Privacy Policy
Your Privacy
We respect your privacy and are
committed to protecting the personal information we hold about you. This policy explains what information we
collect about you, how we collect it, the measures we take to keep your
information secure and the uses we make of it. We also explain the options you have
regarding your personal information.
When you request services from us, access our websites, utilize our
mobile "apps" or otherwise interact with us, for example, but without
limitation, through our service centers, our in‑vehicle or in‑equipment
technology, our official corporate pages on third party social networks (such
as Facebook) or the "apps" on those pages, you consent to our collection,
retention and use of your personal information in the manner described in this
policy and accept the risks outlined in the Security Measures section below.
Summary of our Privacy Policy ("what
you need to know")
Who We Are: We are Clutch Georgia,
LLC and its subsidiaries. This
policy does not cover our licensees or affiliates or other third parties
through whom you may interact with us.
Legal
Issues: We aim to comply with the privacy laws applicable to
the personal information we collect and use.
What
We Collect: We collect the personal information we need to
provide the services you request from us, for our operational and marketing
uses listed in this policy and for such other purposes as you authorize. By subscribing for our vehicles and
using our services and providing personal information to us, you consent to our
use and disclosure of your information for the purposes listed in this policy.
Sources: We mostly collect your information
directly from you, through various channels including our website, computer
systems and in‑vehicle and in‑equipment technology, and from
companies involved in our provision of services to you, including our licensees
and third party providers.
Websites: Certain technologies may
be used on our websites, our apps and other electronic media including cookies
and Pixel Tags, to collect information about your visit to our site and sites
upon which we advertise. You may
choose to restrict the use of cookies as suggested in this policy.
Storage: We generally retain
personal information about our subscribers for as long as we believe
appropriate for the purposes for which it was collected.
Security
Measures: We aim to maintain appropriate physical, procedural
and electronic safeguards to protect your personal information.
Access: You may access and review
the personal information we retain about you and correct any factual errors.
Contact Us: We hope this policy
answers your questions about our collection and use of your personal information. If you have any questions, please
contact us by following the instructions in the Contact Us section below.
Changes: We may change this policy
from time to time. The policy was
last updated on June 30, 2014.
Detail of our
Privacy Policy
Scope of Policy
This policy covers the
personal information we collect about you in connection with our vehicle
subscription business and services that identify you as an individual. It does not address data that does not
personally identify you as an individual, for example, but without limitation,
aggregated anonymous data, IP addresses, computer operating systems, personal
preferences, vehicle identification numbers, etc. We are free to use information that does
not identify you as an individual as we wish. This policy does not apply to
information collected by third party social networks (such as Facebook), mobile
device manufacturers, third party "mobile apps", wireless service providers,
internet service providers or the operators of any networks through which you
may interact with us and we expressly disclaim any responsibility for the data
collection, privacy or data security practices of those entities. With regard to pages on third party
social networks, this policy only applies to personal information we collect
through our pages (those with a direct link to this policy) and does not apply
to any "unofficial" pages or pages of our affiliates or licensees. Our websites are not directed to
individuals under the age of 13, and we do not knowingly obtain personal data
from such individuals.
When you request services
from us, operate a vehicle or equipment with in‑vehicle or in‑equipment
technology, access our websites, utilize our mobile "apps" or otherwise
interact with us, for example, but without limitation, through our kiosks, our
official corporate pages on third party social networks (such as Facebook) or
the "apps" on those pages, you consent to our collection, retention and use of
your personal data in the manner described in this policy and accept the risks
outlined in the Security Measures section.
Who We Are
We are [Company Name],
a U.S. company based in Atlanta, Georgia, which, together with our subsidiary
companies, provides and supports vehicle subscription services across the
United States. All references in
this policy to "we", "us" and "our" are to us and our subsidiaries. We operate a network of licensees in
provision of our services worldwide and are affiliated to many other companies
through ownership. As our licensees
and affiliates are independent companies, they are not owned or controlled by
us and are not covered by this policy, although they may have their own privacy
policies to govern the personal information they collect. We are not responsible for the privacy
practices of our licensees and affiliates.
Personal
Information
Personal information means information
that identifies you as an individual, or that we can combine with readily
available information to identify you as an individual.
Personal
Information We Collect and How We Use It
The principle purposes for which we
collect and store your personal and financial information are to process your
application and subscription agreement, allow you to reserve and use our
vehicles and services, authorize payment, bill you, respond to your inquiries,
improve our products and services and maintain your account with us. We collect a range of information about
you from a variety of sources for the purposes of our business. The examples we provide throughout this
policy are illustrative rather than a complete list of our practices.
When you visit our websites or apps, our servers might
automatically log certain information about your use of our websites, such as
your IP address, your browser type, operating system, browser language and
service provider. We also collect information about your activities on our
websites and apps, such as the pages you visit or the ads or links you click
on. The first time you visit our website, we may assign you a unique identifier,
which is stored in one or more cookies on your computer's hard drive. These
cookies help us distinguish new visitors from returning visitors and enable us
to measure the effectiveness of content on the website and refine and tailor
that content to suit our visitors' interests. If you have subscribed for our
services or provided other personal information about yourself (for example, if
you send us an email), your cookie ID can be associated with you personally.
When you are signed in to our mobile apps, you will be identified to us by your
account email and/or phone number.
We collect information that you
voluntarily submit to us, such as:
Name, address and contact details, including telephone and mobile number, and email;
Date and place of birth, passport number and driver's license number and a copy of your driver's license;
Employer(s) name and address;
Credit card information;
Driving record and accident history;
Location data such as geographic location of electronic devices used to contact us or to access our mobile "apps" or of the vehicle you are using;
Information regarding the vehicles you subscribe for and use, and the operation of our vehicles during your subscription period;
Charges you incur and other information relating to your transactions;
Information transmitted by your computer's browser software; and
Information about your credit history or other publicly available information about you from consumer reporting agencies.
Your telephone calls and email
correspondence with us may be recorded or monitored for quality control,
training and similar purposes. By using these communication methods you are
consenting to the recording or monitoring of your calls and emails with us and
to our use of the information you provide us for the purposes described in this
policy.
If you subscribe with us, we collect
personal and financial information as you proceed through the stages of our
online application, subscription agreement and reservation process. In addition
to your name and contact information, we will also collect your driver's
license number, the jurisdiction in which you are registered, credit card or
other payment information, and other information. We may also collect information such as
your driving record from regulatory bodies where you live, and from third
parties. This information is used to process your subscription and, if you are
approved, for the purposes described below.
If you use our vehicles and services, we collect
information about the vehicles' use and your use of our services. This may
include details about your reservations, the dates, times and locations of use,
mileage, driving performance, accidents and other data. We use this information to bill you,
respond to your inquiries, ascertain whether you are in compliance with our
polices and rules, provide and improve our products and services and maintain
your account with us, and to provide content and offers that we think may be of
interest to you. From time to time we will send newsletter emails. To
unsubscribe from our newsletters please use the opt out in the email body.
Our vehicles may be equipped with
vehicle tracking and other technology. We implement Global Positioning Systems
(GPS), a network of satellites that allows us to determine the location of our
vehicles. This information is transmitted to us and can be stored for extended
periods. We use this information for a variety of important purposes. For
example, we use GPS data to help you find our vehicles, to provide roadside
assistance, to ensure that a vehicle is available at the place and time you
have reserved, to ensure that the vehicle is not driven to unauthorized
locations and to locate a lost or stolen vehicle. We also maintain in‑vehicle and in‑equipment
technologies to track and monitor performance of our vehicles and to assist us
with ensuring that our vehicles are used only in accordance with applicable
laws and our rules and policies.
Disabling, disconnecting or destroying any such technology device or
equipment is strictly prohibited.
Other
Sources
We also gather personal
information about you from a variety of other sources, including:
Transactions you complete with us and our vendors and licensees, including options you take, charges you incur and any incidents or accidents that may occur;
To the extent you have made such information available, from third party social networks;
Consumer and other reporting agencies; and
Other companies that have business relationships with us, such as our licensees, affiliates and business partners, including road‑side assistance and other service providers and insurance companies.
Where
We Hold Personal Information
We utilize servers in various locations
in the United States of America. If you are accustomed to other countries
privacy laws, please note that the laws governing the processing of personal
information in the United States of America may not be as rigorous as they are
in the United Kingdom, Canada or other nations. By subscribing for and using
our vehicles and services, you consent to the transfer of your personal and
financial information to other locations within the United States for the
purposes described in this policy.
We do not conduct business in countries outside the United States, but
to accommodate subscribers from other countries, we aim to comply with the
privacy laws applicable to the personal data we collect and use.
Clutch Georgia, LLC and those of its
subsidiaries operating within the United States, comply with the U.S.-E.U. Safe
Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the
U.S. Department of Commerce regarding the collection, retention and use of
personal information from European Union member countries and Switzerland. We have certified that we adhere to the
Safe Harbor Privacy Principles of notice, choice, onward transfer, security,
data integrity, access, and enforcement.
We try to ensure that the personal data
we retain about you is stored securely and, in light of the information
provided to us, is as accurate, current and complete as necessary for the
purposes for which we use it. We
generally retain personal data about our subscribers for as long as we believe
appropriate for the purposes for which it was collected or as otherwise
required by applicable law.
Where
We Can Send Your Personal Information
Except as described in this policy, we will
not share your personal information with third parties outside our company
group unless it is necessary to provide our services, verify information you or
your approved secondary drivers provide to us, fulfill a transaction you have
requested, or in other circumstances with your consent. We do however disclose
your personal information within our related company group and to contractors,
advisors, consultants and service providers acting on our behalf or under our
instructions, including for purposes relating to the operation, maintenance,
administration, improvement, and oversight of our services, websites and
advertising services, or to fulfill your requests for information or service.
If you subscribe for our vehicles and
services, some of the information you supply must necessarily be shared with
regulatory bodies where you live and/or service providers we utilize to obtain
your driving record from such regulatory bodies. In addition, if you are
associated or affiliated with another, primary account (for example, if you are
an associate member or affiliated with a business's or university's account),
the primary account holder or administrator of that account may have access to
limited information regarding your use of our services.
We may disclose your personal
information in connection with a corporate transaction, proceeding, or
reorganization involving the business activities for which the information is
maintained. In the event that ownership of our business was to change as a
result of a merger, acquisition, sale of assets or transfer to another company,
your personal information may be transferred. If such a transfer results in a
material change in the way your personal information is used, we will provide
notice about the choices you have to decline to permit such a transfer.
We may disclose your personal
information, including location/GPS data and data gathered from in‑vehicle
and in‑equipment technologies, in response to legal process (for example,
a court order, search warrant or subpoena) or requests from law enforcement
authorities; in other circumstances in which we believe our services, our
vehicles or our website are being or has been used in violation of applicable
law or otherwise in the commission of a crime; when we have a good faith belief
that there is an emergency that poses a threat to the safety of you or another
person; or when necessary to protect our rights or property (or those of third
parties).
To
Provide You Services
We will share your
personal information among our employees and affiliated companies and
employees, our representatives and agents, our licensees and vendors, and other
companies that we engage in business with, to provide services to you,
including to:
Fulfill your vehicle subscription and make your reservations for alternate vehicles;
Process and/or confirm your transactions;
Provide you with enhanced services, such as services provided in connection with our membership programs and similar services;
Provide you services in connection with your use of our vehicles; such as navigation assistance or road‑side emergency assistance;
Provide you services in connection with your use of our vehicles; such as navigation assistance or road‑side emergency assistance;
Provide you with customer assistance;
Bill and collect amounts owed in connection with your subscription and use of our vehicles and services; and
For customer satisfaction and market research purposes to help us improve our services.
To Communicate
With You
We may use your personal information to communicate
with you, including with regards to:
Your subscription or any other transaction with us;
Your status in our membership program(s); or
Changes to the terms or features of your subscription or any policy or rule related thereto.
By subscribing for or using our vehicles and
services, or by contacting us in any way, you give us your consent to call you
on or send text messages to your mobile telephone/device. You also consent to our use of
auto-dialers and pre-recorded messages in connection with any such telephone
call or text message, including calls or texts to mobile telephone
numbers. We will not charge you for
such calls or texts, although you may be charged by your mobile service
provider to which you subscribe.
Disclosure To
Companies You Use
We will also share your information with companies
you use in connection with your subscription, including:
Your credit card provider and other companies that process your charges;
Any company or organization that is paying all or part of your charges; and
Any service provider you use, such as a repair provider, insurance company or other vendor or provider relation to any aspect of your subscription or use of our vehicles.
Protective and
Legal Uses
We may use, share and disclose your personal
information for legal reasons as we believe necessary or appropriate,
including:
under applicable law, including laws outside your state or country of residence;
to process, handle or otherwise respond to claims for damages, including claims or demands for bodily injury or property damage;
to enforce our policies and rules and the terms and conditions of your subscription;
to recover our vehicles, equipment or any monies due, such as through debt collection agencies;
to comply with legal process and to respond to requests from public and government authorities;
to protect our operations, rights, privacy, safety or property, and/or that of our subsidiaries, you or others; and
to allow us to pursue available remedies or limit the damages that we may sustain.
Advertising
We may use personal information to present offers
to you on our behalf and on behalf of business partners, but we do not share
information that personally identifies you with those parties. If you
do not want us to send you promotional emails, please adjust your settings or
utilize our "unsubscribe" feature.
We may also use third party ad network
providers and other service providers to help present customized content and
offers on our websites. These providers use cookies, web beacons, or similar
technologies on your computer to help present, better target, and measure the
effectiveness of their content and advertisements, using data gathered over
time and across their networks of web pages to determine or predict the
characteristics and preferences of their audience. We may share certain
non-personally identifiable information about you (such as age and zip code)
with certain ad network and service providers to help them deliver more relevant
content and advertisements through their networks. The use of cookies,
web beacons, or similar technologies by content and ad network providers is
subject to their own privacy policies, not ours.
Cookies are text files that are placed
in your computer's browser, and that can be used to help recognize you on our
websites. Web beacons are small pieces of code placed on web pages that can be
used, among other things, to count the users who visit that web page, or to
deliver a cookie to the browser of a user viewing that page. Many websites,
including our website, also may use Flash cookies that are similar to regular
browser cookies. You can control
browser cookies through your browser's settings. You may delete cookies or set
your browser to alert you when cookies are being sent. If you reject all
browser or flash cookies, however, some areas of our sites may not function.
Third party advertiser/service provider
may use cookies, web beacons, or similar technologies in connection with
offers, content, and services offered through our website, including to help
operate ad networks. When there are third parties that are performing such
activities, we will endeavor to list the parties in this privacy notice and to
provide a link to their web sites. The use of cookies by our partners,
affiliates, and service providers is not covered by our privacy statement. We
do not have access or control over these cookies. Our partners, affiliates, and
service providers use session ID cookies to make it easier for you to navigate
our site.
Our web site may include social media
features, such as the Facebook Like button and widgets or interactive
mini-programs that run on our site. These features may collect your IP address,
which page you are visiting on our site, and may set a cookie to enable the
feature to function properly. Social media features and widgets are either
hosted by a third party or hosted directly on our site. Your interactions with
these features are governed by the privacy policy of the company providing it,
not by us.
Review
and Correct Your Personal Information
We are committed to providing you with
reasonable and practical access to your information to allow you the
opportunity to identify inaccuracies. If you are a subscriber, you can review and
correct personal information by navigating to the relevant section of our app
or by contacting us. If you would like to access, delete and/or correct other
personal information, please contact us in one of the ways provided below and
we will respond to your request within 30 days. If we are informed of the
inaccuracy we will make the appropriate corrections.
We will retain your information for as
long as your account is active or as needed to provide you services. Please
contact us if you wish to cancel your account or request that we no longer use
your information to provide you services. We will retain and use your
information as necessary to comply with our legal obligations, resolve
disputes, and enforce our agreements.
Security
Measures
As you may be aware, there is no
completely secure method of transmitting or storing information and data. Although their physical characteristics
are different, postal mail, telephone calls, text messages, faxes and transmissions
over the Internet or wireless networks all present possibilities of loss,
misrouting, interception and misuse of the information and data that is
transmitted.
We try to strike a balance between the
security of your information and your convenience. As a result, we may sometimes use a
method of communication that is less secure than a less convenient alternative.
For example, but not limitation, we may
send you an e-mail or a text message in unencrypted form (i.e., instantly
readable) because many of our customers are unable to access encrypted (i.e.,
coded) e-mail or messages. This
means that our message, if misrouted or intercepted, could be read more easily
than encrypted messages. For this
reason, please do not include confidential information, such as your credit
card number, in any e-mail or text you send to us or on any posting you make to
a public area of a third party social network page, especially since any such
posting immediately becomes public.
We take reasonable measures to protect
against the loss, misuse and unauthorized access or disclosure, alteration and
destruction of your personal data by aiming to maintain appropriate physical,
procedural and electronic safeguards to protect your personal data, including:
Restricting access to personal data to our employees on a "need to know" basis;
Enforcing policies and procedures for our employees in their handling of personal data; and
Using technologies designed to safeguard data during its transmission, such as SSL encryption for the data you provide on our websites and apps. In particular, we adhere to the appropriate standards for PCI compliance
Destroying confidential personal data after it is no longer needed.
We have established safeguards to help
prevent unauthorized access to or misuse of your personal information, but cannot
guarantee that your personally identifiable information will never be disclosed
in a manner inconsistent with this policy (for example, as a result of
unauthorized acts by third parties that violate applicable law or our policies
and those of our affiliated providers). We may use a password to help verify
your identity before granting access or making corrections to any of your
personal information. It is your responsibility to safeguard your password,
which you should never disclose to a third party. If you contact us by phone,
we will ask you to verify certain information related to your account before
providing any access to personal information.
Changes
to Our Policy
We may change this policy from time to
time, so it is advisable to review it frequently. Changes to this policy will
be announced on our website or through similar means and all amended terms
shall automatically be automatically effective when posted (or as indicated in
our posts).
Contact
Us
Clutch
Georgia, LLC
If you have questions about our
handling of personal information, you may write to us at hello@driveclutch.com or at the address
below.
Clutch Georgia, LLC
3535 Piedmont Road NE
Suite 1500
Atlanta, GA 30305