Telematics Policy

CBX SOLUTIONS LLC

Driver Fleet Telematics, Camera & Biometric Information Privacy Policy

 

Policy Owner	CBX Solutions, LLC
Applies To	All CBX Solutions employees who operate or occupy fleet vehicles equipped with the Samsara System
Effective Date	June 2026
Review Cadence	Annual, or upon material change to applicable law or platform configuration
Public Availability	Available upon request and posted to the CBX Solutions safety resources site

This Driver Fleet Telematics, Camera & Biometric Information Privacy Policy (the “Policy”) establishes how CBX Solutions, LLC (“CBX Solutions” or the “Company”) deploys and uses a video recording system provided by a third-party vendor, Samsara, to monitor and record employees operating and/or occupying Company vehicles. CBX Solutions utilizes several of Samsara’s recording capabilities, including the Dual-Facing Camera System, Live View, and Camera ID (these capabilities, collectively, the “Samsara System”). This Policy defines what information is collected by the Samsara System, the Company’s uses for that information, who has access to the information, how long the information is retained, and when the information is destroyed, in accordance with applicable law.

Before any data is collected through the Samsara System, CBX Solutions provides each affected employee with written notice of this Policy. Because use of the Samsara System is a condition of operating or entering a CBX Solutions fleet vehicle, employees must give written consent by signing the corresponding Employee Acknowledgment and Consent Form (the “Acknowledgment Form”) prior to the employee operating or entering an equipped vehicle. Employees who do not consent to the collection and use of data described in this Policy are not authorized to operate or enter a CBX Solutions fleet vehicle.

This Policy applies to all CBX Solutions employees who operate, ride in, or otherwise occupy a CBX Solutions fleet vehicle equipped with the Samsara System. “CBX Solutions” or the “Company” refers to The Cook and Boardman Group, LLC, doing business as CBX Solutions, including its operating divisions and subsidiaries. CBX Solutions does not currently operate fleet vehicles outside the United States.

•     Biometric Information: The data generated from the scan of an employee’s face and/or facial geometry on the Samsara System, and any information derived therefrom. For purposes of this Policy, information derived from a scan of an employee’s face and/or facial geometry during the video recording process by the Samsara System is referred to as “Biometric Information,” even though it may not meet the definitions of “biometric information” or “biometric identifier” under applicable law, and as such, this term does not reference any single statutory definition of “biometric information”, “biometric identifier,” or “biometric data.”

•     Camera ID: Samsara’s facial recognition feature used solely for assigning trips to the correct driver, attributing safety events to the correct driver, and improving fleet safety performance. This feature collects Biometric Information.

•     Deactivation: The point at which an employee is removed from the CBX Solutions Samsara account and therefore the employee’s data (including Biometric Information) is no longer being recorded or collected by CBX Solutions or Samsara.

•     Disabling: The point at which CBX Solutions disables Camera ID and any other Biometric Information collecting features of the Samsara System for an individual driver, a vehicle, a branch, or the fleet as a whole. The employee’s data, other than any Biometric Information, may still be recorded, collected, and retained by CBX Solutions or Samsara after this point.

•     Dual-facing Camera System: The Samsara in-cab camera assembly that captures both a forward-facing road view and an inward-facing driver view. The inward-facing camera analyzes drivers for distracted driving, phone usage, and other unsafe driving behaviors, and in doing so collects Biometric Information.

•     Employee Data: All data collected by the Samsara System, including Biometric Information, that is specific to an individual employee.

•     Live View: Samsara’s real-time video viewing function. Live View is not used routinely. It may be activated only in special circumstances, such as suspected misconduct, a safety event in progress, or a driver-initiated request, and only with proper authorization.

•     Samsara System: The Samsara hardware and software platform deployed by CBX Solutions. This platform records vehicle motion and behavior data by using features such as telematics sensors, the Dual-Facing Camera System, Telemetry Data, the Samsara dashboard (Samsara’s information hub, which displays a vehicle map and allows the Company to access video recordings, vehicle diagnostics, and all other features of the Samsara System), and Camera ID.

•     Telemetry Data: Vehicle and driver behavior data such as GPS location, speed, acceleration, braking, cornering, seatbelt status, idling, and distracted-driving events.

While the Samsara System’s primary purpose is to capture only the Biometric Information of the driving employee, the Samsara System may also record, collect, and analyze Biometric Information of any passenger in the Company vehicle. Non-employee passengers in Company vehicles are strictly prohibited, regardless of whether the vehicle is being used for work or personal purposes. Failure to comply with this requirement may result in discipline, up to and including termination of employment. For further information regarding permissible uses of Company vehicles, please refer to the Company’s Handbook and Fleet Policy.

Although certain features of the Samsara System are turned off by default, and although certain employees may not have Employee Data collected, this Policy is intended to cover not only the Employee Data intended to be captured and collected, but also any capture of Employee Data that may occur inadvertently due to technical or human error. Employees are hereby notified that, by their presence in a Company vehicle equipped with the Samsara System, Employee Data may be collected in any manners described below, even if such collection was not explicitly intended by the Company. CBX Solutions securely stores all collected Employee Data.

The Company may utilize any or all of the following Samsara System features in a Company vehicle, depending on the circumstances. Company vehicles may display visible signage notifying occupants that the vehicle is equipped with recording devices, however, the features below may be used by the Company regardless of signage:

3.1 Video Recording

Equipped Company vehicles capture a forward-facing road video stream and an inward-facing driver video stream through the Samsara dual-facing camera system. Recording may be either event-triggered or continuous-buffered depending on configuration. The dual-facing cameras record, collect, and analyze Biometric Information to determine if an employee is engaged in unsafe driving behaviors, such as distracted driving or not wearing a seatbelt, at any point during operation of the Company vehicle.

3.2 Telemetry Data

Equipped Company vehicles collect Telemetry Data such as GPS location, speed, acceleration, braking, cornering, seatbelt status, idling, distracted-driving events, and similar vehicle and driver-behavior data through the Samsara System.

3.3 Audio

Audio recording is not enabled on CBX Solutions vehicles. Therefore, audio is not recorded or collected either inside or outside the cab of CBX Solutions vehicles. If audio configuration changes in the future, drivers will be notified in writing and provided an updated Acknowledgment Form.

3.4 Live View

Live View is not used routinely by the Company. The function may be activated only in special circumstances — such as suspected misconduct, a safety event in progress, or a driver-initiated request — at the discretion of the Company and in conjunction with Corporate Safety, Fleet, Human Resources, or Legal. When activated, Live View allows the Company to view the driver and interior of the Company vehicle in real time. Use of Live View by any Company representative is logged and monitored to ensure Company representatives are only utilizing Live View in accordance with this Policy.

3.5 Camera ID and Facial Recognition

CBX Solutions uses the Samsara System’s Camera ID feature to assign trips to the correct driver. Camera ID records and collects images of employees’ faces, including Biometric Information, in order to identify and assign the employee to the Company vehicle being operated.

CBX Solutions deploys the Samsara System for the following specific, limited, and legitimate business purposes:

•     Monitoring and improving driver and public safety through coaching, training, and recognition;

•     Reconstructing accidents, near-misses, and safety events;

•     Assigning trips, routes, and vehicles to the correct driver, and attributing safety events to the correct driver;

•     Protecting CBX Solutions employees, customers, vendors, and Company property;

•     Managing fleet performance, routing, and operational efficiency;

•     Supporting investigations of suspected misconduct or Company policy violations;

•     Any other lawful employee or public safety reasons.

The Company does not sell, lease, or trade any Employee Data captured by the Samsara System. The Company’s use of the Samsara System is intended to be non-punitive, unless a safety incident or violation of Company policy occurs. Data collected is used primarily by CBX Solutions for safety coaching, recognition, accident reconstruction, and operational improvement, consistent with the CBX Solutions Safety Recognition Program.

All Employee Data captured through the Samsara System is processed and stored using Samsara’s hardware and software, including third-party cloud-based infrastructure. In certain circumstances, CBX Solutions may also retain Employee Data in its own records. CBX Solutions is confident in Samsara’s contractual and technical security commitments, which include encryption in transit and at rest, access controls, and operational safeguards. In addition, CBX Solutions shall, using a reasonable standard of care for its industry and in a manner that is the same or exceeds the standards used to protect other confidential and sensitive information of employees, safeguard all employee data and Employee Data in its possession, regardless of format, from unauthorized access, acquisition, or disclosure.

Within CBX Solutions, access to Employee Data is restricted to personnel with a documented business need, including but not limited to, Corporate Safety, Fleet, Human Resources, Legal, and authorized branch and operations leadership. Access by CBX Solutions employees is logged by the Company. Certain designated Samsara employees and agents may also be permitted to access Employee Data as necessary and appropriate to carry out their assigned job duties.

Video recordings and Telemetry Data may be used for safety coaching, recognition, performance management, accident investigation, claims defense, and disciplinary proceedings. Coaching feedback may be documented and shared with the driver as part of CBX Solutions’ continuous improvement and recognition programs.

Where video recordings are used in disciplinary proceedings, the affected employee will be permitted to review the relevant recording and respond. Employees may request, through Corporate Safety or Human Resources, a copy of recordings containing images of themselves, subject to applicable retention periods and as required by applicable law. Improper access, distribution, or use of Employee Data is prohibited and may result in disciplinary action up to and including termination.

Disclosure of Employee Data by CBX Solutions may occur in the following circumstances:

•     To Samsara and its sub-processors and agents as necessary to operate the platform;

•     To the employee whose data or Biometric Information is at issue, upon request and as required by applicable law;

•     To law enforcement, regulatory authorities, insurance carriers, accountants, or attorneys as required or permitted by law, including in connection with legal claims, investigations, civil recovery, audits, investigations, or as otherwise required by law or legal process;

•     As reasonably necessary, to defend CBX Solutions against legal claims or to support investigations of suspected misconduct, with Legal and Corporate Safety review.

In the event additional parties need access to Employee Data for technical support, administration, or other lawful purposes, the Company will only provide such access in accordance with applicable law and other best practices.

In the event of a data security incident that may compromise the security of Biometric Information in the Company’s or Samsara’s possession, the Company and/or Samsara will provide all affected employees (whether current or former) with written notice of the data security incident as soon as reasonably practicable.

CBX Solutions retains Employee Data collected by the Samsara System according to the following schedule:

 

Data Type	Retention*
Camera ID facial recognition data containing Biometric Information	90 days after the earlier of: (a) employee deactivation from CBX Solutions Samsara account, or (b) Camera ID and all other Biometric Information collecting capabilities disabled for the employee or fleet
Routine forward-facing and inward-facing video footage (including Biometric Information captured in any inward-facing video)	Up to 45 days
Telemetry Data (GPS, speed, behavior events; no Biometric Information included)	Up to 30 days
Video footage retained for cause (incidents, claims, discipline, training; no Biometric Information included)	Up to 5 years

CBX Solutions may retain Employee Data collected by the Samsara System for longer periods as necessary for the purpose the recording was captured, including but not limited to for disciplinary proceedings, safety trainings, investigations, or as otherwise dictated by legal necessity. In such cases, the data is segregated, access is further restricted, and deletion proceeds promptly upon release of the hold.

*In all cases where required by applicable law, CBX Solutions permanently destroys all records of Biometric Information in its possession upon an employee’s termination of employment or within one year after the original purpose for collecting the Biometric Information has expired, whichever is earlier.

At the end of the applicable retention period, Employee Data is permanently deleted from the Samsara platform and the Company’s records. For Biometric Information, CBX Solutions confirms permanent deletion through Samsara’s data destruction processes as published in Samsara’s Biometric Data Retention and Destruction Policy. Deletion of Biometric Information is documented in CBX Solutions records, and a deletion record is retained as part of the driver qualification file or its successor system of record in accordance with Company personnel record retention policies.

Disciplinary action up to and including termination of employment may be taken against any employee who:

•     Destroys, dismantles, disconnects, or interferes with Samsara hardware or the Samsara System;

•     Deliberately blocks or obstructs the camera lens (forward-facing or inward facing) using clothing, tape, sun visors, or any other means;

•     Engages in conduct that violates any CBX Solutions policy, the rules of the road, or that endangers employees, customers, vendors, or the public;

•     Misuses or improperly accesses Employee Data collected by the Company.

CBX Solutions will not discriminate against any employee subject to this Policy based on the employee’s lawful use of lawful products or otherwise lawful off-duty activities about which the Company becomes aware through the Samsara System, provided the activity occurs off Company premises during non-working hours and does not adversely affect the employee’s job performance, ability to meet position responsibilities, or the safety of the employee or others.

Where personal use of a CBX Solutions vehicle is authorized by the Company, the vehicle always remains subject to this policy. Employees should not have an expectation of privacy while operating a CBX Solutions vehicle, including during personal use periods and during non-working hours.

Employees have the following rights with respect to Employee Data collected through the Samsara System:

•     To receive written notice before collection (provided through this Policy and the corresponding Acknowledgment Form);

•     To review video footage that contains images of themselves and to request a copy, subject to applicable law and retention periods;

•     To review and respond to any video footage or other Employee Data used in disciplinary action involving them;

•     To request a copy of this Policy at any time;

•     To ask questions of Corporate Safety or Human Resources regarding the collection, use, retention, and deletion of their Employee Data;

•     To exercise all other additional rights as granted by applicable law.

CBX Solutions structures this Policy to satisfy the requirements of all applicable U.S. federal, state, and local privacy and biometric privacy laws.

Where such laws may impose additional or stricter requirements than those described in this policy, CBX Solutions follows the stricter requirement.

This policy is owned by the CBX Solutions Corporate Safety Department in coordination with Human Resources, Legal, and Fleet. Material changes will be communicated to affected employees and posted to the CBX Solutions safety resources site. Continued operation of an equipped CBX Solutions vehicle constitutes ongoing acknowledgment of and consent to the most current version of this policy, where permissible under applicable law.

This policy is reviewed annually and upon any material change to: (a) applicable law; (b) Samsara System configuration; (c) the CBX Solutions retention schedule; or (d) the scope of biometric data collected. Employees will be notified of material changes and provided updated Acknowledgment Forms as needed.

Questions about this policy, requests to review recordings, requests to exercise rights described herein, or requests for a copy of this policy, or a copy of Samsara’s Biometric Data Retention and Destruction Policy, should be directed to Corporate Safety or Human Resources through the channels published on the CBX Solutions safety resources site.