA/UK Processing of Personal Data. Where Processor engages a Sub-Processor hereunder for carrying out personal data processing activities on behalf of Controller which entail transfers of personal data outside the European Economic Area and the United Kingdom, Processor will only transfer personal data outside the European Economic Area and the United Kingdom if the appropriate GDPR requirements are met. Processor will only engage Sub-Pro­cessors to process personal data in the Client Data outside the European Economic Area or the United Kingdom if either (a) an adequacy decision in the meaning of Article 45 GDPR is in place to cover the geography where processing by the relevant Sub-Processor is set to take place; or (b) standard contractual clauses adopted by the European Commission (EEA) or the Information Commissioner's Office (UK) in accordance with of Article 46(2) GDPR are in place between Processor and Sub-Processor, provided that the conditions for the use of those standard contractual clauses are met. Specific information applicable to the processing of personal data carried out by each Sub-Processor is laid out in Appendix 2 (Sub-Pro­cessors).

4. Security & Compliance

4.1. Confid­en­ti­ality of Client Data. Processor will not access, use, or disclose to any third party, any Client Data, except as (a) directed by Controller, (b) described in this DPA, or as (c) necessary to comply with the law or a valid and binding order of a governmental body (such as a subpoena or court order). If a competent (government) authority requests access to Client Data, the Processor will, where legally permitted and reasonably practicable, seek to redirect the authority to request the data directly from the Controller. If the Processor is legally required to disclose Client Data, it will provide the Controller with prompt notice of the request and await instructions, unless prohibited to do so by law.

4.2. Processor's Security Measures. Processor will implement and maintain technical, organ­iz­a­tional, and physical measures to protect Client Data against Processor Security Incidents in a manner consistent with its obligations under Applicable Privacy Laws as described in Appendix 4 (Technical & Organ­iz­a­tional Measures). Processor may update such measures from time to time provided that such updates do not result in a material reduction of the security of the Client Data processed within the WEBFLEET Service and Products.

4.3. Controller's Security Assessment. Controller is solely responsible for making an independent determination as to whether the technical and organ­iz­a­tional measures for the security of the WEBFLEET Service and Products meet Controller's requirements, including any of its security obligations under Applicable Privacy Laws. By entering into this DPA, Controller agrees that the WEBFLEET Service and Products and in particular the security practices and policies implemented and maintained by Processor provide a level of security appropriate to the risk to Client Data, taking into account the state of the art, the costs of imple­ment­ation and the nature, scope, context and purposes of the processing of Client Data as well as the risks to individuals.

4.4. Security Incidents. Processor will notify Controller promptly and without undue delay after becoming aware of a Processor Security Incident, take reasonable steps to minimize harm and secure Client Data, and continue to provide reasonable assistance to Controller to that effect. Processor may provide information about a Processor Security Incident in phases in so far as more information about the Security Incident becomes available. To enable Controller to notify a Processor Security Incident to a Supervisory Authority and/or data subjects, Processor will cooperate with and assist Controller by including in the notification under this Section 4.4 such information about the Processor Security Incident as Processor is able to disclose to Controller, taking into account the nature of the processing and the information available to Processor. Processor's notification of or response to a Processor Security Incident to Controller hereunder will not be construed as an acknow­ledgement by Processor of any fault or liability with respect to the Processor Security Incident. Controller must notify Processor promptly about any possible misuse of its accounts or authen­tic­ation credentials or any other security incident, breach or adverse event related to the WEBFLEET Service and Products.

5. Access to Data and Assistance to Controller

5.1. Data Access. At all times during the term of the Agreement and this DPA, Processor will enable Controller, in a manner consistent with the function­al­ities of the WEBFLEET Service and Products, to access and to export Client Data, including where necessary for further use of Client Data by Controller outside the WEBFLEET Service and Products. Processor keeps a Data Access Specification Sheet up to date with the purpose of transparently informing Controller about the different data points generated by Processor throughout the Agreement, as well as the means available for Controller to access and export such data. This can be consulted at webfleet.com/dpa.

5.2. Control and Respons­ib­ility Over Client Data. Notwith­standing the specific­a­tions of the processing of Client Data for the purposes of the adequate provision of the WEBFLEET Service and Products under this DPA, Controller retains exclusive respons­ib­ility for assessing whether the processing of Client Data commissioned to Processor as described in this DPA and Agreement fulfills the legal, technical, and operational requirements of the Controller. This includes the specific retention periods applicable to the different categories of Client Data outlined in Appendix 1 (Description of Processing) and Controller's obligations and potential interests in keeping Client Data for periods that differ from those laid out in this DPA. During the term of this DPA, Controller retains control over Client Data, including where necessary to rectify, update, export, make copies of, and erase Client Data. Processor shall reasonably cooperate and assist Controller to that extent in accordance with the provisions of this DPA.

5.3. Data Subject Requests. Should Processor receive a request from a data subject that relates to Client Data, Processor will (1) advise the data subject to submit their request to Controller, (2) notify Controller without undue delay, and (3) refrain from responding to the request without authorization from Controller. Controller will be responsible for responding to any such request including by using the functionality of the WEBFLEET Service. Processor will (taking into account the nature of the processing of Client Data) assist Controller in fulfilling its obligations under Applicable Privacy Law to respond to requests for exercising the data subject's rights by either instructing Controller on how to use the WEBFLEET Service to that end or, if that proves insufficient, and upon Controller's express request, by providing Controller with additional reasonable cooperation and assistance.

5.4. Assistance for Compliance. Upon Controller's express request, Processor will (taking into account the nature of the processing and the information available to Processor) reasonably assist Controller where necessary in ensuring compliance with its obligations relating to data protection impact assessments, prior regulatory consultations with Supervisory Authority(ies) or equivalent procedures under Applicable Privacy Law. Processor will provide such cooperation and assistance by providing the requested information, which shall never be construed by Controller as legal advice, related to the processing activities and technical and organ­iz­a­tional measures relevant to the WEBFLEET Service and Products, unless the requested information is otherwise already available to Controller. To the extent that Controller requests assistance, support or cooperation that materially exceeds the scope of Processor's obligations under this DPA or Applicable Privacy Laws, Processor may charge Controller for its reasonable and demonstrable costs incurred in providing such additional assistance. Controller shall reimburse Processor for all such reasonable and demonstrable costs and expenditures, provided that Processor notifies Controller in advance and obtains Controller's prior written approval for such costs.

5.5. Audits. Processor uses independent third-party auditors to verify the adequacy of its security measures according to ISO 27001 standards. At Controller's written request, and under appropriate confid­en­ti­ality covenants, Processor will provide Controller with as much information and records as reasonably necessary so that Controller can verify Processor's compliance with its obligations under this DPA, including by providing access to relevant third-party audit reports, certi­fic­a­tions, and summaries thereof. Controller agrees to use such reports and certi­fic­a­tions as the primary means of verifying Processor's compliance. To the extent that Applicable Privacy Laws provides for audit rights and Controller reasonably determines that the information provided is insufficient to verify Processor's compliance with its obligations under this DPA, Processor will allow Controller (or a demonstrably independent auditor appointed by Controller) to verify Processor's compliance with its obligations under this DPA. During an audit, Processor will reasonably cooperate with Controller or its auditor, including by providing any relevant documents relating to Processor's measures applied by Processor to comply with this DPA. Controller remains responsible for any fees charged by an auditor appointed by Controller or otherwise incurred for the carrying out of any such audit. Following an audit request hereunder, the Parties will discuss and mutually agree in advance on:

  1. the reasonable start date, scope and duration of the audit; and
  2. each Party's security and confid­en­ti­ality obligations, controls, and covenants applicable to the audit and to any related evidence or other documents, as well as any ensuing reports and agreements.

6. Miscellaneous

6.1. Termination of this DPA. This DPA shall remain in force for the duration of the Agreement and for so long thereafter as the Processor continues to process Client Data on behalf of the Controller during the applicable retention periods specified in Appendix 1 (Description of Processing). This DPA shall automatically terminate upon the Processor's cessation of all processing activities involving personal data in the Client Data.

6.2. Severability. If any provision of these DPA is at any time held by a competent court to be invalid or unenforceable, it shall be ineffective only to the extent of such invalidation or unenforce­ab­ility without invalidating the remaining portions hereof, and such remaining portions of this DPA shall continue to be in full force and effect. In the event that any provision of this DPA shall be determined to be invalid or unenforceable, the Parties will negotiate in good faith to replace such provision with another provision that will be valid or enforceable and that is as close as practicable to the provisions held invalid or unenforceable.

6.3. Return or Deletion of Client Data. In addition to Controller's right to retrieve/obtain access to Client Data under Section 5.1 above, Processor will further enable Controller, at all times during the term of this DPA, to delete Client Data in a manner consistent with the function­al­ities of the WEBFLEET Service and Products. If Controller is technically unable to access or delete Client Data via the dedicated function­al­ities provided in the WEBFLEET Service and Products, Controller may submit a request in writing to that effect and Processor will enable Controller to access or irreversibly delete Client Data following such request.

6.4. Notices & Communication. Except where expressly stated otherwise, all notices from Processor to Controller under this DPA will be delivered to one or more of Controller's admin­is­trators, either by dedicated notifications via the WEBFLEET Service interface or email. Notice is given as of the date it is made available by Processor. It is Controller's sole respons­ib­ility to ensure Controller's admin­is­trators maintain accurate contact information on the WEBFLEET Service's management console and secure transmission at all times. Notices and other commu­nic­a­tions from Controller to Processor referring to the subject matter of this DPA will be delivered by Controller's authorized repres­ent­atives to digitaltrust@bridgestone.com.

6.5. Updates. This DPA may be updated from time to time by Processor, including as needed to comply with updates to applicable laws and reflect the release of improvements or other material changes to the WEBFLEET Service and Products. The most up-to-date version of this DPA can be consulted at webfleet.com/dpa.

6.6. Governing Laws & Dispute Resolution. The provisions relating to the choice of applicable laws and dispute resolution contained in the Agreement shall apply in full to this DPA.

Appendices

The most up-to-date version of this DPA as well as of each of the documents above can be found on webfleet.com/dpa.

Appendix 1

Description of Processing

Throughout Client's use of the WEBFLEET Service and Products, the following categories of data may be generated and further processed by Webfleet Solutions:

In the tables below, a detailed description of the different data points processed by Webfleet Solutions is presented. These tables include: (1) a general reference to each data category, (2) a description of the (more granular) data contained in each such data category, and (3) a reference to the retention period that Webfleet Solutions applies by default to the data points in each such data category.

Product- or Service-Spe­cific Processing. Certain components and modules of the WEBFLEET Service and Products have specific data processing capabilities that apply only to them. Individual tables are set out below to describe this where applicable. To jump straight to the product- and service-spe­cific data tables, please refer to the links below:

The entirety of Client Data listed in this Appendix 1 is processed and made available to Client via the Webfleet Telematics Service Platform. To the extent that Client does not use certain components or modules of the WEBFLEET Service or Products, the data processing specific­a­tions that apply only to those unused components or modules will not apply to Client.

General Data Processing Overview

The tables below describe the general data processing capabilities that are enabled with the use of core features of the Webfleet Telematics Service Platform, as well as with most function­al­ities from the LINK and PRO devices.

User Managed Data and Created Content

Data created by users of the WEBFLEET Service and Products

Data CategoryDescriptionRetention Period
AddressesGeolocation data, shipping addresses, way points and EV charging station locationsThroughout the Agreement, then during the remainder of the current calendar year + 2 full calendar years
Administrator and other Authorized Webfleet User DataUser name, address, and contact data as phone, email, identi­fic­ation numbers
AreasGeo-zone definitions to determine areas of wanted or unwanted vehicle position
Driver DataDriver name, address, and contact data as phone, email, driving license information, identi­fic­ation numbers
Other User-Managed Vehicle DataOther user content, such as individual vehicle specific­a­tions, additional telematics data (manually) provided by users, such as registration, VIN or license plate
Fleet and Vehicle Departure TimePlanned departure time on a fleet or vehicle level
RoutesPre-defined driving routes, order destinations, planned routes on driver terminals
VIN (Vehicle Identi­fic­ation Number)17-character unique identifier for a vehicle which displays the car's unique features, specific­a­tions and manufacturer which can be used to track recalls, registrations, warranty claims, thefts and insurance coverage as well as map a vehicle to a particular owner or data subject
ChecklistsRegular vehicle inspection and maintenance by drivers24 months
Orders and Order StatesJob data for drivers, attachments, electronic proof of delivery, and order status90 days
(France: 60 days)
Text MessagesMessages exchanged between fleet manager and driver through driver terminals

Transactional Data

Data generated by using the WEBFLEET Service and Products

Data CategoryDescriptionRetention Period
(Lateral) AccelerationEvents of harsh breaking, cornering, and acceleration90 days
(France: 60 days)
CAN/OBD DataSignals from a vehicle's Controller Area Network (CAN) or on-board diagnostics (OBD) interface as malfunction indicators, maintenance prediction, door monitoring, fuel level etc.
Detailed Position MessagesCurrent/historical location of a vehicle with a LINK device
Ignition ChangesIf and when ignition is switched on and off
Momentary Odometer and Fuel LevelThe current odometer and fuel levels
TracksSequence of coherent positions
Tracking Device MonitoringVehicle movements with ignition off (towing, theft), power disconnection, shielding of tracking device
Trouble CodesMalfunction indicators taken from FMS bus of heavy goods vehicles or OBD
Other Observed Vehicle DataOther sensor data including driving time, time of day, vehicle and engine speed, engine load and temperature, trailer data, battery voltage, accident data protocols for 45 seconds before and 15 seconds after an accident, vehicle connected devices, sensors, and service-re­lated diagnostic data
Trips and Trip Position Data including time stampRegistration of trip start and trip end location and time only – no detailed routeCurrent calendar year + 2 full calendar years
Trip Fuel and Energy ConsumptionFuel and/or energy consumption during a trip
Trip OdometerDistance driven during a trip

Aggregated Data

Data derived by applying statistical analysis as part of the WEBFLEET Service

Data CategoryDescriptionRetention Period
Asset StatisticsCoupling events, activities and maintenance for assetsCurrent calendar year + 2 full calendar years
Driver StatisticsDriver behavior aggregated over time
Driving EventsDriving behavior above pre-defined thresholds of normal driving90 days
(France: 60 days)
Driving KPIs and OptiDrive ScoresAggregated driving behavior indicators (speeding, driving events, idling, fuel, constant speed, coasting, green speed, gear shift) and resulting OptiDrive scoresCurrent calendar year + 2 full calendar years
ReportsConfigurable reports with the ability to combine all data mentioned above, which needs to be set up by the account administratorBetween 30 days and 36 months depending on Client's chosen setup
Speed and Speeding EventsCurrent speed compared with local speed limit from map data90 days
Vehicle StatisticsDriving events, carbon footprint data, engine hours etc. aggregated over timeCurrent calendar year + 2 full calendar years
Work Time StatisticsDriver/co-driver check in/out

Product- and Service-Spe­cific Processing

The tables below describe product- and service-spe­cific data processing specific­a­tions. To the extent that Client does not use (a portion of) the following products or services, the corresponding data processing specific­a­tions will not apply.

Cold Chain

Webfleet Cold Chain gives you complete visibility of your refrigerated fleet for worry-free cold chain logistics. With real-time temperature monitoring and control, this adaptable solution helps you both protect temperature sensitive products and achieve cold chain compliance. Learn more about Cold Chain here.

Data CategoryDescriptionRetention Period
TemperatureTemperature value in Celsius degrees coming from temperature sensor (up to 6 sensors)1 year
Door statusOpen / Close state of the doors for refrigerated vehicle/truck/trailer (up to 3 doors)
Reefer unit statusOn / Off state of the reefer unit
Operational modeCurrent mode of the refrigeration machine (continuous or start/stop)
Fuel levelRemaining fuel for the diesel engine
Operating hours totalTotal running hours of the reefer unit
Operating diesel hours totalTotal running hours of the diesel engine of the reefer unit
Operating electric hours totalTotal running hours of the electric engine of the reefer unit
Power modeIt tells if reefer unit is using diesel or electric engine when running
Zone: Set PointTemperature set in the reefer unit for a certain zone (up to 3 zones)
Zone: Supply AirThe temperature of the air leaving the refrigeration unit for a certain zone (up to 3 zones)
Zone: Return AirThe temperature of the air returning to the reefer unit for a certain zone (up to 3 zones)
Zone: Operational modeCurrent state of the refrigeration machine (cooling, heating or defrosting) for a certain zone (up to 3 zones)

EV Charger Monitoring & Optimization

Gain comprehensive insights into your EV charging routine by connecting your private chargers to the Webfleet EV monitoring system. Effortlessly monitor your chargers across multiple sites without the need for additional hardware. Stay on top of charging costs and occupancy to improve operational reliability. Chargers must comply with OCPP 1.6 and be connected to the internet. Learn more about EV Charger Monitoring & Optimization here.

Data CategoryDescriptionRetention Period
Charger dataCharger identifier, Maximum power, Connector type, Charger status, Number of socketsThroughout the Agreement, then during the remainder of the current calendar year + 2 full calendar years

Charger and charge session data are automatically deleted when the relevant third party from which that data originated either removes the charger or deletes the data themselves.
Charge session dataCharger identifier + socket number, Start/end time, Current charging power, Energy charged, Cost, Expected remaining charging time, Charge session authorization token
Vehicle dataVehicle connection status, Expected time until fully charged, Vehicle identifier / name, Battery level

Fleet Advisor

Webfleet Fleet Advisor is an advanced AI fleet management feature designed to help fleet managers make data-driven decisions with ease and precision. Learn more about Fleet Advisor here.

Data CategoryDescriptionRetention Period
User prompts, responses given, and conversation historyRequests sent by the Webfleet user to generate insights based on existing data from Client's Webfleet environment, responses provided by Fleet Advisor in response to user prompts and the resulting conversation history90 days per interaction (each single prompt + response context)

Fleet Insights

Webfleet Fleet Insights helps fleet managers transform complex fleet data into practical action. Fleet benchmarks, trends, and a recom­mend­a­tions dashboard allows for faster, actionable understanding of fleet performance. By unifying key aggregated metrics from your fleet, benchmarking against similar fleets, surfacing trends, and with seamless link to Fleet Advisor for tailored recom­mend­a­tions and deeper analysis, you get to make faster, more confident decisions that reduce costs, improve efficiency, and elevate safety and operational performance. Learn more about Fleet Insights here.

Data CategoryDescriptionRetention Period
Aggregated sustain­ab­ility, safety, and productivity data from Client's fleet

Includes fuel consumption, wasted fuel while idling, driving events, video events, vehicle mileage, trailer mileage, vehicle utilization, and trailer utilization.

This feature uses fleet-level, non-personal aggregated data to show trends and enable unidentified peer benchmarking. Identifiers are removed, transformed or aggregated so data is no longer attributable to an individual. This enables Client to act on what matters most to improve performance with a holistic dashboard, KPI benchmarking, and interplay with Webfleet Fleet Advisor for recom­mend­a­tions and deep-dive follow-up actions.

Granular input data (e.g., from each fleet data point) follows the retention period applicable to its usual feature-based processing under this DPA

Aggregated data generated for the purposes of Fleet Insights remain available in Client's environment for up to 15 months and are then replaced with newer indicators

In-App Translation Service

In-App Translations enables authorized users to request translations of text messages and order descriptions exchanged through Webfleet, Webfleet Mobile, and the Work App. When a user selects the translation function, the relevant text and requested target language are processed using an AI-powered translation service, and the translated text is returned for display alongside the original content. Translations may be temporarily cached within the Client's account to improve performance and avoid repeated translation of identical content.

Data CategoryDescriptionRetention Period
Translation inputs and outputs

Text messages and free-text order descriptions submitted for translation within the Webfleet Service, together with the requested target language and the resulting translated text.

Content may contain personal data entered by users in free-text fields. Translated content is cached separately for each Client account to improve performance and avoid repeated translations.

Cached translations: up to 90 days, after which they are automatically removed. The cache may also be cleared earlier upon request.

Original text messages and order data remain subject to the retention periods otherwise applicable under this DPA.

Tachograph Manager

Webfleet Tachograph Manager is the reliable all-in-one software solution for downloading, analyzing and archiving tachograph data for your HGVs and LCVs. Learn more about Tachograph Manager here.

Data CategoryDescriptionRetention Period
Driver card dataTachograph records from the driver, including driver unique identi­fic­ation, trip start/end events and timestamps37 months

(Data from vehicles with a terminated contract are retained only for 90 days post-contract termination)
Tachograph mass storage dataTachograph records from the vehicle, including driver unique identi­fic­ation, trip start/end events and timestamps

TachoShare

Webfleet TachoShare is a Remote Download Module that downloads tachograph data from vehicles on the road and offers connectivity to 3rd party analysis software. You get complete control of how you use your data and who you share it with, from a secure, accessible archive. Learn more about TachoShare here.

Data CategoryDescriptionRetention Period
Driver card dataTachograph records from the driver, including driver unique identi­fic­ation, trip start/end events and timestamps37 months
Tachograph mass storage dataTachograph records from the vehicle, including driver unique identi­fic­ation, trip start/end events and timestamps

Tire Pressure Monitoring

Webfleet Tire Pressure Monitoring System (TPMS) checks your tire pressure and temperature in real-time. With predictive tire management, problems are detected before they lead to costly repairs or downtime. Whether you are transporting passengers or cargo – TPMS helps you ensure you get to your destination safely and on time. Learn more about TPMS here.

Data CategoryDescriptionRetention Period
Tire pressure current readingsSignals from tire pressure sensors' last reading: pressure, temperature, TPMS sensor battery level (valve mounted sensor)Undefined (data follows object lifecycle)
Tire pressure historical readingsSignals from tire pressure sensors' readings: pressure, temperature90 days
Tire-related configurationVehicle/asset chassis layout, recommended axle pressureUndefined (data follows object lifecycle)

Webfleet Video

Combined with Webfleet Video, fleet cameras provide comprehensive insights into road incidents and driving events. AI technology detects risky driving behavior like mobile phone use and tailgating, then notifies drivers so they can immediately adjust their driving style. Learn more about Webfleet Video here.

CAM 50 (Legacy Solution)

Data CategoryDescriptionRetention Period
Raw video footage

Road-facing video footage: cannot be disabled.

Driver-facing video footage: can be disabled via the Webfleet UI. Lens cover accessories available for users to avoid driver-facing video recordings.

Raw footage is only processed outside the camera device itself when either the fleet manager toggles live view or an event trigger is met (see events below).

Server storage: 90 days (France: 60 days)

On-device storage: Data retention on SD card storage configurable on the Webfleet UI from 4 minutes to unlimited.
Video events

Video footage based on event triggers is transferred to the Webfleet backend and then made available in Webfleet UI. All event triggers can be enabled/disabled per camera or vehicle. Event triggers are automatically flagged using computer vision algorithms, G-sensors and accel­er­o­meters. Events include:

  • Driving events (harsh braking, harsh steering) above level 3 severity
  • Crash events
  • Driver-facing events: distracted driver, mobile phone, smoking and food/drink, seatbelt, driver-facing camera covered
  • Road facing events: tailgating, lane crossing
  • Driver­-triggered event: alert button
  • Video on request: an available video stored in the SD card can be requested via Webfleet track and trace modules, of a specific time.
  • LINK input/output events: changes to the I/O state of a Webfleet LINK device, e.g., door open/close sensor.

Videos are only uploaded to Webfleet if one of the events listed above is triggered, with footage of specific durations of 10 to 20 seconds by default.

Activity log

System- and user-­gen­erated audit trail that logs event usage and camera lifecycle per camera, allowing authorized users to keep track of how event-related data is used within Webfleet as well as to keep track of relevant camer­a-re­lated activities.

Activity info contains:

  • Activity type: See list of activity types
  • Time: Date/time when the activity took place
  • Actor: i.e., User — Webfleet username (if applicable), or System
  • Vehicle (if applicable): Vehicle to which the camera was attached at the time of the activity
  • Event time (if applicable): Date/time of the corresponding event

Activity types – Event log:

  • Event created
  • Video requested
  • Video watched
  • Video downloaded
  • Event commented
  • Event resolved
  • Event rated
  • Event deleted

Activity types – Camera log:

  • Live view started
  • Camera woken up
  • Private mode started
  • Private mode ended
  • Configuration changed
  • Driver assigned
  • Driver unassigned
  • Camera attached
  • Camera detached
  • Camera deactivated
  • Camera reactivated
  • SIM deactivated
  • SIM reactivated
  • Camera activated (RMA)
  • Camera replaced (RMA)
Event log: 90 days* (France: 60 days*)

*The log entries for a specific event is deleted when the corresponding event is deleted by an authorized user and gets replaced by an Event deleted entry

Camera log: Undefined (data follows device lifecycle)

CAM Lite & Pro

Data CategoryDescriptionRetention Period
Raw video footage

Recording to local microSD card of road-facing lens and any connected outward-, cargo-facing or other in-cabin auxiliary camera: always enabled during trip and, by default, continuously recording for 10 mins after trip end/ignition off. This can be managed in the Webfleet UI. Fleet managers can also wake up the camera remotely, also outside of a trip, as long as the device is in standby mode—not when it is offline (e.g., low battery or no connectivity). Lens cover accessories available for users to avoid road facing video recordings.

Recording to local microSD card of driver-facing lens: Disabled by default. Can be enabled/disabled via the Webfleet UI, the Installer App, or with lens covering accessory.

3 Minute video blocks stored on encrypted video files in the microSD cards. Authorized Client users can decrypt the video files in the Webfleet UI.

Raw footage is only processed outside the camera device itself when either the fleet manager toggles live view or an event trigger is met (see events below). Audio recordings may also be collected and further processed—feature disabled by default and possibly enabled on request.

Encrypted footage is retained in the microSD card until it is overwritten.

The standard microSD card stores 128 GB, which corresponds to ~100 hours recording with default resolution and without auxiliary cameras. Oldest content is overwritten when saving new footage in 3-minute segments. MicroSD card can be upgraded to maximum 1 TB in CAM Lite and maximum 2*1 TB in CAM Pro.
Video events

Video footage based on event triggers is transferred to the Webfleet backend and then made available in Webfleet UI. All event triggers can be enabled/disabled per camera or vehicle and the creation of events and in-cabin driver alerts can be enabled/disabled separately—all using the Webfleet UI. Event triggers are automatically flagged using computer vision algorithms, G-sensors and accel­er­o­meters. Events include:

  • Driving events above certain level of g-force: harsh braking, harsh steering
  • Crash events
  • Road-facing MVAI: following distance, lane crossing, stop sign violation, collision risk, stop and go (only driver alert—no event creation)
  • Driver-facing MVAI: distraction, fatigue, mobile phone, seatbelt, smoking, driver-facing camera covered
  • Driver­-triggered event: alert button
  • Office-triggered event: video request from trip/trace/standstill or for specific date/time
  • LINK input/output events: changes to the I/O state of a Webfleet LINK device, e.g., door open/close sensor.

Videos are only uploaded to Webfleet if one of the events listed above is triggered, with footage of specific durations of 10 to 30 seconds by default depending on event type (extendable on request).

Event footage and events transmitted to backend: 90 days (France: 60 days)
Activity log

System- and user-­gen­erated audit trail that logs event usage and camera lifecycle per camera, allowing authorized users to keep track of how event-related data is used within Webfleet as well as to keep track of relevant camer­a-re­lated activities.

Activity info contains:

  • Activity type: See list of activity types
  • Time: Date/time when the activity took place
  • Actor: i.e., User — Webfleet username (if applicable), or System
  • Vehicle (if applicable): Vehicle to which the camera was attached at the time of the activity
  • Event time (if applicable): Date/time of the corresponding event

Activity types – Event log:

  • Event created
  • Video requested
  • Video watched
  • Video downloaded
  • Event commented
  • Event resolved
  • Event rated
  • Event deleted

Activity types – Camera log:

  • Live view started
  • Camera woken up
  • Private mode started
  • Private mode ended
  • Configuration changed
  • Driver assigned
  • Driver unassigned
  • Camera attached
  • Camera detached
  • Camera deactivated
  • Camera reactivated
  • SIM deactivated
  • SIM reactivated
  • Camera activated (RMA)
  • Camera replaced (RMA)
Event log: 90 days* (France: 60 days*)

*The log entries for a specific event is deleted when the corresponding event is deleted by an authorized user and gets replaced by an Event deleted entry

Camera log: Undefined (data follows device lifecycle)
Enhanced Road Safety (CAM Pro Only)

The enablement of the Enhanced Road Safety feature allows CAM Pro to detect critical situations – such as speed sign violations, red-light violations, difficult road or weather conditions, and truck size or weight restrictions. Based on this, drivers may receive in-cabin alerts, and customers may receive related events and metadata in the Webfleet platform. The data processed for this feature includes:

  • Road signs
  • Traffic-light events
  • Road and weather conditions
  • Truck size restriction signs.

The Enhanced Road Safety feature uses an AI model, running on the CAM Pro camera itself, to analyze footage and related data to generate event metadata, risk classi­fic­a­tions, scores, ratings, and alerts to drivers, and transmit the data to the Webfleet backends. The feature may also involve AI model improvement, either using anonymized data or non-an­onymized data where the customer has opted in.

Event footage and events transmitted to backend: 90 days

(France: 60 days)

Working Times & Remaining Driving Time

Webfleet delivers accurate, up-to-date remaining driving times, helping you and your drivers to stay compliant with regulations. Precise data on how many hours your drivers have left each day also enables your dispatchers to plan more effectively and efficiently. Learn more about Remaining Driving Time here.

Data CategoryDescriptionRetention Period
Work StateThe different work and break states reported by the driver collected from tachograph (driving, other work, availability and break), PRO devices, and the Work App (work and break states)37 months
Driving and Working Time Violation Event NotificationsNotifications displayed in the Webfleet Telematics Service Platform user interface flagging driver violation events based on driving time and working time calculated from work states reported by driver in the tachograph.90 days

About Webfleet's Mobile Apps

The Webfleet mobile apps help fleet managers run their fleets on the go and effectively communicate with their mobile workforce. Driver­-ori­ented apps also help streamline workflows wherever drivers are. Learn more about Webfleet's Mobile Apps here. Most data points listed below reflect the same data that is processed in the context of the WEBFLEET Service as a whole. Unless expressly stated otherwise, the retention time for such data points will follow the data lifecycle defined for the WEBFLEET Service in general, as per the tables above. Webfleet's mobile apps data processing activities are also subject to Webfleet's privacy notice.

Mobile App: Logbook App

Data CategoryDescriptionRetention Period
Driver NameName that the fleet manager enters in the Webfleet UI at driver creationUndefined (data follows object lifecycle)
Driver EmailEmail address that the fleet manager enters in the Webfleet UI at driver creation and which may be used to login
Driver Phone NumberPhone number that the fleet manager enters in the Webfleet UI at driver creation and which may be used to login
Driver Trip Mode (Change) in LogbookPrivacy management change events to drive in private/commute or business modesCurrent calendar year + 2 full calendar years
Driver/Vehicle AssociationThe vehicle that has been assigned or selected by the driver in the Logbook AppUndefined (data follows object lifecycle)
Driver OptiDrive Score, Ranking and Trip DataDriving behavior data (OptiDrive), calculated by the LINK device in the vehicle and only visualized in the Logbook App: OptiDrive Score, trips with their unique scores and ranking within the company drivers (all set up by the fleet manager in the Webfleet UI)Current calendar year + 2 full calendar years

In the app for 14 days
Vehicle LocationLocation of the vehicle where the LINK device is installed or in case of mobile tracking unit, the location of mobile device that is associated to a vehicle in Webfleet90 days
(France: 60 days)
Vehicle TracksSequence of coherent positions
Vehicle TripsAll trips made by a registered driver with the vehicleCurrent calendar year + 2 full calendar years
Vehicle Name/NumberName/number of the vehicle that has been added in the Webfleet UI by the fleet managerUndefined (data follows object lifecycle)
Vehicle License PlateThe license plate entered by the fleet manager in the Webfleet UI
Vehicle SpecificationVehicle data added automatically or manually by the fleet manager in the Webfleet UI
Vehicle OdometerOdometer of the assigned vehicle, either coming from the CAN or added manually by the driver
Vehicle Push NotificationsPush notifications sent about vehicle assignmentNot persisted
Logbook ReportsPDF or Excel sheets that can be created in the Logbook AppCurrent calendar year + 2 full calendar years

Mobile App: TPMS Tools App

Data CategoryDescriptionRetention Period
Tire pressure current readingsSignals from tire pressure sensors' last reading: pressure, temperature, TPMS sensor battery level (valve mounted sensor)Undefined (data follows object lifecycle)
Tire pressure historical readingsSignals from tire pressure sensors' readings: pressure, temperature90 days
Tire-related configurationVehicle/asset chassis layout, recommended axle pressureUndefined (data follows object lifecycle)

Mobile App: Vehicle Check App

Data CategoryDescriptionRetention Period
Driver Login CredentialsDriver email and password24 months
(France: 2 months)
VIN (Vehicle Identi­fic­ation Number)Used as vehicle identi­fic­ation number
License PlateUsed as vehicle identi­fic­ation number
Driver NameUser includes driver name in Driver Module & assign him/her to a vehicle and to the Vehicle Check App feature
Vehicle Inspection Filled ChecklistDrivers perform vehicle inspections and marks components with defects and what type of defects they have
Vehicle DefectsVehicle damages marked by drivers while doing inspection of a vehicle
Pictures of DefectPictures of damages reported by driver
Driver Notes (related to defect)Notes reported while performing the inspection
Checklist Timestamps & DurationChecklist performance date and time, duration

Mobile App: Webfleet Mobile App

Data CategoryDescriptionRetention Period
AddressesGeolocation data, shipping addresses, way points and EV charging station locations90 days
(France: 60 days)
AreasGeo-zone definitions to determine areas of wanted or unwanted vehicle position
Driver DataDriver name, address, and contact data as phone, email, identi­fic­ation numbers
Orders and Order StatesJob data for drivers, order destinations, attachments, electronic proof of delivery, and order status
Text MessagesMessages exchanged between fleet manager and driver through driver terminals
User-Managed Vehicle DataIndividual vehicle specific­a­tions, additional telematics data (manually) including registration, VIN or license plate, and additional data made accessible by Client
Fleet Manager NotificationsFleet managers can receive notifications of certain driving events (e.g., harsh braking, cornering, racing) and other vehicle data (e.g., on-board diagnostic data, malfunction, trouble codes, fuel level, movements with ignition off, power disconnection etc.) in the app—all manageable in the app90 days
Detailed Position MessagesCurrent/historical location of a vehicle with a LINK device90 days
(France: 60 days)
Ignition ChangesIf and when ignition is switched on and off
Momentary Odometer and Fuel LevelThe current odometer and fuel levels
Trips and Trip Position Data including time stampRegistration of trip start and trip end location and time only – no detailed routeCurrent calendar year + 2 full calendar years
Trip Fuel and Energy ConsumptionFuel and/or energy consumption during a trip
Trip OdometerDistance driven during a trip
VIN (Vehicle Identi­fic­ation Number)17-character unique identifier for a vehicle which displays the car's unique features, specific­a­tions and manufacturer which can be used to track recalls, registrations, warranty claims, thefts and insurance coverage as well as map a vehicle to a particular owner or data subject
Webfleet Video DataAll (live) data from Webfleet Video as available to fleet manager90 days
(France: 60 days)
Driving KPIs and OptiDrive ScoresAggregated driving behavior indicators (speeding, driving events, idling, fuel, constant speed, coasting, green speed, gear shift) and resulting OptiDrive scoresCurrent calendar year + 2 full calendar years
Work Time StatisticsDriver/co-driver check in/out

Mobile App: Work App

Data CategoryDescriptionRetention Period
Driver NameName that the fleet manager enters in the Webfleet UI at driver creationUndefined (data follows object lifecycle)
Driver EmailEmail address that the fleet manager enters in the Webfleet UI at driver creation and which may be used to login
Driver Phone NumberPhone number that the fleet manager enters in the Webfleet UI at driver creation and which may be used to login
Working TimesManually started/paused/ended registration of working times. Automatic working times registration when used with driver card + tachographCurrent calendar year + 2 full calendar years
Remaining Driving TimesFor drivers with tachograph and driver card, the legally allowed remaining driving time is shown in the Work App37 months
Driver/Vehicle AssociationThe vehicle that has been assigned to the driver using the Work AppUndefined (data follows object lifecycle)
Driver License DetailsIncludes name, category, valid from/to — only available if feature is activated
Driver OptiDrive Score, Ranking and Trip DataDriving behavior data (OptiDrive), calculated by the LINK device in the vehicle and only visualized in the Work App: OptiDrive Score, trips with their unique scores and ranking within the company drivers (all set up by the fleet manager in the Webfleet UI)Current calendar year + 2 full calendar years

In the app for 14 days
E-Learning RecordsTitle of the relevant e-learning content, assignment date, due date, start date and completion date — only available if feature is activatedUndefined (data follows object lifecycle)
Vehicle LocationLocation of the vehicle where the LINK device is installed or in case of mobile tracking unit, the location of mobile device that is associated to a vehicle in Webfleet90 days
(France: 60 days)
Vehicle TracksSequence of coherent positions
Vehicle TripsAll trips made by a registered driver with the vehicleCurrent calendar year + 2 full calendar years
Vehicle Routing, Destination & ETARoutes, destinations and estimated time of arrival (ETA) to the destination, as used for navigationUndefined (data follows object lifecycle)
Vehicle Name/NumberName/number of the vehicle that has been added in the Webfleet UI by the fleet manager
Vehicle License PlateThe license plate entered by the fleet manager in the Webfleet UI
Vehicle SpecificationVehicle data added automatically or manually by the fleet manager in the Webfleet UI
Text MessagesShort text messages sent between the driver/vehicle and the fleet manager (within Work App and Webfleet)90 days
(France: 60 days)
Orders and Order UpdatesOrder created by the fleet manager in Webfleet or via WF.connect API, including customer name, address, contact person info (name, phone number), any free text order text/description, signature (ePOD) of the customer, order status data, every kind of update relating to orders (order-related status messages)
Order AttachmentsPDF files and pictures attached by the driver in the Work App or by the fleet manager in the Webfleet UIUndefined (data follows object lifecycle)
ePOD SignaturesSignature of the customer
Driver Trip Mode (Change) in LogbookPrivacy management change events to drive in private/commute or business modesCurrent calendar year + 2 full calendar years
Cold Chain DataTemperature data, violation information – only available if feature is activated1 year
Driving Behavior Feedback (Active Driver Feedback)Instant, in-cab, real-time feedback for drivers, shown in the Work App about driving behavior, including events of harsh breaking, cornering, and racing starts.90 days
(France: 60 days)
Driver Smart NotificationsSmart rules can be set up by the fleet manager in the Webfleet UI and many vehicle notifications can be sent to the driver. Driver will see push notifications and the history of notifications in the Work App90 days
In the app for 14 days
Vehicle OdometerOdometer of the assigned vehicle, either coming from the CAN or added manually by the driverUndefined (data follows object lifecycle)
Generic Push NotificationsPush notifications sent to driver about new incoming text messages, new orders, order updates, new e-learning assigned, etc.90 days

Appendix 2

Sub-Pro­cessors

Webfleet Solutions has engaged the following entities to process Client Data to deliver core features of the Webfleet Telematics Service Platform and the WEBFLEET Service more broadly:

CompanyScope of ProcessingPrincipal Location(s) of ProcessingContact
Amazon Web Services EMEA SARLSecure data hosting services for all Client Data processed as part of Webfleet Solutions' offerings.

Also includes data processing for inference in AI features offered by Webfleet when they are actively enabled by the Client: Webfleet Fleet Advisor, In-App Translation Service.
EEA – Luxembourg, Germany, Franceaws.amazon.com/contact-us
Microsoft Ireland Operations LimitedEEA – North Europemicrosoft.com/en-us/privacy/privacy-support-requests
TomTom International B.V.Provision of services relating to traffic, security cameras, local search, road condition services, weather information and fuel pricing.EEA – The Netherlandstomtom.com
Webfleet Solutions Development Germany GmbHWebfleet Solutions's technology hub which includes Information Technology and Secure Software Development.EEA – GermanySame as Webfleet Solutions: digitaltrust@bridgestone.com

Product- and Service-Spe­cific Sub-Pro­cessors

Webfleet Solutions has engaged the following entities to process Client Data to deliver specific features of the Webfleet Telematics Service Platform, as individually highlighted below. To the extent that Client does not use certain features listed below, the Sub-Processor involvement that apply only to those unused features will not apply to Client:

CompanyScope of Processing/ServicePrincipal Location(s) of ProcessingContact
BIA Power Grid, S.L.Provision of data and services regarding EV charging stations as part of the provision of the EV Charger Monitoring services provided by Webfleet Solutions. This enables the sending of commands to the charger to manage charge sessions and the receipt of charger and charge session data for processing in the Webfleet Telematics Service Platform.EEA – Spainbiapower.io
Bridgestone Europe NV/SAProvision of tire pressure monitoring events and related data (Tirematics) in the context of Webfleet Solutions's tire pressure monitoring service (TPMS).EEA – Belgium, Irelandbridgestone.com
DAKO Systemtechnik und Service GmbH & Co. KGProvision of services related to the operation of the WEBFLEET Tachograph Manager.EEA – Germanydako.de
Google Ireland LimitedProvision of push notifications (Firebase Messaging) in the Webfleet mobile applications.EEA, Google Cloud Platform Locationscloud.google.com/contact
Jibe Mobility B.V.Provision of EV charger­-re­lated data and services in the context of the EV Charger Monitoring services provided by Webfleet Solutions. This enables the receipt of charger and charge session data for processing in the Webfleet Telematics Service Platform, as well as to other charger management systems that the Client uses.EEA – The Netherlands, Romaniajibe.company
LeMobi Leszek ChwalinskiProvision of e-toll collection and management services in Poland and Hungary.EEA – Poland, Hungarylemobi.pl
Lytx, Inc.Provision of data processing services and customer support associated with the operation of CAM 50 Webfleet Video solutions.EEA – Luxembourg
United Kingdom *,
Israel *
lytx.com
Longship IT Solutions B.V.Provision of data and services regarding EV charging stations as part of the provision of the EV Charger Monitoring services provided by Webfleet Solutions. This enables the sending of commands to the charger to manage charge sessions and the receipt of charger and charge session data for processing in the Webfleet Telematics Service Platform.EEA – The Netherlandsevesto.com
MiTAC Digital Technology CorporationStrictly in the operation of the CAM Lite & CAM Pro Webfleet Video solutions and exclusively upon explicit request of Webfleet Solutions: providing troubleshooting and technical support services for system deployments, config­ur­a­tions, updates, corrections and improvements.Taiwan **mitacmdt.com/en
Peregrine Technologies GmbHStrictly in the operation of the Enhanced Road Safety feature exclusive to the CAM Pro Webfleet Video solution aimed at detecting critical situations, such as speed sign violations, red-light violations, difficult road or weather conditions, and truck size or weight restrictions.EEA – Germanyperegrine.ai
Verkeersveiligheid Groep Nederland B.V.Provision of an independent e-learning platform for driver coaching services, including audiovisual content, quizzes, course completion tracking, and quiz performance scoring.EEA – The Netherlandsverkeersveiligheidgroep.nl

* Data processing outside the European Economic Area carried out based on Article 45 GDPR.

** Data processing outside the European Economic Area carried out based on Article 46(2)(c) GDPR.

Appendix 3

OEM & Third-Party Integrations Data Processing Terms

1. Applicability & Precedence. This Appendix governs Client-ini­tiated processing of Client Data in connection with third parties other than the Sub-Pro­cessors listed in Appendix 2. Third parties may include OEMs and independent providers offering integrations with the WEBFLEET Service (each a Third-Party Integration Provider and, together with OEMs, Integration Providers). For clarity, this Appendix 3 does not apply to Vehicles from OEM brands listed in Section 3 that have not been linked to the WEBFLEET Service via the applicable OEM Platform under the OEM Schedule. If there is a conflict between this Appendix 3 and the DPA, this Appendix 3 prevails with respect to the processing of Client Data in Client-ini­tiated integrations to the extent of any inconsistency.

2. On-Demand Third-Party Data Processing Enablement. By enabling a connection between the WEBFLEET Service and an Integration Provider, Client issues documented instructions to Webfleet Solutions to send, receive, and otherwise process Client Data to/from that Integration Provider as needed for inter­op­er­ab­ility with the WEBFLEET Service:

  1. OEM Onboard Units. If Client uses OEM Onboard Unit interfaces, Webfleet Solutions' enablement thereof in the WEBFLEET Service is (1) subject to the OEM Schedule and (2) contingent on per-Vehicle authen­tic­ation and consent via Webfleet Solutions' secure methods and/or the OEM Platform following each OEM's requirements.
  2. Third-Party Integration Providers. If Client links services from Third-Party Integration Providers to the WEBFLEET Service, Webfleet Solutions' enablement thereof occurs upon (1) Client's request (via the WEBFLEET Service user interface or Webfleet Solutions' support channels) and (2) the ensuing linkage of Client's WEBFLEET Service environment to the provider using credentials securely managed by Webfleet Solutions.

3. OEM Integrations. Depending on the OEM integration(s) selected by Client, Client acknowledges and agrees that Client Data will be further processed by the following OEMs, as the case may be:

Legal EntityRelevant Vehicle Brand GroupPrincipal Location of ProcessingOEM Specific­a­tions & Contact
Bayerische Motoren Werke AGBMW GroupGermanybmw.com
Ford Smart Mobility U.K. LimitedFord GroupEngland *ford.com
Mercedes-Benz Connectivity Services GmbHMercedes-Benz GroupGermanymercedes-benz.com
Mobilisights S.p.A.Stellantis GroupItalymobilisights.com
Renault S.A.S.Renault GroupFrancerenaultgroup.com
TB Digital Services GmbHTraton GroupGermanycompany.rio.cloud
Volkswagen Group Info Services AGVolkswagen GroupGermanydrivesomethinggreater.com

* Data processing outside the European Economic Area carried out based on Article 45 GDPR.

4. Processing of Client Data by Integration Providers. Webfleet Solutions does not control and is not responsible for Integration Providers' services, including their security, availability, or compliance. Furthermore, given the limited scope of Client Data processed per selected integration, Client acknowledges and agrees that each Integration Provider will independently:

  1. Technical Specific­a­tions. Define, maintain, and update the technical methods/specific­a­tions for data made available to Webfleet Solutions for further processing within the WEBFLEET Service. All such data is provided as is/as available without any repres­ent­ation or warranty by Webfleet Solutions to Client regarding accuracy or quality;
  2. Purposes and Means. Determine the purposes and means of processing for data generated, collected, or otherwise processed under the services each Integration Provider provides to Client, including any further (sub-)processing on its behalf;
  3. Security. Implement and maintain its own technical and organ­iz­a­tional measures to protect Client Data, ensure lawful processing, and conduct its own security audits/assessments of data processing environments;
  4. Security Incidents. Receive notifications from Webfleet Solutions of (suspected) personal data breaches, including and related follow-up commu­nic­a­tions aimed at protecting Client Data and complying with applicable law;
  5. External Access Requests. Receive notifications from Webfleet Solutions of binding requests for access to Client Data by governmental (law-en­forcement) authorities or comparable requests, to the extent permitted by law;
  6. Cooperation. Remain responsible for cooperation requested by Client relating to security of processing, access to data, data subject requests, DPIAs, audits, breaches, and prior consultation with Supervisory Authorities insofar as those requests concern processing by the Integration Provider. Requests for audits or assessments of an Integration Provider's environment must be pursued by Client under Client's agreement with that Integration Provider; Webfleet Solutions will reasonably coordinate to the extent such requests involve the WEBFLEET Service, in line with the provisions of the DPA;
  7. Service Changes and Availability. Subject to the terms of the agreements referred to in Items 5 and 6 below, suspend, terminate, or change their services. Disruptions in an Integration Provider's services may result in irretrievable loss of Client Data expected from that provider, without liability of Webfleet Solutions. Webfleet Solutions' service levels, availability, support, and data-­freshness commitments under the Agreement exclude data feeds, functionality, latency, or outages attributable to Integration Providers outside of Webfleet Solutions' control.

5. Client's Independent Agreements. Client's use of Integration Providers with the WEBFLEET Service depends on Client's lawful use of the relevant Vehicles, Onboard Units, and services those providers supply to Client. Client's separate agreements with each Integration Provider (including the OEM Platform terms) solely govern that relationship. Client is exclusively responsible for complying with those terms, including in its use of the WEBFLEET Service. Client may consult (1) its own contracts and the websites listed in Item 3 (for OEMs) and (2) its contracts and websites of each Third-Party Integration Provider to understand features, behavior, settings, specific­a­tions, requirements, and limitations applicable to the offerings of each Integration Provider.

6. Webfleet Solutions' Independent Agreements. Webfleet Solutions maintains OEM Agreements with the OEMs listed in Item 3 and separate agreements with Third-Party Integration Providers. Shared processing of Client Data between Webfleet Solutions and any Integration Provider at Client's direction is subject to the continued effectiveness of these agreements. If any such agreement terminates, affected WEBFLEET Service features or data-­pro­cessing capabilities will be adjusted accordingly. Where an OEM Agreement involves an OEM processing personal data in Client Data in the capacity of a Sub-Processor, then Section 3 of the DPA applies to Webfleet Solutions' engagement of that OEM.

Appendix 4

Technical & Organ­iz­a­tional Measures

Webfleet Solutions maintains an ISO/IEC 27001 certification (available on request) which covers Webfleet Solutions' scope of processing of Client Data detailed in the DPA and includes the below technical and organ­iz­a­tional measures to ensure the security of Client Data:

Technical & Organ­iz­a­tional Measures | Confid­en­ti­ality of Client Data

DomainDescription of Measures and their Purposes
Access Control
Buildings, Offices, Data Centers
  • Alarm system
  • Automatic access control system
  • Photoelectric sensors / Movement detectors
  • Key Management (Issuance of keys, etc.)
  • Logging of visitors
  • Careful selection of security guards
  • Protection of building shafts
  • Chip card / Transponder locking system
  • Manual locking system (Limited usage for key employees to be used in the event of a failure in the access control systems)
  • CCTV at entry points (office and data centers)
  • Security locks
  • Visitor management at reception desks
  • Careful selection of cleaning staff
  • Visible wearing of access badges mandatory
  • A separate, specific, and documented access control for data centers and/or server rooms for authorized persons is implemented. Access by authorized persons is documented by name and card or token number. For the data centers, separate access control systems are implemented.

Purpose: Prevent unauthorized access to data processing systems where Client Data is processed.

Access Control
Systems
  • Assignment of user rights
  • Assignment of passwords
  • Authen­tic­ation with username / password
  • Use of Intru­sion-­Pre­ven­tion-Systems
  • Use of software/hardware firewalls
  • Creation of user profiles
  • Additional measures: web-ap­plic­ation firewalls, regular vulnerability scans, regular penetration testing, patch management, minimum requirements for password complexity and forced password changes, use of virus scanners
  • Assignment of user profiles to IT systems
  • Use of VPN Technology
  • Encryption of mobile storage media
  • Use of central smartphone admin­is­tration (for example: remote wiping of smartphone)
  • Disk encryption on laptops / tablets

Purpose: Prevent unauthorized use of systems where Client Data is processed.

Access Control
Client Data
  • Creation of an authorization concept
  • Number of admin­is­trators reduced to absolute necessary
  • Logging of application access, especially during the entry, modification, and deletion of data
  • Secure media sanitization before re-use
  • Use of shredders or services (if possible, with privacy seal)
  • Disk encryption (laptops)
  • Management of rights by system admin­is­trators
  • Password policy including password length, password change management
  • Secure storage of data carriers
  • Logging of secure media destruction
  • Compliant destruction of data media (DIN 66399 / ISO/IEC 21964)

Purposes:(1) Ensure that authorized users of a system where Client Data is processed may only access the Client Data for which they are authorized, and (2) prevent Client Data from being read while the data is in use, in motion, or at rest without authorization.

Segregated Processing
  • Creation of an authorization concept
  • Provision of records with purpose attributes / data fields
  • Approved and documented database rights
  • Logical client separation (in software)
  • In pseudonymized data: separation of the mapping file and storage on a separate secured IT system
  • Separation of production and test systems

Purpose: Ensure that Client Data collected for different purposes can be processed separately.

Technical & Organ­iz­a­tional Measures | Integrity of Client Data

DomainDescription of Measures and their Purposes
Transfer Control
  • Creation of dedicated lines or VPN tunnels
  • Documentation of recipients of data and the time periods for the provision of data including agreed deletion times
  • Disclosure of data in anonymous form
  • Creation of an overview of regular request and delivery operations
  • During physical transport, secure transport containers / packaging
  • TLS encryption of all commu­nic­a­tions (web-client, APIs, mobile apps)

Purpose: Ensure that Client Data cannot be read, copied, or modified during electronic transmission or during trans­port­ation or storage to disk. Additionally, to control and determine to which bodies the transfer of Client Data provided by data communication equipment is allowed.

Input Control
  • Logging of input, modification, and deletion of data
  • Traceability of input, modification, and deletion of data by individual usernames (not user groups)
  • Granting of rights for the input, modification or the deletion of data based on an authorization concept
  • Creation of an overview of which applications are permitted to input, modify, or delete which data

Purpose: Control and monitor if and by whom Client Data has been entered, changed, or removed on data processing systems.

Technical & Organ­iz­a­tional Measures | Availability of Client Data & Resilience

DomainDescription of Measures and their Purposes
Availability Control
  • Uninter­ruptible power supplies (UPS)
  • Devices for monitoring temperature and humidity in server/communication rooms
  • Fire and smoke detection systems
  • Alarm when unauthorized entry to server rooms is detected
  • Testing of data recovery
  • Secure off-site storage of data backups
  • In flood areas: server/communication rooms above the water border
  • Air conditioning in server/communication rooms
  • Protection power strips in server/communication rooms
  • Fire extinguishers in server/communication rooms
  • Creation of a backup & recovery concept
  • Prepare an emergency response plan
  • Server/communication rooms not located under sanitary installations
  • Service operation is distributed over three Availability Zones in AWS Frankfurt

Purpose: Ensure that Client Data is protected against accidental destruction or loss.

Technical & Organ­iz­a­tional Measures | Organ­iz­a­tional Management

DomainDescription of Measures and their Purposes
Organ­iz­a­tional Efforts
ISMS & DPMS
  • Comprehensive Information Security Management System (ISMS)
  • Robust Incident Response Management Framework
  • Recurring training for all teammates on information security, privacy, and data protection
  • Informative and aware­ness-raising events focusing on information security, privacy, and data protection matters
  • Comprehensive set of information security policies and controls in line with ISO27001 standards
  • Data Protection Management System (DPMS) following Bridgestone West policies and standards
  • Continuous application of the privacy by design and default principles in product development cycles

Purpose: Ensure that the Webfleet Solutions' workforce is sufficiently informed, educated and engaged on information security, privacy and data protection topics in a way that matches the roles and specific exposure to Client Data of each teammate.

Third Party Management
Sub-Pro­cessors
  • Sub-Processor vetting and selection via history review (in particular data security)
  • Written instructions to Sub-Processor (for example, by DPA) (GDPR)
  • To the extent required: ensure Sub-Processor have appointed a Data Protection Officer
  • Effective control rights over Sub-Pro­cessors have been agreed
  • Prior examination of the documentation and the security measures taken by Sub-Processor
  • Obligation of the Sub-Processor's employees to maintain confid­en­ti­ality over Client Data
  • Ensure the secure destruction of Client Data after termination of the Sub-Processor contract
  • Continual review of Sub-Processor and their activities

Purpose: Ensure that Client Data processed by a Sub-Processor is only processed as instructed by the Client.

Data Access Specification Sheet

Under development

This Data Access Specification Sheet is currently under development.

The most up-to-date version, once available, can be consulted at webfleet.com/dpa.