PRIVACY NOTICE FOR THIRD PARTY PROVIDED SERVICES
Last Updated: July 2025
This Privacy Notice applies to the processing of Personal Data (as defined in Section 1 below) by Nexar Inc. and its affiliates ("Nexar", "we", "our" or "us") in relation to services provided by Nexar to fleets of vehicles ("Fleets") where such services are provided to them via a third party, such as an insurance company, reseller of Nexar or another Nexar partner (the "Partner").
In this Notice, when we refer to our "Services" we mean our smart dashboard cameras ("Cameras") provided to Fleets by the Partner including the Nexar dashboard, to which the Fleet Manager (as defined below) has view access.
Specifically, this Privacy Notice describes how Nexar, collects, stores, uses and discloses Personal Data about the following categories of individuals:
- Drivers: The employees and/or contractors of the Fleet who are driving from time to time the Fleet's vehicles in which the Cameras were installed.
- Fleet Managers: Owners of the Fleets, who sign a contract with the Partner to receive our Services.
If you are a Fleet Manager or Driver (collectively, "Users", "you" and "yours"), please read this Privacy Notice carefully and make sure that you fully understand it and agree to it.
In addition, please refer to the Partner's Privacy Policy to learn how the Partner handles Personal Data collected in connection with the services it provides to you.
You are not legally required to provide us with any Personal Data. If you do not wish to provide us with your Personal Data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us, avoid interaction with us and our Services, and do not use our Services.
Data Collection & Processing
When we use the terms "Personal Data" or "Personal Information" in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include anonymous, aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Types of Personal Data collected or generated:
- Account Information (app/dashboard credentials, Fleet Manager's contact details and billing and shipping information).
- Driver Data (driver's name, email and the unique fleet identifier assigned to the Driver by its Fleet Manager).
- Insurance Information (vehicle Identification Number (VIN), policy ID, claim ID, driver details and identifier, and information about your insurance broker or agent).
- Collision Reports (reports created based on recordings of traffic incidents, collisions, road conditions, or violations, which may be shared with you, the Partner (from example, if the Partner is an insurer) or other third parties, subject to your authorization, and as outlined in Section 5 below. Collision reports may also include location and time of the accident, photos, license plates, and insurance information of those involved. If you decide to send that report to your insurer, we'll collect data to monitor the performance of the submission process).
- Camera-Generated Content (images and videos, sensor data, location, GNSS location data, data obtained from your device's gyroscope and accelerometer sensors, and user ID).
- Communication Data (Personal Data contained in (a) communications with the Fleet Manager or Drivers (e.g., when we provide support), or (b) interactions between Drivers through our services)
- Derived Data (information, reports, data, and materials Nexar develops, generates, creates, or derives from or based on Camera-Generated Content. Derived Data mainly consists of anonymized information, but may include residual Personal Data limited to locations, or third parties' faces and license plates contained in footage or images captured by the Cameras).
- Usage Data (technical usage data relating to the manner in which Users use our Services, which may constitute Personal Data if it can be used to identify them. This may include connectivity, technical and aggregated information, such as your ride start and end locations; IP addresses, wireless networks, cell towers and Wi-Fi access points; non-identifying data regarding a device, operating system and browser; activity, communication and performance logs; issues and bugs; and user activity on our Services).
For the purposes of the California Consumer Privacy Act ("CCPA"), in the last 12 months, we have collected the following categories of Personal Information, as defined in the CCPA: identifiers; geolocation data; customer records information; commercial information; internet or other electronic network activity information; audio, electronic, visual, or similar information; professional or employment related information; inferences; and Sensitive Personal Information (as defined in the CCPA and as described above).
We collect Personal Information from the following sources:
- Data collected directly from you.
- Data collected from the Partner.
- Data collected from publicly available sources.
- Data that is automatically generated.
Data Uses
We use Personal Data for the following business and commercial purposes, and, where applicable, in reliance on the legal bases noted next to them, as appropriate:
Purpose
Legal Bases for Processing
Providing and improving our services
To operate, deliver, improve and enhance our Services, customize your experience, and develop new features.
Legitimate Interest
Supporting and maintaining our services
To provide customer support, fix technical issues, and ensure the proper functioning of our services.
Legitimate Interest
Personalizing your experience
To recognize individuals on our Services, remember preferences, and provide personalized content and localization.
Legitimate Interest
Ensuring security and preventing fraud
To protect our Services and Users from fraud, errors, and illegal activities.
Legitimate Interest; Legal Obligation
Communicating with you
We use your contact details to send service-related updates and respond to your inquiries. We may also share promotional messages (with your consent).
Legitimate Interest; Consent
Anonymizing data for business and commercial purposes
We use the anonymized data for the following purposes:
In connection with our CityStream Service: To improve safety and driving experience. The data is utilized on CityStream and shared with our trusted third-party partners for mapmaking purposes.
While we make significant efforts to ensure full anonymization in the data, you or any data subject may submit a Takedown Request for anonymized content related to a specific location, provided you can demonstrate a valid right to request its removal (i.e., if it includes your identified or identifiable information). For more information on how we anonymize Personal Data, please see our Anonymization White Paper.
To collect and share driving scenarios: To create anonymized videos of real-world driving scenarios to support the development, evaluation and testing of advanced driving technology.
Consent
Improving and Innovating Our Technology and Anonymization Technics
Considering our company mission to contribute to a safer and more efficient driving experience, it is of utmost importance that we continuously develop our Vision AI algorithms, which are used to perform object detection and image classification that produce relevant information for our products. A critical requirement of this development process is the need for training data. Training data is made of certain portions of Camera-Generated Content captured by both in-cabin and road-facing Cameras. It may capture third-party data subjects, such as pedestrians and other vehicle drivers, license plates and other potentially identifiable details.
We use it in the following ways:
To enhance existing services and pioneer new features designed to improve driving conditions; To develop our safety-related events detection algorithms, such as distracted driving, by analyzing the behavior of drivers and passengers within the vehicle; To identify a wide range of road assets and work zones and to assess overall road conditions; To develop and refine state-of-the-art anonymization techniques to ensure the privacy of data subjects.
Despite the inclusion of non-anonymized content, we uphold the highest standards of data security and privacy:
Access to training data is strictly confined to the team members directly involved in the AI development process;
We employ advanced encryption and stringent access controls to safeguard against unauthorized access to the data; The training data is retained exclusively for a limited period of time for the training purposes for which it was collected, ensuring it is not used beyond its intended scope;
The training data closely mirrors the lifecycle of Personal Data. When a User decides to delete their rides or deactivate their account, we ensure that the corresponding training data is also deleted from our systems.
Legitimate Interest
Generating insights and statistics
To create aggregated statistical data, inferred non-Personal Data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services or for any other purpose. We create aggregated, non-Personal Data to analyze trends and improve our Services for everyone.
Legitimate Interest
Marketing and advertising
To manage marketing campaigns, deliver relevant ads (which may include anonymized Camera-Generated Content) and for the management of sales operations, including on other websites and applications. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners. We also use anonymized content for marketing purposes (e.g., using anonymized footage in commercial ads).
Legitimate Interest; Consent
Collaborating with marketing affiliates
To engage with marketing affiliates and perform contracts with them and our business partners.
Legitimate Interest
Compliance with legal and contractual obligations
To comply with laws and regulations, enforce our Terms and Conditions for Fleets, resolve disputes, carry out our regularity and contractual obligations and enforce our rights, and protect our business interests and the interests and rights of third parties.
Legal Obligation; Legitimate Interest
If you reside or are using the Services in a territory governed by privacy laws under which "consent" is the only or most appropriate legal basis for the processing of Personal Data as described herein (in general, or specifically with respect to the types of Personal Data you expect or elect to be processed by or via the Services, or due to nature of such processing) ("Consent"), your acceptance of our Terms and Conditions for Fleets and this Privacy Notice (collectively, the "Terms") will be deemed as your consent to the processing of your Personal Data for all purposes detailed herein, unless applicable law requires a different form of Consent. If you wish to revoke such consent, please contact us at privacy@getnexar.com.
Data Location and Transfers
We and our authorized Service Providers (as defined in Section 5) maintain, store and process Personal Data in the United States, Canada, Europe, Japan, Australia, Mexico and the United Kingdom, Israel and other locations, depending on where you are using our Services and as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
While privacy laws may vary between jurisdictions, Nexar is committed to protecting Personal Data in accordance with this Privacy Notice, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
Nexar and its subsidiaries are headquartered in Israel, which is recognized to be offering an adequate level of protection for the Personal Data of European Economic Area (EEA) and UK residents by the European Commission and the UK Secretary of State. We transfer Personal Data from the EEA and the UK to Israel on this basis. In addition, Nexar has affiliates in the USA, Israel, Portugal and Japan. Personal Data is transferred to these locations.
For data transfers from the EEA or UK to countries that are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission and UK Information Commissioner's Office (ICO). You can obtain a copy by contacting us via privacy@getnexar.com.
Data Retention
We retain Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, as necessary for allowing our Users' insurers to meet their own obligations or legitimate needs, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy. Without derogating from the foregoing, the retention of Derived Data used for as training data (as described in Section 2) is limited to the lifecycle of the Personal Data of the User to which it relates. Consequently, if a User requests to delete their Personal Data held with us, we will also delete the User's respective training data.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at privacy@getnexar.com.
Data Disclosure
We disclose Personal Data in the following ways:
Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant, or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so and solely to the extent that we believe is strictly necessary to comply, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (b) such disclosure is required to protect our legitimate business interests, including the security or integrity of our Services.
Service Providers: We may engage selected third-party companies and individuals to perform services complementary to our own. Such Service Providers include hosting and server co-location services, communications and content delivery networks (CDNs), data analytics services, mapping services, marketing and advertising services, data and cyber security services, fraud detection and prevention services, billing and payment processing services, e-mail and SMS distribution and monitoring services, session or activity recording services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, support and customer relation management systems, and our business, legal, financial and compliance advisors (collectively, "Service Providers"). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes and in accordance with our agreements with them.
Insurance Companies: When you receive our Services as a part of your insurance plan, the insurer will have access to your Camera-Generated Content in order to provide you with the insurer's services. Additionally, we may notify the insurer of probable road collisions involving you and/or third parties and share with it any related recordings, data and reports in accordance with the instructions of the insurer, in cases where your use of our Services is part of your agreement with the insurer, and you have granted your insurer authorization to receive such recordings or reports from us/
Members of your Fleet: Your Personal Data may be shared with other members of your Fleet in accordance with the sharing settings of the Fleet (which are managed by the Fleet Manager). We advise Fleet Managers to review the sharing settings of their Fleets and adjust them per their needs. Fleet Managers gain access and visibility into their Drivers' location data, ride videos (live or post ride), and alerts concerning incidents during the ride. Fleet Managers may also appoint additional administrators for their Fleet, who will also gain access and visibility to all or some of this data, depending on the privileges set by the Fleet Manager. For more information about the role of Fleet Managers as "data controller" of Personal Data, please see Section 10 below.
Mapmaking Partners: We share Derived Data with our business partners, whose mapmaking services benefit from the up-to-date mapping information provided by our platform. Please note that once Personal Data is anonymized, we will not be able to trace it back to you. Therefore, Users will not be able to request deletion or rectification of anonymized data or exercise any other privacy rights (as described in Section 9) in relation to it.
Third-Party Websites and Services: Our Services may include links to third-party websites and integrations with third-party services. Such websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by such third-party's terms and privacy practices and policies and not by this Privacy Notice. We encourage you to carefully read the terms and privacy policies of such websites and third-party services. We do not receive or store your passwords for any of these third-party services.
Protecting Rights and Safety: We may share Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Nexar, any of our users or any members of the general public.
Nexar Subsidiaries and Affiliated Companies; Change of Control: We may share Personal Data internally within our group for the purposes described in this Privacy Notice. In addition, should Nexar or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, or will be considered or found eligible for a governmental grant and/or a potential investment, Personal Data may be shared with the parties involved in such an event. If we believe that such an event might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.
Additional Sharing: For the avoidance of doubt, Nexar may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
For the purposes of the CCPA, specifically in the past 12 months, we may have disclosed to the third parties listed above the following categories of personal information: Identifiers; Professional or employment-related information; Internet or other electronic network activity information; Customer records information, Audio, electronic, visual, thermal, olfactory, or similar information; Inferences from personal information collected, and geolocation information.
Cookies and Data Collection Technologies
We and our Service Providers use "cookies", anonymous identifiers, pixels, and other technologies to provide our Services and ensure they perform properly, analyze our performance and marketing activities, and personalize your experience. Such cookies and similar data collection technologies or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, previously indicated by a User.
Please see our Cookie Policy for more information about the types of cookies we use, or click the "Cookie Settings" at the bottom of our website's homepage to set your preferences.
Communications
We engage in service and promotional communications through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset instructions, etc. You can typically control your communications and notifications settings from your Nexar user profile settings or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Notifications and Promotional Communications: We may send you notifications concerning messages and other updates in your user account (such as messages concerning collision reports, road conditions etc.). We may also send you notifications about new features, additional offerings, events, webinars, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. SMS, phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Nexar at any time by sending an e-mail to: privacy@getnexar.com, changing your communications preferences in your user profile settings, or by following the "unsubscribe", "stop", "opt-out" or "change e-mail preferences" instructions contained in the promotional communications you receive.
Data Security
We and our hosting services implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security, confirmed also by Nexar's ISO/IEC 27001 and 27018 certifications. However, although we make efforts to protect your privacy and data, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties.
Data Subject Rights
If you wish to exercise your privacy rights under any applicable law, including (to the extent applicable) the EU or UK General Data Protection Regulation (GDPR or UK GDPR, respectively) or the California Consumer Privacy Act (CCPA), such as the right to request access to, and rectification or erasure of your personal data held with Nexar, or to port such personal data.
If you wish to exercise your right to restrict or object to such personal data processing or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at: privacy@getnexar.com. If you are an individual subject to the GDPR/UK GDPR, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable.
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above. We may redact any personal data related to others from the data we will make available to you.
To the extent applicable to you, you may designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.
When you or an authorized agent ask us to exercise any of your rights, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. We may not be able to fulfil your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the Personal Data. We may then request additional information for legal purposes (e.g., as proof of the identity of the person submitting the request, or proof of request fulfillment).
We may redact from the data which we will make available to you, any Personal Data or confidential information related to others.
If you are a resident of Virginia, Colorado or Connecticut, you may also have the right to appeal if we decline to take action regarding your request. We will notify you providing our reasons and instructions for how you can appeal the decision. If you are a Colorado resident, you may also have the right to contact the Colorado Attorney General if you have concerns about the result of the appeal.
Roles and Responsibilities
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the "data controller" (or under the CCPA, "business"), who determines the purposes and means of processing; and the "data processor" (or under the CCPA, "service provider"), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Nexar is the "data controller" of Account Information, Derived Data and Usage Data. As such, we assume the responsibilities of the data controller (solely to the extent applicable under law), as set forth in this Privacy Notice. Where we use Service Providers to process such data, the relevant Service Provider will assume the role of "data processor".
Nexar is the "data processor" of Driver Data, Insurance Information, Collision Reports, Camera-Generated Content and Communication Data. With respect to such data, the respective Fleet Manager assumes the responsibilities of a data controller and will be responsible for meeting any legal requirements applicable to data controllers (such as establishing a legal basis for personal data processing or meeting transparency requirements). As the data controller, Fleet Managers instruct us how and for what purposes to process such data as further stipulated in our Terms and Conditions for Fleets and Data Processing Addendum incorporated therein or other commercial agreements we have entered into with such Fleet Managers. The Data Processing Addendum contractually requires Fleet Managers to ensure the legality of the processing of the Personal Data of their Drivers. As a data controller, each Fleet Manager is solely responsible for providing adequate notice to their Drivers and obtaining their consent for the processing of their Personal Data as required under applicable laws.
Additional Notices and Contact Details
Updates and Amendments: We may update and amend this Privacy Notice from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.
External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third-parties, and to read the privacy policies of each and every website and service you visit. This Privacy Notice applies only to our Services.
Our Services are not designed to attract children under the age of 16: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make all efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at privacy@getnexar.com.
Data Protection Officer: Nexar has appointed PrivacyTeam Ltd. As its Data Protection Officer, for monitoring and advising on Nexar's ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding this Privacy Notice, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by Nexar, you can contact privacy@getnexar.com or our DPO at dpo@getnexar.com.
EU and UK Representative: We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact in the EU and UK. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit the following website https://prighter.com/q/13925556347.
Questions, concerns or complaints: if you have any comments or questions about this Privacy Notice or if you have any concerns regarding your privacy, please contact us at privacy@getnexar.com. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.
