Effective Date: 2/15/18
Collection of Information
Information you provide
The Company may collect and store any personal information you enter using our App, or provide to us in some other manner. This includes identifying information, such as your name, address, email address, telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information) and other information you choose to provide to us. You may also provide us information including personally identifiable information, your GPS location relating to ride pick-up and drop-off locations, and aggregate data as set forth in our Terms of Service, and to have your personally identifiable information collected, used, transferred to and processed within Canada and the United States.
Information from other sources
Information we collect
The App collects two different kinds of information from you:
- Personally identifiable information (“PII”) is information that could be used to identify you as an individual or that could be used to contact or locate you.
- Non-personally identifiable information (“non-PII”) is any other kind of information we collect from you.
Methods of Collection
The App collects your information both actively and passively. Active data collection occurs when you enter your information when you are creating an account with the App. Passive data collection occurs without your affirmative consent by the App’s use of analytic and reporting technologies.
The App actively collects your email address, password, gender, and birthdate when you supply them by registering to use the App. These data items are considered PII because each of them could either: (i) be used individually to identify you or to contact you; or (ii) be used in combination with each other to access your account.
The App passively collects certain anonymous information about your use of the App. Examples of this anonymous information are: your operating system, the date and time of use, and device type. The App also passively collects your geographical location data if you have agreed to allow location access in the App settings. This collection will take place either while you are using the App or always depending on the setting you have selected. If you do not allow the App to collection your geographical location data, your use of the App will be limited.
This list is not an exhaustive list of the types of passive non-PII we may collect; it merely provides examples.
Information Collected Through Your Use of the App
When you use the App, the Company collects information about you in the following categories:
The App gathers statistical information automatically when you use it.
The App collects information you provide when you register for a RideFlag User account, including your name, age, email, gender, profile photo (if given), address, organization, mobile phone number and password.
The App collects information consisting of your driver license number, photographs of the front and back of your driver license, and car profile information you, as a Driver, provide.
The App collects information about your vehicle, including its model, color, and license plate, as well as photographs of the vehicle provided by you, as a Driver.
“Occupancy Information” is the number of current passengers as provided by the App. This Occupancy Information may be reported to a trusted partner organization, such as a toll agency or its technical partners, for the purposes of high-occupancy validation and/or high-occupancy rewards (e.g., nearby registered users, occupancy count, and time series data when occupancy is detected).
“Location Information” is precise location data about the ride collected by the App. If you permit the App to access location services through the permission system used by your operating system, the Company may collect Location Information in the form of the precise location of your device when the App is running in the background or foreground. The Company may also derive your approximate location from your IP address. This Location Information may be reported to a trusted partner organization, such as a toll agency or its technical partners, for the purposes of determining whether the registered vehicle likely traversed a specific location (such as a virtual toll plaza or toll plaza) or a set of locations.
“Contacts Information” consists of names and contact information from your address book. This Contacts Information is collected if you permit the App to access the address book on your device through the permission system used by your device platform. This Contacts Information may be used to facilitate interactions with regard to the services as described in the Terms of Service or for other purposes described at the time of consent or collection.
The App saves details related to your use of the App, including the date and time the service was provided, contribution charged, distance traveled, and other related transaction details.
Usage and Preference Information
The App may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, serial number, device motion information, and mobile network information.
The App facilitates communications between Riders and Drivers. In connection with facilitating these communications, the App collects call data including the date and time of the call and the parties’ phone numbers.
When you interact with the App, it collects server logs, which may include information like the type of mobile device you are using, the device IP address, access dates and times, App features or pages viewed, App crashes, and other system activity.
Information Collected from Other Sources
The Company may receive information from other sources and combine that with information collected through the App. For example:
Social Media; API
If you choose to link, create, register or log in to your RideFlag account with a social media service such as Facebook, or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
When you use the App, Riders may provide the Company with Driver ratings, and Drivers may provide the Company with Rider ratings after completing a ride.
Use of Information
The Company’s use of your Non-PII
The Company reserves the right to make full use of your non-PII. The Company may use this information for the purposes of demographics and analytics. It may sell this demographic information to third parties or use this demographic information to solicit advertising for the App. In addition, the Company may use this non-PII for the purpose of analyzing use patterns and trends with regard to the App.
The Company’s use of your PII
The Company may use your PII to:
- Communicate with you via email, text message, or phone calls. You may opt-out of these communications by following these instructions.
- Perform internal operations, including, for example, to prevent fraud and abuse of the services, to troubleshoot software bugs, to conduct data analysis, testing and research; and to monitor and analyze usage and activity trends;
- Send or facilitate communications between Riders and Drivers, such as estimated times of arrival and estimated distance between you and another User in connection with your use of certain features, such as ride invites.
- Personalize and improve the App, including to provide or recommend features, content and social connections.
- Provide verified occupancy and Location Data to trusted partner agencies, such as a toll agency and/or our technical partners, to enable the User to be issued with a high-occupancy validation and/or rewards by that trusted partner for use in promotions like commuter or student challenges.
- Transfer the information described in this Policy to process and store it in, the United States and other countries, some of which may have less protective data protection laws than the region in which you reside.
- Validate verified occupancy and Location Data when you reach reward levels.
Use of aggregated information: Analytics and validation monitoring provided to third parties
The Company may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific User, to properly operate the App, to improve the quality of the App, to create new services and features, including customized services, to change or cancel existing content or services, and for further internal, commercial and statistical purposes.
The Company may also use anonymous, statistical or aggregated information collected from the App, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the App, departments of transportation, service providers, partners and any other third party.
Sharing of Information Though Use of the App
The Company may share your information:
- With other Users, whether Drivers or Riders, to enable them to provide the services you request. For example, the App may share your name, photo (if you provide one), average user rating given by other Users, and pickup and/or drop-off locations.
- With other Users and with other people, as directed by you, such as when you want to share your estimated time of arrival or other information about your ride(s);
- With the public and other Users if you submit, publish, display or otherwise post content in a public forum or in any public message area (including, but not limited to the feedback section) or through any email feature, such as social media posts, blog comments or other features of our services that are viewable by the general public;
- With your employer (or similar entity) and any necessary third parties engaged by the Company or your employer (e.g., an expense management service provider).
The Company requests permission for the App’s collection of Location Information per the permission system used by your mobile operating system. If you initially permit the collection of this Location Information, depending on your mobile device’s operating system, you may later be able to disable it by changing the location settings on your mobile device. However, this will limit your ability to use certain features of the App. Additionally, disabling the App’s collection of precise location from your device will not limit the App’s ability to collect your trip location information from a Driver’s device nor our ability to derive approximate location from your IP address.
The Company may also seek permission for the App’s collection and syncing of Contacts Information from your device per the permission system used by your mobile device operating system. If you initially permit the collection of this Contacts Information, depending on your mobile device’s operating system, you may later be able to disable it by changing the contacts settings on your device.
Third-Party Software Components
Use of Google services
Other third-party software components
The company will comply with the User’s requests regarding access, correction, and/or deletion of the PII we store in accordance with applicable law.
Social Sharing Features
Certain user profile information, including your name, location, contact information and any video or image content that you have uploaded to the App, may be displayed to other Users.
Any content you upload to your public user profile, along with any PII or content that you voluntarily disclose online in some manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone.
Protection of Your Information
The Company uses reasonable practices and technologies to safeguard your information against illegal intrusion and unauthorized access. No security measures are 100% reliable, however, so the Company cannot guarantee the security of your PII.
Third-Party Access to Your Information
The Company will not share, lease, or sell your PII but the Company may provide your information to the following third parties:
The Company may disclose your PII to service providers who maintain the App and to service providers who process our payments. These trusted service providers will have access to your PII but may not use your PII for any purposes other than those to which they have been entrusted. The Company shall use reasonable efforts to ensure that these service providers hold your PII in confidence. In addition, the Company shall only disclose your PII to third parties that the Company believes, in good faith, follow acceptable privacy and security policies.
The Company may disclose your PII to investigate or enforce violations of our rights. The Company may also disclose your PII to protect the security of the App. In addition, the Company reserves the right to disclose your PII if the Company has a good faith belief that this disclosure is necessary to satisfy a legal process or an enforceable government request (such as a subpoena) or to be in compliance with any law or regulation.
Airport or other governmental authorities
Users specifically agree to the release of their ride data using the App to airport authorities or other governmental authorities who may request such data from the Company.
The Company may transfer your PII as part of a sale, merger, acquisition, or any other change of control. In addition, the Company reserves the right to transfer your PII to protect the Company’s legal rights in the unlikely event of a bankruptcy, reorganization, receivership, assignment, or any application of creditor’s rights.
Correction or Removal of Your Information
Policy with regard to children
The Company will not knowingly collect any information from children under the age of thirteen (13) as is consistent with the Children’s Online Privacy Protection Act (“COPPA”) unless the parent or legal guardian of the child has provided that information to the App for the purposes of student challenges. If, as a parent or guardian, you discover your child under the age of thirteen has supplied the Company with PII or you wish to remove any PII that you have provided on behalf of your child, you may contact the Company and we will remove your child’s information from our database. In this communication with us, please provide the username and password used by your child to enter their PII onto the App.