Last modified: May 1, 2019
What Information Do We Collect?
We collect, receive, generate and store the following types of information:
- Personal Identifying Information: Personal Identifying Information is information that can be used to identify or contact you or a Third Party Source, including but not limited to one’s name, address, email address, telephone number, account identifiers, account password, payment information, credit card information and other billing data. We collect, receive and store Personal Identifying Information when you connect, sign up or register on or with the Site or other Services, or when a Third Party Source signs up or registers with you or your product or service and then, because of Company’s relationship with you, provides or makes accessible such information to us through our Services. For example, you may provide Personally Identifying Information directly to us in connection with signing up, registering or interacting with Company on or through the Site, when you set up an account for Services, when you subscribe to email alerts, updates or newsletters, or when you respond to a survey, fill out a form, or complete any profile through the Site. As another example, a Third Party Source may provide such Personally Identifying Information when signing up as a driver with a company that uses our Services to collect driving data about such Third Party Source; and that company may then choose to share such Personally Identifying Information with us.
- Personal Non-Identifying Data: Personal Non-Identifying Data is information about your or a Third Party Source’s activities or behavior or information that is otherwise about you or a Third Party Source which, in any event, cannot be used to identify or contact you or the Third Party Source or which has been stripped of any Personal Identifying Information. This type of information, would includes for example without limitation, an individual’s gender, city or state of residence, age, characteristics, driving behavior, driving locations and driving activities as well as data regarding particular trips one has taken, types of vehicles used and similar information. We collect, receive and store Personal Non-Identifying Data when you directly provide it to us through the Site or Services (such as through sign-ups or registration or through use of a Service that collects or tracks such information) or when a Third Party Source provides it through the use of our Services on behalf of or through you or when such Third Party Source uses your product or service that collects or tracks such information using our Services.
- User Content: User Content is information, data, text, files, software, graphics, music, audio, photographs, video, messages, communications or other materials (other than Personal Indentifying Information or Person Non-Identifying Data), that you (or, if applicable, Third Party Sources) upload, submit, post, transmit, share or otherwise provide on, through or to the Site and other Services. For example, we receive and store User Content provided to Company when you (or, if applicable, any Third Party Sources):
(a) use the Services; and/or
(b) post, upload, submit or otherwise provide content, materials or other information on, through or to the Services; and/or
(c) fill out surveys or questionnaires or sign up for or enter promotions, events or other special activities on, through or to the Services; and/or
(d) communicate with Company or with other users or participants of the Services (including the content of such communications and information provided in connection with such communications); and/or
(e) provide information to third parties and their web sites, applications and services which are accessed or used by Company or on, through or to the Services.
- Information We Collect or Generate About You and/or the Use of Our Services: We may receive, collect, generate and store certain types of information whenever you use the Site and when you or a Third Party Source uses any Services or otherwise interacts with us. For example, one of our applications or Services may collect data regarding driving activities or behavior and our Services may then analyze such data and generate derivative data or aggregated data as well as reports and other output. As another example, we may automatically record your activity on the Site, the time and date of your activities, your IP address, browser type, Internet Service Provider, page views, domains, operating system and similar information. Also, we may automatically send and receive information to and from a computer, mobile phone or other device in connection with the use of the Services. Like many websites and online services, we may also use “cookies” (see below), log files, web beacon technologies and other automated tools to obtain certain types of information when a web browser, mobile application or other application accesses our Services.
How Is The Information Used?
Company may use the information submitted, collected, received or generated from and/or about you or a Third Party Source for any of the following purposes:
- To operate, provide, administer, develop, and improve our Site and other Services, and to operate and support Company’s related businesses.
- To better understand how users access and use our Site and other Services on an aggregated and individualized basis, to track and monitor usage, to conduct quality control, to fix technical and other errors or problems, to conduct market research and to respond to user desires and preferences.
- To analyze, compile, publish, sell and otherwise similarly commercialize information (other than Personal Identifying Information), including without limitation derivative information and analyses, relating to usage and users of the Services. The foregoing includes, for example, the distribution or sale by Company of aggregate or de-identified Personal Non-Identifying Data or the use of Personal Non-Identifying Data to provide products or services to third parties.
- To provide personalized experiences and recommendations, language and location customization, personalized help and instructions, or other responses to the usage of our Services.
- To provide user support and handle inquiries.
- To communicate with or contact users concerning the usage of or participation in the Services, and for other customer service; this could include use of e-mail addresses to send messages and notices for the purposes described above and below.
- To offer content, services, or other products and services, including to develop new services and products.
- To provide news and newsletters, special offers and promotions (which excludes the provision to third parties of, or the publication of, any Personal Identifying Information).
- To comply with applicable laws, rules and regulations and any regulatory mandate or court order.
- To enforce our TOU, any Terms of Service and other applicable agreements, rights and remedies.
- To protect the safety of any person, to address fraud, security or technical issues, or to protect Company’s rights or property.
- To use the name of entities who have signed up for Services or otherwise contracted with Company in Company’s own marketing, advertising and promotional materials (notwithstanding anything to the contrary above).
- To use in any other manner, or for any other purpose, for which you or, if applicable, a Third Party Source, has given permission or consent to Company.
When is Information Shared with or Disclosed to Others or the Public?
Information provided by our users is an important part of our business. Company will share and disclose information submitted, collected, received or generated from and/or about you or Third Party Sources only as compatible with the purposes described above, when we have permission or consent (as may be provided by you or the applicable Third Party Source from time to time through the Site, Services or otherwise), or as described in this section as follows:
- Aggregated Data and Anonymous Data: Company may publish and otherwise disclose (a) on an aggregated basis, information (including derivative information and analyses) relating to usage and users of the Services, and (b) information that does not contain Personal Identifying Information or is de-identified and not connected to the name of an individual or entity nor connected to similar information that would allow one to be specifically identified or contacted.
- Disclosures In Connection with Permitted Uses. Company may disclose your and Third Party Source information (other than Personal Identifying Information) to third parties in connection with the purposes described in the previous section such as, for example, to commercialize non-identifying information relating to usage and users of the Services. Company may also share information from and about Third Party Sources with you. Company may also disclose the name of entities who have signed up for Services or otherwise contracted with Company in Company’s own marketing, advertising and promotional materials.
- Public Forum: Any User Content or other user information, content or materials submitted, posted, shared, transmitted or otherwise provided to public portions of the Site or public portions of other Services may be shared with the public without restriction. Company also reserves the right to publish or make publicly available any information that is already publicly available prior to the time first provided to or collected by Company or information that becomes publicly available without any action or omission on the part of Company.
- Business Transfers and Collaborations: As we continue to develop our business, we might sell the Company and/or its business or assets and/or sell or buy online sites, services, subsidiaries, or other businesses; or we might collaborate or partner with other companies in strategic transactions, business arrangements or licenses. In such transactions, customer and user information and information regarding usage of the Services (including without limitation Personal Identifying Information and Personal Non-Identifying Data) generally would be one of the transferred business assets or otherwise one of the components of, or involved in, the transaction, we may therefore share this information in connection with such transactions or arrangements.
- Compliance with Law and Protection of Company and Others: We reserve the right to disclose Personal Identifying Information and any other information when we believe release is appropriate to comply with the law, judicial proceeding, court order, subpoena or other legal process; detect, prevent, or otherwise address fraud, security, emergency situations or technical issues; enforce or apply our TOU, Terms of Service and other agreements, rights and remedies; or protect the rights, property, or safety of Company, our employees and contractors, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes.
The Services may include or interoperate with applications, services, features or functionalities provided by third parties. In connection with such third party applications, services, features or functionalities, you may send (or such third parties may get access to) certain information about or related to you or your activities therewith. The use, storage and disclosure of such information by these third parties is subject to their own privacy policies.
Security and Protection of Your Information
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of unencrypted electronically stored “personal data” (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on or through the Services in an expedient manner and without unreasonable delay, insofar as these are consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Changing or Deleting Your Information
Cookies and Other Files
Log file information is automatically reported by your browser each time you access a web page. When you use the Services, our servers may record certain information that your web browser sends whenever you visit any website or utilize any other services or applications. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other information. When you use the Services, we may employ clear GIFs (also known as web beacons) or similar mechanisms which are used to track the online usage patterns of our users anonymously. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients.
Our Services are hosted in the United States. If you or Third Party Sources use the Services from the European Union, Asia or any other country outside the United States with laws or regulations governing personal data collection, use and disclosure that differ from the United States laws and regulations, please be advised that through the continued use of the Services, you (or the Third Party Sources) are transferring information to the United States and you consent to that transfer. Your and Third Party Source’s information may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us or use the Services, Company transfers personal information to the United States and processes it there, and your submission of such information represents your consent and agreement to that transfer.
Our Policy Toward Children
In order to use our Site and other Services you must represent and warrant that you are over the age of 13 in the sign-up process. Children under the age of 13 are not eligible to use the Services and must not attempt to sign-up with the Services and/or submit any personal information to us. We do not knowingly collect personal information from any person who is under the age of 13 or allow them to register. If it comes to our attention that we have collected personal data from a person under the age of 13, we will delete this information as quickly as possible.
Links to Other Sites, Services and Applications
Our Services may contain links to, interoperate with, and allow you to share content to and from third party services, websites and applications. The fact that we link to a website, service or application or allow you to share content through these third parties is not an endorsement, authorization or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. Other websites, services and applications follow different rules regarding the collection, use, storage or disclosure of the personal and other information. We encourage you to read the privacy policies or statements of the other websites, services and applications you use.
Limitation of Liability