Data processing agreement

The controller is the fleet, represented by the account that accepts this agreement. The processor is Human Hygiene Kft., Datolya utca 40, 1163 Budapest, Hungary (company registration 01-09-464537), trading as FleetFault.

FleetFault processes the fleet’s data for as long as the fleet exists on FleetFault: from the day its manager accepts this agreement until the fleet is deleted in Settings. Deleting the fleet ends this agreement with it.

FleetFault stores and shows the fleet its own vehicles and their QR stickers, the fault reports filed against them and their photos, and the fleet’s alert addresses, and sends the alert e-mails those addresses ask for. It processes this data only to run the service the fleet signed up for: showing the fleet its own reports, sending its own alerts, and letting it export or delete its own data.

Data subjects are the fleet’s drivers, who file a report with no account of their own, and the people named in the fleet’s alert addresses. The personal data processed is: a fault report’s description and category, and whether the vehicle is still drivable; the odometer reading, the driver’s name and phone number if the driver gives them; the location if the driver adds it; up to three photos per report; and the e-mail addresses the fleet lists under Settings → Notifications.

FleetFault processes the fleet’s data only on the fleet’s documented instructions, given through the product itself (adding a vehicle, changing a report’s status, adding or removing an alert address, exporting or deleting data) or in writing to support@mixtape.works. If FleetFault believes an instruction would break the GDPR or another EU data protection law, it tells the fleet before carrying it out.

Anyone at Human Hygiene Kft. who can reach a fleet’s data is bound to keep it confidential, whether by an employment contract or a separate agreement.

FleetFault keeps the fleet’s data behind TLS in transit, signs accounts in with no password of its own (the mixtape account does that), keeps a session only as a salted hash, and limits database access to the staff who run the service. These measures are reviewed as the service changes, under GDPR article 32.

FleetFault uses Hetzner Online GmbH (hosting, Finland), Amazon Web Services EMEA SARL (alert e-mails, sent from Frankfurt, Germany) and, as the backup for alert e-mails, Resend, operated by Plus Five Five, Inc. (United States), as the privacy notice also says. This is a general authorisation: FleetFault may add or replace a sub-processor, and tells the fleet’s manager by e-mail at least 30 days before a new one takes on the fleet’s data, so the fleet can object. Every sub-processor is bound by a written agreement giving the fleet’s data the same protection as this one.

FleetFault helps the fleet answer a driver’s or an alert recipient’s request about their own data, and helps with a data protection impact assessment or a consultation with a supervisory authority, to the extent the nature of the processing allows and information reasonably available to FleetFault permits.

FleetFault tells the fleet’s manager without undue delay after becoming aware of a personal data breach affecting the fleet’s data, with what it knows at the time about what happened, what it affects, and what is being done about it.

When the fleet is deleted in Settings, FleetFault deletes the fleet’s vehicles, reports, photos and alert addresses with it; nothing is kept back. A fleet’s manager can also export every report as a CSV file from the dashboard at any time before then.

FleetFault gives the fleet the information it reasonably needs to show this agreement is being kept, and allows the fleet, or an auditor it names, to check that, with reasonable notice.

A fleet’s manager accepts this agreement once, in Settings → Data processing agreement. Accepting records the account’s e-mail address and the time, and that record is kept as long as the fleet account is.