MOBILE22 INC PRIVACY STATEMENT
(Updated July 20, 2020; Version 1.0)
This Privacy Statement (this “Privacy Statement“) explains how Mobile22 Inc., a Delaware corporation (“Mobile22“, “we“, “our” and “us“), may collect, use, and share your personal information when you use or interact with Mobile22 products and services, https://www.mobile22.com/ (our “Site“) and our mobile application (the “Mobile App“) (collectively, “Mobile22 Services“). This Privacy Statement does not apply to other products and services even if accessed via the Mobile App. By using Mobile22 Services, you consent to and accept our use and other processing of your personal information as set forth in this Privacy Statement. If you do not agree with the terms of this Privacy Statement, please do not submit any personal information to us and please do not use the Mobile22 Services. If you have any questions or complaints regarding our Privacy Statement or practices, please contact us at email@example.com or one of the other ways provided below.
PERSONAL INFORMATION WE COLLECT
We collect personal information through your use of Mobile22 Services and related marketing events. We may also collect your personal information from licensees, affiliates, dealers, partners, service providers, and other third-party service providers and subcontractors (collectively, “Service Providers”). We collect the following types of your personal information: Information about you and your accounts with us. This includes your name, address, telephone number, date of birth, photographic image, e-mail address, login information, ride request information (including pickup and dropoff locations), demographic data, account password and/or PIN, emergency contact information, and billing information (your credit card number, CVV code and expiration date). We use this information to verify your identity, complete your account activation and to provide to you Mobile22 Services. Information about your device and how you interact with Mobile22 Services. When you visit our Site, we automatically collect your IP address, browser type, device location, unique device identifier, cookie data, associated identifying and usage information from your mobile phone, laptop, or other device. We collect and use such personal information to personalize your Mobile22 Services experience. We may also record information about your browsing session on our Site, including which pages you visited and any forms you filled in. We review this information to identify any technical issues in the operation of our Site and to improve the user interface of our Site. If we use a third-party to help us with this service, this information will be passed to that third-party for this purpose. When you download and use the Mobile App, we may use mobile analytics software to help us better understand the functionality of the Mobile App on your mobile device. Our analytics may record how often you use the Mobile App, how you use the Mobile App, aggregated usage performance data and from where you download the Mobile App. In addition, you may elect to provide us access to certain information such as your mobile device photographs and camera. If you grant us such access, this enables drivers to verify your identity prior to beginning a requested ride.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information in order to: provide you access to Mobile22 Services; assist drivers with providing you with your requested ride; improve the quality, safety, and security of Mobile22 Services; develop new products and services including, without limitation, cab products and services; maintain customer relationships and communicate with you; personalize your experience; administer your account including verification of your identity; process your payments; operate our Site and applications, including our online registration processes; provide customer support and service; provide product and service updates; evaluate and maintain the quality, safety, security and integrity of our products and services; for research, evaluation of use, and troubleshooting purposes; protect the safety of you or others; verify eligibility for incentive and discount programs and to evaluate ongoing program and membership eligibility; perform and/or send marketing communications, including interest-based marketing and advertising (with required consents, as applicable); administer quizzes, surveys, promotions and offers; customize and improve communication content and your experience with Mobile22 Services; comply with legal, regulatory or contractual requirements; detect and deter fraud, theft or abuse of Mobile22 Services; assist emergency service providers; and engage in other activities in the normal course of operating a cab service. We may also use your personal information for any other purpose with your consent. Where required, we will anonymize your personal information in a way that it can no longer reasonably be associated with you. We may use anonymized personal information or share it with third parties for any legitimate business purpose including, without limitation, general demographic and general marketing purposes.
Communications with you in connection with these uses may be made via mail, telephone, e-mail, text message and other electronic messages through Mobile22 Services. See “Your Choices” below to learn how to manage your communication preferences.
HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your personal information as follows for the uses described above (and where required we will obtain additional consent or anonymize your personal information):
Electronic Vehicle Original Equipment Manufacturers (OEM): With Tesla and/or any other Mobile22 Vehicle fleet partners.
Emergency Service Providers: With emergency service providers, such as law enforcement, roadside assistance providers, and ambulance providers.
Business Partners and Independent Third Parties: With business partners, such as research institutes who assist us with research and development (for example, improving highway safety), OEM fleet providers, for service maintenance of the Vehicles, and marketing activities. We may also share your personal information with third parties where you have elected to receive a service from them and you have authorized them to request data from Mobile22.
Service Providers: With our third-party product and service providers including, without limitation, companies that perform eligibility services (such as identity verification to prevent theft and fraud), administer our contests and promotions, host and/or operate our Site, send communications, perform data analytics, credit card processors, or system providers necessary to process, store, or manage credit card personal information (we will not otherwise share your credit card personal information).
Where Required or Permitted by Law: Such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, to detect, investigate and prevent fraud, or to conduct screening to ensure you are not on any government list of restricted parties.
Business Transfers: In connection with a corporate transaction, a prospective or completed sale, transfer, restructuring, bankruptcy or financing of Mobile22 or its assets.
You have certain choices regarding how we use and share your personal information. For example, you can restrict our access to and our ability to collect and share the location of your mobile device by disabling location-sharing in the settings feature on your mobile device. However, some of the products and services require access to and collection of the location of your device (for example, we require your mobile device’s location to start and complete your requested ride). If you elect to restrict our access to location-sharing services on your device, your ability to use Mobile22 Services may be severely limited. In addition, data collection, use, and sharing practices are tied to the products and services we offer. To stop the collection, use, or sharing of personal information, you may have to decline those products and services or be willing to accept limited functionality. You may choose to limit the marketing communications we send you by managing your subscriptions. You may also contact us directly, at firstname.lastname@example.org to indicate your communications preferences. We provide opt-out instructions in all of our marketing communication channels (for example, an unsubscribe option will appear at the bottom of all marketing-related e-mails). If you opt out of marketing communications, your personal information may still be used for the other purposes described in this Privacy Statement including communications we are required or permitted by law to send to you (for example, certain types of transactional or account-related messages). You may permit us to send you push notifications. We will use push notifications to provide certain services such as emergency or other service notifications, Vehicle arrival notifications, and providing details regarding Mobile22 Services. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information. If you have elected to share your geolocation with us, push notifications may also be used in conjunction with or related to your location. If you change your mind about sharing your location or receiving push notifications from the Mobile App, adjust the settings of your mobile device to turn off transmission of geolocation data or to stop transmission of push notifications at any time. For additional personal information about your choices, please contact: email@example.com.
COOKIES AND OTHER TRACKING TECHNOLOGIES
If you are a California resident, you have the right to receive specific information about how we disclose your personal information to others for marketing purposes and your related choices. Pursuant to California Civil Code Section 1798.83(c)(2), we will not share your personal information with other parties for direct marketing use unless you agree that we may do so or as provided for in this Privacy Statement. If you are a California resident under the age of 18 and you have publicly posted any information on our Site or on the Mobile App, California Business and Professions Code Section 22581 permits you to request and obtain removal of the content or information you have publicly posted. If you wish to make such a request, please send an e-mail with a detailed description of the specific content or information to firstname.lastname@example.org. Please be aware that there may be circumstances in which the law does not require or allow us to remove information even if you have made such a request.
Most web browsers and some mobile operating systems and mobile applications include a Do Not Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will update our policy related to such DNT signals in this Privacy Statement.
THIRD-PARTY SERVICES, APPLICATIONS AND WEBSITES
Certain third-party services or applications (for example, your carrier data plan, navigation services) you download, that are pre-installed, or which you may sign up for may have separate user terms and privacy statements, which are independent of our Privacy Statement. Mobile22 is not responsible for the personal information practices of these third-party services or applications. We recommend that you carefully review the user terms and privacy statement of each third-party service or application prior to signing up, downloading, or using them.
Google utilizes IP address information to evaluate your use of our Site, compile reports on website activity and to provide further services related to our Site. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google. In addition, our Site uses the Analytics feature UserID to track interaction data. This User ID will be additionally anonymized and encrypted and will not be linked with other data. You can prevent the storage of Cookies by changing your browser software settings; however, if you do this, you may not be able to use all the features of our Site to the fullest extent possible.
ACCESS AND UPDATES TO YOUR PERSONAL INFORMATION
You can access your online account to view or update your information related to and stored on your account. You may also contact email@example.com to learn about how to access, review, correct, update or delete the personal information about you in our records. We may need to retain certain personal information for recordkeeping purposes, to complete any transactions that you began prior to your request or for other purposes as required or permitted by applicable law.
HOW WE SAFEGUARD YOUR PERSONAL INFORMATION
We maintain commercially reasonable procedures and technology designed to prevent the unauthorized access of your personal information that you provide to us. Mobile22 Services has reasonable technical, administrative and organizational security measures in place to protect the loss, misuse or unauthorized alteration of information under our control. However, we cannot guarantee that unauthorized third parties will never be able to defeat those security measures or otherwise obtain access to your personal information.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We generally keep your personal information only for so long as necessary to provide Mobile22 Services to you including, without limitation, to enable us to communicate with you, for your safety, for our research, evaluation of use, or troubleshooting purposes, as well as to operate our business, or to satisfy our legal or contractual obligations. Where required or appropriate, we will anonymize or dispose of your personal information when we no longer need it for the uses described above.
We do not knowingly collect personal information from children under 13 years of age. If you become aware that a child has provided us with personal information without parental consent, please contact us via e-mail at firstname.lastname@example.org. If we become aware that a child under 13 years of age, we will take steps to remove such personal information and terminate the child’s account.
INTERNATIONAL DATA TRANSFERS
We store your personal information on servers located in the U.S. If you reside outside the U.S., please know your personal information will be transferred, processed and stored on third-party servers in the U.S., which the EU has deemed to have inadequate safeguards. Since individuals who are not residents of the U.S. are ineligible for the cab services provided by Mobile22, Mobile22 Services is not intended for non-U.S. residents. Accordingly, we request that non-U.S. residents refrain from providing us personal information and to refrain from utilizing Mobile22 Services.
CHANGES TO THIS PRIVACY STATEMENT
We may update this Privacy Statement from time to time as our business, products and services expand or change, or as required to by law. If we do, we will post the updated version of the Privacy Statement on our Site. Your continued use of Mobile22 Services shall be construed as your implied consent to the Privacy Statement updates.
Unless otherwise required by applicable law, this Privacy Statement, and Mobile22’s collection and use of personal information, shall be governed and interpreted in accordance with the laws of the U.S. and the State of Wisconsin.
By using Mobile22 Services, you are consenting to our processing of your personal information as set forth in this Privacy Statement now and as amended by us from time to time. “Processing” means using Cookies on a computer/mobile device or using or touching your personal information in any way, including, but not limited to, collecting, storing, deleting, accessing or transferring, combining and disclosing personal information, all of which activities will take place in the U.S.
HOW TO CONTACT US
If you have concerns or questions regarding Mobile22’s consumer privacy practices or this Privacy Statement, please visit our Site at https://www.mobile22.com/, e-mail us at email@example.com. You may also contact us by regular mail at 821 E. Washington Ave., Suite 200. Madison, WI 53703.