Carter Express, Inc. (“Company”) may collect, store, and use Biometric Data for certain purposes described below, and it may disclose that Biometric Data in certain circumstances. This Policy explains what that means for you, and how you consent to Company’s activities.
Definitions
“Biometric Data” as used in this Policy includes both: (i) “Biometric Identifiers”, meaning a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry or other physiological traits. Biometric Identifiers do not include writing samples, written signatures, photographs, human biological samples used for scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color; and (ii) “Biometric Information”, meaning any information, regardless of how it is captured, converted, stored, or shared, that is based on Biometric Identifiers, including a facial, retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry, that is used to identify an individual.
Data Collection and Purpose
Company uses Samsara Inc.'s (“Samsara”) AI dash cameras and software technology to manage our fleet and improve driver safety. The Samsara AI Dash Cam includes both a road-facing camera to capture video footage of critical events, along with an inward facing camera. Samsara’s inward facing dash camera technology operates, in part, through scans of a driver’s face and therefore may involve the collection of Biometric Data under Illinois law. Samsara's technology allows Company to use the data collected to analyze driving and driver performance, analyze driver distractions, identify driver fatigue, improve customer service, optimize efficiency, improve safety, and to analyze harsh driving events in the Samsara Dashboard. Using the features on Samsara's camera enhances safety by increasing the efficacy of Samsara's driver-based insights and also helps Company maintain accurate logs of our operations.
The data collected using Samsara’s AI Dash Cam will be disclosed to Samsara and stored on Samsara’s Cloud Dashboard. Samsara will have access to the data to perform the functions of its services agreement with Company. A copy of Samsara’s privacy policy is available at https://www.samsara.com/support/privacy/.
Data Storage, Protection and Disclosure Policy
Company’s policy is to protect and store Biometric Data in accordance with applicable laws and regulations, including, but not limited to, the Illinois Biometric Information Privacy Act. Specifically, Company shall use a reasonable standard of care to store, transmit and protect from disclosure any Biometric Data collected. Such storage, transmission and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which Company stores, transmits and protects from disclosure other confidential and sensitive information, including personal information that can be used to uniquely identify an individual such as social security numbers.
Any Biometric Data collected from drivers using Samsara’s AI dash cameras will not be disclosed to parties other than Company or Samsara, except in the following circumstances: (1) after Company obtains appropriate written consent from the driver(s); (2) when disclosure completes a financial transaction requested or authorized by the driver(s); (3) when disclosure is required by federal, state, or local law; or (4) when disclosure is required by a valid subpoena or warrant issued by a court. Within Company, the Biometric Data may be shared with only those employees who have a need to know for a specific business purpose.
Retention and Destruction of Biometric Data
Company will retain any Biometric Data collected using the Samsara AI Dash Cam during the time that an individual is employed by Company in a role for which the Samsara AI Dash Cam is used. At the conclusion of the employment relationship, or upon an employee’s transfer to a position for which the Samsara AI Dash Cam is not utilized, whichever occurs first, Company will permanently delete the Biometric Data that it retained. In any event, any Biometric Data will be permanently deleted within three years of the driver’s last contact with Company. Absent a valid warrant or subpoena issued by a court of competent jurisdiction, Company will comply with this retention schedule and destruction guidelines.
Consent Form
Before you begin or continue employment with Company in a role for which the Samsara AI Dash Cam is used, you must execute the Notice and Consent to Collection of Biometric Data form accompanying this Policy.
4890-5420-3089, v. 2
