Collectively, we refer to the Websites, the Apps and our Social Media Pages as the “Services”.
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual including, but not limited to:
We and our third-party service providers collect Personal Information in a variety of ways, including:
We and our third-party service providers use Personal Information for legitimate business, research, and operational purposes including:
We will engage in these activities to manage our relationship with you and/or to comply with any legal obligation.
We will engage in this activity with your consent or where we have a legitimate interest.
We will provide personalized services either with your consent or because we have a legitimate interest.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
We may disclose Personal Information:
These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, event registration, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
This can include laws outside your country of residence.
To respond to a request or to provide information that we, in our sole discretion, believe is important or is necessary to protect our interests. These can include authorities outside your country of residence.
For example, when we respond to law enforcement requests and orders or provide information that we, in our sole discretion, believe is important.
To enforce any terms and conditions; and
To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual:
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
We and our third-party service providers may collect Other Information in a variety of ways, including:
Certain information is collected by most browsers or automatically through your device. We use this information to ensure that the Services function properly.
When you download and use the App, we and our third-party service providers may track and collect App usage data, which may include the following:
We use the data we receive to meet the aims and objectives of our research trials. Some examples of how we may use the data include:
Driving data and mobile phone information collected by the App will be retained on your mobile phone for several days and will then be deleted from the App, but an overview report of your driving trips will be available in the App for a limited time.
We limit access to the data we receive and use physical, electronic and procedural safeguards to help protect it and your privacy. We will retain this data for as long as needed for research and operational purposes.
App analytics information is used to help us understand how you interact with the App, so that we can continue to improve the experience.
Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
We will collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We will record this information through the Way to Drive App and use your device’s physical location to collect relevant information for research and/or operational purposes. Your physical location data will only be recorded by the App when your device is moving more than five miles per hour (considered a driving trip event). We will be unable to enroll you in our research trials if you do not share your device’s physical location with us.
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Your choices regarding our use and disclosure of your Personal Information
To the extent these rights are provided to you by applicable law, if you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, object to the processing of Personal Information or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another entity, please contact us at firstname.lastname@example.org. We will respond to your request consistent with applicable law.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
The Services are not directed to individuals under the age of fourteen (14), and we do not knowingly collect Personal Information from individuals under 14.
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
In accordance with applicable law, you may lodge a complaint with the relevant privacy or data protection regulatory authority.
LAST UPDATED: May 17, 2021