Trimble Supplemental Privacy Notice for Facial Imagery Data

Last Updated: September 25, 2023

This Supplemental Privacy Notice supplements Trimble’s standard Privacy Notice, available through the Trimble Privacy Center at https://www.trimble.com/privacy. This Supplemental Privacy Notice applies to facial imagery data that we collect, capture, possess, use, analyze, share, transfer and/or process (“Process”) at the direction of our customers when they, or their end users, access or use Trimble’s products or services or otherwise interact with Trimble, such as from drivers of commercial trucks enabled with the available driver intelligence solution called Driver Behavior Events provided as part of Trimble Transportation’s Video Intelligence solution.

Processing Facial Imagery Data. Trimble and its affiliates, directly and/or through its service providers and vendors (collectively, “Trimble”), provides certain product offerings, such as Driver Behavior Events, that involve processing photos and/or videos to generate facial imagery data. Facial imagery data may be considered biometric data in some jurisdictions.

Purpose for Processing Facial Imagery Data. Trimble Processes facial imagery data at the direction of its customers for identity verification, safety, training, and/or compliance purposes, and may use facial imagery data to improve Trimble’s products and services. Trimble does not sell, trade, or lease facial imagery data collected or received from its customers or their employees through their use of Trimble products or services.

Storage of Facial Imagery Data. Trimble uses a reasonable standard of care and implements reasonable safeguards to store, transmit, and protect from loss, unauthorized access and/or disclosure of all facial imagery data that it Processes. Trimble stores, transmits, and protects all such facial imagery data in a manner that is the same as or more protective than the manner in which Trimble stores, transmits, and protects other personal information that can be used to uniquely identify an individual or an individual’s account or property.

Retention and Destruction of Biometric Data. Trimble permanently destroys any facial imagery data in its possession in accordance with its customers’ instructions, but no longer than the earlier of (i) the date that the customer ceases to have a relationship with Trimble, (ii) the date that the customer informs Trimble that the initial purpose for collecting or obtaining the facial imagery data has been satisfied, or (iii) a date that is within three years after the date that the customer informs Trimble that its last interaction with an individual has occurred.