Effective Date: January 1, 2020.
1. APPLICABILITY OF THIS POLICY
This Policy covers our treatment of information that is collected by us or submitted by you in relation to your access to or use of the Service, including personally identifiable information and non-personally identifiable information. When you visit the Site or access the Application without registering for an Account, you can browse without submitting any personally identifiable information. In order to use certain features, however, you may be asked to provide personally identifiable information, such as your name, email address, vehicle information, and mobile telephone number. The Service utilizes services provided by third parties. This Policy does not apply to information collected by third parties, including our third party payment processor or third party Linked Sites. We have no control over, and no responsibility or liability for third party collection, use, disclosure, or retention of your information and that collection, use, disclosure, and retention is not subject to this Policy. Be sure to review the privacy policies of any Linked Sites or other third party sites or services you may access.
2. CHANGES TO THIS POLICY
3. INFORMATION COLLECTION
For various services we offer, we may require you to provide appropriate information as indicated on various forms presented to you. Where possible, we indicate which fields are required and which fields are optional. You always have the option to not provide information by choosing not to use a particular service or feature.
We collect the following types of information:
- Account, Login, and Service-Related Information. We will collect personally identifiable information from you when you create an Account. If you create an Account, you will be asked to provide information about yourself, including, but not limited to your first name, last name, and a password selected by you. If you create an account, we collect a unique identifier (“Device Identifier“) for your computer, mobile or other device used to access the Service. A Device Identifier is a number that is automatically assigned to your device used to access the Services, and our computers identify your device by its Device Identifier. We may also collect additional information including profile picture, postal address, credit/debit card information, gender, age, and local employer. If you use the Service, we will collect additional information, including, but not limited to, the origin, destination, rating information, date and time of your Rides, the Riders in your car if you are a Driver, the Driver of your car if you are a Rider, or the number of Ride Credits charged or credited to your Account. We will store your Account related information indefinitely and in a profile specific to you.
- Location Information. Certain features available in the Service, including, but not limited to, requesting a Ride or offering a Ride require us to obtain your location information, including GPS coordinates in real time (“GPS Location”). Your GPS Location may allow us to locate you with a high degree of precision. We use this GPS Location information in order to provide the Service. For example, if you are a Rider, we may use your GPS Location to show you matching Drivers near you who are available to provide a Ride. If the Service is unable to acquire your GPS Location, certain features of the Service may not be available to you. We may collect and use GPS Location information over time to offer you services, protect, enhance or update the Service.
- Driver-Specific Information. If you apply to become a Driver, we will collect additional personally identifiable information from you, including, but not limited to, mailing address, car make and model, state DMV record, employer contact information, and vehicle picture (“Driver-Specific Information”). Using this information, we may obtain information from your employer, information from your insurance company, results from a background check on you, and information about your driving record from the applicable State Department of Licensing or Department of Motor Vehicles. Driver-Specific Information will be stored indefinitely in a profile specific to you. If you are an approved Driver, we may perform additional background checks, driving record checks, or other verifications on your Account at any time. In addition, you may be required to resubmit certain Driver-Specific Information periodically, such as updated insurance information, driver’s license renewal information, or an updated mailing address if you move.
- Support Requests or Communications. Any personal communications that you or a third party voluntarily submits to us in any format, including by email, postal mail, or any other method of communication, may be collected and saved indefinitely and in a profile specific to you.
- Automatically Collected Information. Similar to other web sites and mobile applications, we may collect some information automatically and store it in log files. We also use Google Analytics, a third party analytics provider, to collect analytics information about the Service. This collection may include, but is not limited to: your IP address, city, zip code, age range, operating system, browser type and language, referring/exit pages and URLs, other browser history, platform type, device type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time of each request you made. We collect this non-identifying information in order to better understand our customer base, to more efficiently operate our business, to promote our products or services, and to improve the quality of the Service. We do not link analytics information with any of your personally identifiable information.
We may automatically collect information using various mechanisms, including, but not limited to:
Pixels (aka web beacons/web bugs/java script). Pixels are tiny graphics with a unique identifier that are used to track the online movements of web users. Unlike cookies, which are stored on a computer’s hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on web pages or in HTML-based emails. Our third party analytics provider may place pixels on the Site that track what other websites you visit (both before and after visiting the Site). Our third party analytics providers use information obtained from pixels to help us improve our business and the Site. We do not control the use of pixels by third parties.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.
4. INFORMATION USE
- General. We may use your personally identifiable information to operate, manage and administer your Account and the Service; to provide you with support and a more personalized experience; to communicate with you; monitor usage; improve the Service and develop and test new web sites and applications; match interests, to provide you information about products and services (including products and services of third parties); to resolve disputes; to detect and protect against errors, fraud, and criminal activity; to assist law enforcement; to promote safety associated with the Service; to measure consumer interest in the Service; to enforce this Policy and the Terms; or for any other purpose described in this Policy or that we describe to you at the time of collection.
- Communications. When you create an account with the Service, we send you an email with a code and we send you a text message with a code to ensure the email address and the mobile phone number you provided belong to you. When you make a change to your email address or phone number, we may send an email or a text message to verify that the corresponding email or phone number belongs to you. When you request a Ride or offer a Ride, other parties who may carpool with you may call you on your mobile phone using features provided by the app. We may use personally identifiable information to send you emails, notifications, text messages, or other communications related to your use of the Service, your Account, or to respond to your inquiries or requests. You may not opt-out of receiving service-related messages which are not promotional in nature. We may also send you marketing emails to notify you about products, promotions, or services that may be of interest to you. If you would like to stop receiving marketing email from us or from third parties, please click on the opt-out link in any non-service related email you receive. If you opt out, you will still continue to receive service-related emails.
- Driver-Specific Information. We will use Driver-Specific Information to determine if you are qualified to become an iCarpool Driver. For example, we may run a background check using your driver’s license number or access your state department of licensing vehicle records to verify your driving record. We may use Driver-Specific Information to check if there has been any fraud, abuse, or breach of our Terms or this Policy, and to ensure that Drivers maintain certain levels of quality and service. If you become an approved Driver, we may also use your mailing address to send you material that is relevant to Drivers who use the Service.
- Non-Personally Identifiable Information We may use non-personally identifiable information for any lawful purpose, including, but not limited to, analyzing trends, administering the Service, tracking usage, and to improve our business and the Service. We may share aggregate information with third parties to develop and deliver targeted advertising and to analyze and report on advertising you see. In addition, we may share aggregate statistical information with business partners for public relations purposes. We may also combine non-personally identifiable information we collect with non-personally identifiable information collected from other sources. Aggregate information will not be connected with your personally identifiable information.
- Information Retention. We may retain your information (including personally identifiable information and Driver-Specific Information) indefinitely, or as long as legally required or allowed, for our business needs and in order to deter fraud, abuse or a breach of our contract. By accessing, using, or registering for the Service, you consent to our information retention practices. If you cancel your Account or your Account is otherwise terminated, we may, but are not obligated to, delete information we have collected or obtained from you or third parties and we may continue to store, use, and disclose your information in accordance with this Policy. iCarpool does not undertake any retention obligations through this statement.
5. INFORMATION DISCLOSURE
- Affiliated Entities and Service Providers. We will not sell or rent any of your personal information to third parties for marketing purposes. However, we may disclose your information to any affiliated entity or organization and to suppliers, contractors, agents and service providers, including third party customer service providers, payment processing providers, support providers, and business or sales agents or other service providers. Additionally, if you go into a negative balance and owe us money, we may share your information with collection agencies. Use of information by affiliated entities and organizations will be subject to this Policy or an agreement that is at least as restrictive as this Policy. If we provide information to third parties, it will, unless specifically noted otherwise in this Policy, be governed by this Policy and may only be used by those third parties to help us operate or improve our business or the Service and to provide services to us.
- Other Riders and Drivers. In order to provide the Service to you both safely and effectively, we will share some of your personally identifiable information with other Riders and Drivers when your trip matches these other users or when you request or provide a Ride. Other Riders or Drivers may have access to certain information collected from you, including, but not limited to, your name, profile picture, location, employer, vehicle information, Ride request origin, stops, and destination, Ride start time, your average User Rating, number of seats available in your vehicle, or number of Rides taken or provided. Third party websites or apps that integrate with the Service using an API may match your trip information with its own users and be able to display your information to such matched users in their site or app.
- Promotions. If you submit User Content in connection with a promotional offer, we may make the User Content and certain personally identifiable information including your name and profile picture available publicly through the Service as well as in our advertising, marketing, and promotions even if such offers are made available outside of the Service.
- Legal Requirements In some cases, we may disclose your information (i) as required by any applicable law or legal regulation; (ii) if we believe disclosure is needed to protect our rights, property, or safety; (iii) to government regulators or law enforcement authorities in connection with any judicial proceeding, court order, subpoena, or legal process served on us or the Service; and (iv) to respond to a threat to you or another person.
- Insolvency and Business Transitions. If we should ever file for bankruptcy or engage in a business transition such as a merger with another company, or if we purchase, sell, or reorganize all or part of our business or assets, we may disclose your information, including personal information, to prospective or actual purchasers in connection with one of these transactions.
- Disclaimer. We cannot ensure that your information will never be disclosed in ways not otherwise described in this Policy. For example, a third party may unlawfully intercept or access transmissions or private communications, or other users of the Service may abuse or misuse your personal information. No transmission of data over the Internet can be guaranteed to be 100% secure.
6. INFORMATION SECURITY MEASURES
Keeping your information secure is of great concern to us and the personal information we collect is stored in operating environments that are not available to the public. We use procedural and technical safeguards, including, for example, encryption, firewalls, and secure socket layers, to protect your personal information against loss, theft, or unauthorized access and disclosure. While we have mechanisms in place to safeguard your personal information, no transmission of data or service provided over the Internet or any other public network can be guaranteed to be 100% secure. When you provide your information to us, you do so at your own risk.
7. “DO NOT TRACK” SETTINGS
8. CHILDREN’S PRIVACY
- The Service is Not For or Directed Towards Children. You must be 18 years of age or older to use the Service as a Rider and 21 years of age or older to use the Service as a Driver. Children under the age of 13 are prohibited from using or registering for an Account and we will never knowingly collect any information from children under the age of 13. If we learn that we have collected information from a child under the age of 13, we will remove that information immediately and delete it from our servers. If you believe User Content from a child under the age of 13 has been posted to the Service, please notify us at: email@example.com.
- California Minors. The Service is not available to Riders under the age of 18 or Drivers under the age of 21. However, if you are a California resident under age 18 and you are unable to remove publicly-available User Content that you have submitted to the Service, you may request removal by contacting us at firstname.lastname@example.org. When requesting removal, you must be specific about the information or User Content you want removed and provide us with specific information, such as the URL for each page where the information is located, so that we can find it. We are not required to remove any User Content or information that: (i) federal or state law requires us or a third party to maintain; (ii) was not posted by you; (iii) we anonymize so that you cannot be identified; or if you don’t follow our instructions for removing or requesting removal or you received compensation or other consideration for providing the User Content or information. REMOVAL OF YOUR USER CONTENT OR INFORMATION FROM THE SERVICE DOES NOT ENSURE COMPLETE OR COMPREHENSIVE REMOVAL OF THAT USER CONTENT OR INFORMATION FROM OUR SYSTEMS OR THE SYSTEMS OF OUR SERVICE PROVIDERS. We are not required to delete the User Content or information posted by you; our obligations under California law are satisfied so long as we anonymize the User Content or information or render it invisible to other users and the public.
9. CALIFORNIA SHINE THE LIGHT LAW
California Civil Code Section 1798.83 permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed personal information (as defined under that statute) of that California resident, for direct marketing purposes in the preceding calendar year and the categories of personal information that was disclosed. If you are a California resident and you wish to request this list, you may do so by contacting us at: email@example.com.
10. LINKED SITES AND THIRD PARTIES
11. ACCESSING, UPDATING, OR DELETING YOUR PERSONAL INFORMATION
If your personal information changes, you may make changes in the Profile section in the Application. Some changes, such as email address or phone number changes, may go through a verification process so that the Service can validate that the corresponding email or phone number belongs to you. If you are a Driver, you may make additional changes such as updating the vehicle associated with your account, updating the employer associated with your account, by sending an email request to firstname.lastname@example.org. If you change your information, we usually update our live databases immediately. However, some information may update more slowly. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others, or would be impractical. If you would like to cancel your account, you can send an email request to email@example.com. If you terminate your account, your information will no longer be accessible through your account or associated with your account. However, activity that occurred prior to deletion may still be accessible by the public and will continue to be stored on our servers.
12. PRIVACY QUESTIONS
If you have questions or concerns about our privacy practices or about this Policy, please contact us at: firstname.lastname@example.org.