Privacy Policy Holman Driver Insights®

Privacy information in connection with the use of Holman Driver Insights®

Holman GmbH, Liebknechtstraße 33, 70565 Stuttgart (hereinafter referred to as “Holman”), e-mail: [email protected], phone: 0049 (0) 711-6676-0, fax: 0049 (0)711-6676-17101, attaches great importance to the protection of personal data.

According to Article 4 No. 1 GDPR, personal data is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. For example, a name or an e-mail address are considered personal

1. Order processing by Holman

Client companies may only be entrepreneurs within the meaning of Section 14 of the German Civil Code, Holman does not provide Driver Insights® to consumers.

The client companies can make Driver Insights® available to their employees for use within the framework of their contractual relationships. The customer company decides for itself whether and which personal data is collected and processed with Driver Insights®. Holman has no discretion in this respect and processes the entered personal data only for the business purposes of the client companies and with the means and functions of Driver Insights® that the client company selects and actually uses. In doing so, Holman processes the personal data entered by the customer company for Driver Insights® as a processor of the customer company in accordance with Article 28 GDPR.

2. Data protection information by the controller within the meaning of Article 13 GDPR

The customer company responsible for data protection law must inform the data subjects independently and completely in accordance with Article 13 of the EU General Data Protection Regulation (GDPR), if and to the extent that this is necessary and has not already been done elsewhere, e.g. in the context of employment relationships with its affected employees or in the context of other contractual relationships with other data subjects. Information on the data protection of the customer company can often be found on its websites. The present data protection information of the processor Holman serves to enable the customer company responsible for data protection law to fulfil its information obligations and to supplement its data protection information if necessary

3. Name and contact details of the controller

The data controller is the customer company that uses the Driver Insights® IT system developed by Holman.

The controller must also provide the data subjects with their name and contact details as part of their information obligations under Article 13 GDPR. This information can often be found in the imprint on the websites of the customer company

4. Contact details of the controller’s company data protection officer

If the controller has appointed a company data protection officer, he or she can be contacted via the contact details of the controller’s data protection officer. This information can often be found in the data protection passages on the websites of the client company

5. Contact details of the company data protection officer of the processor Holman

The data protection officer of the processor Holman can be reached by e-mail to [email protected] or via Holman’s postal address.

Data protection requests to Holman or Holman’s corporate data protection officer do not replace any requests by data subjects to exercise their rights as data subjects to the controller, i.e. Holman’s customer company, provided that Holman’s customer company is obliged to them under the EU General Data Protection Regulation. As a processor, Holman is not able to provide information on data protection requests that concern the controller. Requests to exercise data subject rights in connection with Driver Insights® must therefore be made directly to the controller. Notwithstanding the foregoing, Holman may forward such requests to Controller to the extent permitted and required by law, without hereby agreeing to a specific period of time for forwarding. To be on the safe side and to comply with any deadlines, data subjects must contact the controller directly.

6. Purposes of data processing, legal basis, storage period

Holman processes personal data exclusively on behalf of and in accordance with the instructions of its customer companies for the provision and use of the IT system Driver Insights® offered by Holman. The specific processing purposes and means are determined by the respective customer company as the controller and, based on the functions provided and usable by Driver Insights®, may include, in particular:

Provision of the application and its functions to employees of the client company
Implementation of technical business processes of the client company
Management of user accounts of the customer company
Communication between client companies and their partners
Storage, evaluation and provision of the data entered by the customer company
Support, maintenance and troubleshooting

The following explains what personal data is processed during the use of Driver Insights®.

a) Download the Mobile App Driver Insights® from the Apple App Store

In order to use our Driver Insights® mobile app on Apple devices, the user must download it from the App Store of Apple Inc., CA, USA.

The Apple App Store is operated by Apple Inc. and companies affiliated with Apple Inc. There are separate terms of use and data protection information for the use of the App Store by Apple Inc., which the user may have to accept. Holman is not responsible for, and cannot influence these regulations and data processing by or at Apple Inc. and its partners. This applies in particular to the collection and processing of login and payment information for the App Store and the associated device information.

Holman is also not affiliated with the operators of the App Store under company law and does not represent them.

By downloading and using the Mobile App Driver Insights®, the User also acknowledges that the operators of the App Store are not obliged to provide any support or maintenance of the Mobile App Driver Insights®. All rights and obligations regarding the use of the Driver Insights® mobile app exist only between the user, the client company and Holman in accordance with the applicable terms of use.

b) Download the Mobile App Driver Insights® from the Google Play Store

To use Driver Insights® on Andoid/Google devices, you must download them from the Google App Store.

The Google Play Store is operated by Google LLC, USA and for European customers of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland as well as companies cooperating with them. There are separate terms of use and privacy policies for Google’s use of the Play Store, which the user may have to accept. Holman is not responsible for these regulations and data processing by or at Google and its cooperation partners, nor can Holman influence them. This applies in particular to the collection and processing of login and payment information for the Play Store and the associated device information.

Holman is also not affiliated with the operators of the Play Store under company law and does not represent them.

By downloading and using the Mobile App Driver Insights®, the User also acknowledges that the operators of the Play Stores are not obliged to provide any support or maintenance of the Mobile App Driver Insights®. All rights and obligations regarding the use of the Driver Insights® mobile app exist only between the user, the client company and Holman in accordance with the applicable terms of use.

c) Data collection and processing on the terminal device

As a company car driver for Holman customer companies, you can use Driver Insights® to view and administer information and tools relating to your company car via mobile communications or Wi-Fi.

If you use Driver Insights®, you must first log in via a login dialog and provide your credentials. In the login dialog, your e-mail address (user name) and password will be requested.

Processing Purposes

Holman processes the following categories of personal data only for business purposes of the client company, i.e. usually in particular to:

enable the functions used by the user in each case
for the administration of the network infrastructure
to prevent fraud and abuse by implementing appropriate technical and organisational measures for IT system and information security, taking into account the state of the art
to ensure user-friendliness of use
to optimize Driver Insights®

Categories of personal data processed

IP address of the requesting device
Date and time of access
Service methods used
User’s name
User’s email address, password
Mobile phone number
Phone number
Private and employer address
Location data
Content data

Legal bases for processing personal data

The legal basis for Holman is Article 28 GDPR (order processing) in connection with the order processing agreement concluded between us and the customer.

The respective legal basis for the processing of personal data vis-à-vis the data subjects is determined by the respective customer company as the controller and can be found in its data protection information. As a rule, processing is carried out in accordance with No. 1 and 2 in accordance with Article 6 (1) (b) GDPR (performance of a contract), in accordance with No. 3 in accordance with Article 6 (1) (c) GDPR (legal obligation) and in accordance with No. 4 and 5 in accordance with Article 6 (1) (c) and (f) GDPR (legal obligation, legitimate interests).

Storage period

Holman stores personal data only for the duration of the contractual relationship with the respective customer and in accordance with the customer’s documented instructions. The following applies:

After terminating Driver Insights®, no personal user data is stored on the end device in order to prevent information from falling into the hands of third parties, even if the device is passed on or lost. Only the next time Driver Insights® is started/possibly logged in and the next connection to Holman’s servers is data synchronized to the end device again. In addition, personal data will be stored on your device until the app or cache is deleted.

In addition, the above-mentioned data will be deleted from Holman’s servers at the latest after the permissible storage period according to the case law on current law, i.e. connection data usually after 30 days. If data is processed for a longer period of time for purposes according to numbers 2-3, anonymisation will take place if the personal storage is no longer necessary for the respective purpose.

In addition, your data will be deleted from Holman’s servers as soon as the customer company terminates the contractual relationship with Holman and all contractual relationships have been finally settled.

d) Use of Driver Insights® via the web application

In addition to the mobile application, Driver Insights® can also be used via the web application under the URL https://driverinsights.holmanfleet.de/. No download of an app from an app store is required to use the web application.

For the purposes of processing, the categories of personal data processed, the legal bases and the storage period, reference is made to Section 6. c).

e) No further processing

Beyond the cases mentioned above, personal data will not be processed unless you expressly consent in advance to further processing, e.g. to receive a newsletter.

7. Cookies

We and the third-party providers we use cookies on our websites and mobile apps. A cookie is a small file that can be sent together with the pages of a web address and stored by the web browser on your device. The information stored therein may be accessed during subsequent visits and sent to our or third-party servers.

The use of necessary cookies is used to technically adapt the display to device types and to enable certain functions without which our website and mobile app do not function properly (necessary cookies).

We also use so-called session cookies to recognize that you have already visited individual pages of our website within a session and to enable session control, e.g. to store form entries during a session and across different calls (necessary cookies).

Furthermore, to ensure user-friendliness, we use temporary cookies that are stored in the web browser or mobile app of your device for a defined period of time. When you visit the website again, it is automatically recognised that the respective device has already visited our websites and which settings have been made so that you do not have to make them again (optional cookies).

In addition, we use tracking cookies to statistically record the use of our website, for the purpose of optimising our offer and for advertising purposes (optional cookies). These tracking cookies also make it possible to automatically recognise the device you are using when you visit our website again.

Depending on the settings of your device, you can also view our websites without cookies when visiting our websites. You can also set the settings of some web browsers to prevent cookies from being stored, or to always display a notice before a new cookie is created. However, most web browsers automatically accept cookies.

You can also use the cookie consent tool available from us under “Cookie Settings” on the website to control the types of optional cookies that are set. Optional cookies are disabled by default.

You can also delete cookies via standard web browsers. However, deleting or disabling cookies may prevent you from using all the features of our website. When cookies are used on our website and in the mobile app, personal data is processed.

Categories of personal data

Online identifiers (e.g., cookie ID, session ID)
IP address (abbreviatedor pseudonymized if necessary)
Deviceand browser information
Usage and interaction data (e.g., page views, clicks, dwell time)
Preferenceand preference data (e.g. language, cookie consents)

Purpose of processingThe processing is carried out for business purposes of the responsible customer company, in particular:

Ensuring basic website and mobile app functions and session control
Analysis of user behavior
Content optimization and usability
Marketing and advertising measures

Legal basis

The legal basis for Holman is Article 28 GDPR (order processing) in connection with the order processing agreement concluded between us and the customer.

for necessary cookies for purpose number 1 in accordance with Article 6 (1) sentence 1 (f) GDPR (legitimate interest in a secure and functionalwebsite).
for all non-necessary cookies for purposes 2 to 4: Article 6 (1) sentence 1 (a) GDPR and Section 25 (1) TDDDG (consent). This means that these cookies are only set personally if you have expressly consented to them; consent can be revoked at any time with effect for the future.

Storage period

Functionally necessary and necessary session cookies: Deletion at the end of the browser session.
Optional, persistent, temporary cookies: deletion after the specified duration depending on the purpose.
Optional tracking cookies: Deletion after withdrawal of consent or after expiry of the specified storage period.

Transfer to third countries

Depending on the cookie services used, personal data may be transferred to third countries (in particular to the USA). The transfer is based on an adequacy decision (e.g. EU-US Data Privacy Framework) or suitable safeguards in accordance with Art. 46 GDPR (e.g. standard data protection clauses).

For more information about cookies, please see our Cookies Policy (https://www.holmanfleet.de/cookie-policy-eu/).

8. Plug-Ins von Google Inc.

Furthermore, we show addresses in the display of Driver Insights®, which can be found via Google Maps in the browser. The route can also be calculated via Google Maps if desired.

Google Maps is operated by Google LLC, USA and for European customers of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland as well as companies cooperating with them. The plug-ins used can be technically operated in the USA or other countries outside the EU, the European Economic Area and Germany. If you use such a plug-in with Driver Insights®, your web browser or mobile app will connect directly to Google’s servers or their cooperation partners in the respective country. This at least provides the recipient of the connection with the information that you have accessed a specific, identifiable mobile app or visited a website with Google Maps, and possibly also other information that your web browser or device reveals. The content of the plug-in is downloaded and integrated from your device directly from the provider. If you are registered and logged in with the provider in question, your visit may also be assigned to your user account via your device.

The purpose and scope of the described data collection and use by Google or its cooperation partners are primarily marketing measures. You can find details about this and your rights and setting options to protect your privacy directly from Google in their privacy policy (see . www.google.com)

9. Disclosure to third parties, processors, categories of recipients

A transfer of your personal data to third parties, i.e. other natural or legal persons other than the data subject, the controller, the processor and the persons who, under the direct responsibility of the controller or the processor, are authorised to process the personal data, will only take place for the purposes listed below:

You have given your explicit and voluntary consent in accordance with Article 6(1)(a) of the GDPR to:
The transfer is necessary in accordance with Article 6 (1) (b) GDPR for the processing of contractual relationships with you, e.g. to suppliers or recipients of a good or service named by you.
There is a legal obligation to disclose data in accordance with Article 6 (1) (c) GDPR, e.g. to financial or law enforcement authorities.
The disclosure is necessary in accordance with Article 6 (1) (f) GDPR for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data; such a transfer can, for example, in the event of attacks on our IT systems to government institutions and law enforcement agencies.

Driver Insights® is operated on servers in Germany or within the European Economic Area (EEA). There is no regular storage or processing of personal data in connection with the hosting of the application in the USA.

To support the operation of Driver Insights®, Automotive Rentals, Inc., New Jersey, USA may provide technical support and IT services on a case-by-case basis. This includes, in particular, the provision of support services in connection with the analysis and rectification of technical faults as well as incident management and troubleshooting.

Insofar as access to personal data is technically necessary in the context of such support services and cannot be ruled out, this is done exclusively on the documented instructions of Holman and only to the extent necessary for the provision of the specific support service. Holman US acts as a sub-processor in accordance with Article 28 GDPR.

In order to secure any access from the USA, Holman US has implemented the standard contractual clauses adopted by the European Commission in accordance with Article 46 GDPR, Module 2, Transfer from controllers to processors, see . https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en and https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj completed. These can be obtained on request at [email protected].

Holman does not intend to transfer personal data to the USA for the regular operation of Driver Insights®.

10. Authorizations to access the terminal device

Within the scope of the processing purposes described above, Driver Insights® has the following technical access rights to the device used: Internet connection, WLAN, mobile communications, web browser components, location services, images, camera.

11. Rights of data subjects

You have the right vis-à-vis the controller – see sections 1-5 – to:

Request information about your personal data processed by us in accordance with Article 15 GDPR. In particular, you can obtain information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period if possible, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data, if it has not been collected from you, as well as on the existence of automated decision-making, including profiling and, if necessary, meaningful information on its details,
in accordance with Article 16 of the GDPR, to request the correction of incorrect or complete of your personal data stored by us without undue delay,
Request the deletion of your personal data stored by us in accordance with Article 17 GDPR if:
- they are no longer necessary for the purposes for which they were collected or otherwise processed,
- Your consent. on which the processing pursuant to Article 6(1)(a) or Article 9(2)(a) was based and there is no other legal basis for the processing,
- you object to the processing in accordance with Article 21(1) and there are no overriding legitimate grounds for the processing, or you object to processing for the purpose of direct marketing, including related profiling, in accordance with Article 21(2),
- the personal data has been unlawfully processed,
- the erasure of the personal data is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject,
- the personal data has been collected in relation to the information society services offered in accordance with Article 8(1) of the GDPR (consent of a child).
The right to erasure does not exist if the processing is necessary
- to exercise the right to freedom of expression and information,
- to comply with a legal obligation, for reasons of public interest in the field of public health or archiving purposes in the public interest, or
- to assert, exercise or defend legal claims.
to request the restriction of the processing of your personal data in accordance with Article 18 GDPR, insofar as
- the accuracy of the data is disputed by you,
- the processing is unlawful, but you oppose its erasure,
- we no longer need the data, but you need it to assert, exercise or defend legal claims, or
- You have objected to the processing in accordance with Article 21 GDPR.
in accordance with Article 20 of the GDPR, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transmitted to another controller,
in accordance with Article 7 (3) GDPR, revoke your consent to us at any time. As a result, we may no longer continue the data processing based on this consent for the future, unless there is another legal basis for this and
to complain to a supervisory authority in accordance with Article 77 of the GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or place of work or our registered office for this purpose.

12. Right to object, automated decisions in individual cases including profiling

If your personal data is processed on the basis of legitimate interests in accordance with Article 6 (1) (f) GDPR, you have the right to object to the processing of your personal data with the controller in accordance with Article 21 GDPR, insofar as there are reasons for this arising from your particular situation or the objection is directed against direct marketing. In the latter case, you have a general right of objection, which is implemented without specifying a special situation.

Automated decision-making, including profiling, in accordance with Article 22 GDPR does not take place.

13. Data Security

We use the widely used SSL (Secure Socket Layer) method to communicate Driver Insights® with our servers. in conjunction with the highest level of encryption supported by your browser. As a rule, this is a 256-bit encryption. You can tell whether a single page of our website is transmitted encrypted by the closed display of the key or lock symbol in the status bar of your web browser.

In addition, we use suitable technical and organizational measures to secure data processing, in particular to protect your data against manipulation or unauthorized access. In doing so, we take into account the state of the art. Our security measures are adapted in line with technological developments.

14. Links to offers from other providers

Driver Insights® may contain links to offers from other providers. Please note that this privacy information applies exclusively to Holman’s Driver Insights®. We have no influence on and do not control that other providers comply with the applicable data protection regulations.

15. Validity and up-to-dateness of the privacy policy

The data protection information is currently valid and dated 20.08.2026. Due to changes in the legal framework, the further development of Driver Insights®, the implementation of new technologies or due to changed legal or regulatory requirements, it may become necessary to change this data protection information with effect for the future. The current data protection information, which supplements that of the responsible customer company, can be retrieved and saved or printed out by you at any time.

16. Severability

Should individual provisions of this data protection information be or become invalid or unenforceable in whole or in part, this shall not affect the validity of the remaining provisions. The same applies in the case of gaps.