Biometric Data Privacy Policy

This Biometric Data Privacy Policy (this “Policy”) is provided by the members of the HMD Group of Companies described below. These companies are referred to in this Policy as “we,” “us,” or “our.”
We have instituted the following policy related to any biometric data (defined below) that we may now or in the future possess, or to which we may now or in the future have access as a result of our use of products and services provided by Netradyne, Inc., including Netradyne’s Driveri™ device and related services and the Driveri™ App, or the products or services of other third parties in our commercial motor vehicles (collectively, “Safety Products”). This Policy provides you notice that your biometric data may be collected and explains our biometric data retention and destruction policies.

1. Biometric Data Defined
As used in this Policy, the term “biometric data” includes biometric identifiers and biometric information as defined in the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1 et seq. (“BIPA”). BIPA defines “biometric identifier” as “a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry.” Under BIPA, “[b]iometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color.” BIPA also excludes other information from the meaning of biometric identifier.
BIPA defines “biometric information” as “any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual. Biometric information does not include information derived from items or procedures excluded under the definition of biometric identifiers.”
“Biometric data” also includes any similar state or local law definitions related to any biological characteristics of a person, or information based upon such a characteristic, including but not limited to, “biometric identifier” as defined under Tex. Bus. & Com. Code § 503.001, “biometric identifier” as used in Wash. Rev. Code § 19.375.020, “biometric information” as used in the California Consumer Privacy Act, “biometric information” as used in the New York Stop Hacks and Improve Electronic Data Security Act, and “biometric data” as used in Arkansas Code § 4-110-103.

2. Purpose for Collection or Possession of Biometric Data
To the extent we collect or possess biometric data, such collection and possession occurs as a result of our use of Safety Products in our commercial motor vehicles. We use Safety Products to promote and attempt to increase safe driving behaviors and to attempt to improve road safety. We may also use biometric data captured by Safety Products to verify the identities of the employees or contractors who drive the commercial motor vehicles we own or lease, as well as to ensure the security of the Safety Products and our commercial motor vehicles and for fraud prevention purposes.

3. Biometric Data Collected or Possessed
The Safety Products we use may record a facial image of the employees and contractors who drive our commercial motor vehicles.

4. Authorization
To be permitted to drive one of our commercial motor vehicles, you must authorize us and our service providers, such those who provide our Safety Products, to collect, capture, obtain, use, and store your biometric data as described in this Policy.

5. Disclosure
We will not sell, lease, trade, or otherwise profit from your biometric data. We will not disclose or disseminate any biometric data to anyone, other than authorized providers of our Safety Products, unless:

• the subject of the biometric data (or the subject’s legally authorized representative) consents to the disclosure or dissemination;
• the disclosure or dissemination completes a financial transaction requested or authorized by the subject of the biometric data (or the subject’s legally authorized representative);
• the disclosure or dissemination is required by state or federal law or municipal ordinance; or
• the disclosure or dissemination is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

6. Retention Schedule
We will retain any biometric data in our possession until the first of the following occurs:

• when the initial purposes for collecting or obtaining such biometric data have been satisfied (such as when the employee’s employment with us ends); or
• within 3 years after the employee’s or contractor’s last interaction with us.

We may retain a subject’s biometric data for a longer period of time when legally required to do so.

7. Data Storage
We will use a reasonable standard of care within our industry to store, transmit, and protect from disclosure any biometric data collected. Such storage, transmission, and protection from disclosure will be performed in a manner that is the same as or more protective than the manner in which we store, transmit, and protect our other confidential and sensitive information.

8. Changes to this Policy
We may change or update this Policy periodically. When we do, we will post the revised policy on this webpage indicating when the policy was “Last Updated.” The changes will go into effect on the “Last Updated” date posted in the new policy. The new policy will replace this Policy. Please check periodically for changes to this Policy.

9. Companies Providing this Policy
This Policy is provided by the following members of the HMD Group of Companies: HMD Trucking, Inc.; HMD LLC; and Benefit Trucking LLC; and HMD Motorsports LLC.

10. Contact Us
If you have any questions or concerns about our privacy policies and practices, you may contact us by telephone at (708) 398-6237. Please ask to speak with the EVP of MIS.

Last Updated: June 30, 2022