What information do we collect? In order to operate the promogo service and to provide our Services, including, but not limited to, matching commuters and drivers with advertisers, we must ask you to provide nonpublic personal information about yourself, such as your name, e-mail address and mobile number (“Personal Information”). We may collect this information through various forms and in various places through the Services, including account registration forms, “contact us forms”, or when you otherwise interact with us. When you sign up to use the Services, you create a user profile. The current required data fields are:
In addition to any Personal Information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Services (“Usage Information”). This Usage Information may include the browser that you are using, the URL that referred you to our Services, all of the areas within our Services that you visit, and the time of day, among other information. We may use Usage Information for a variety of purposes, including to enhance or otherwise improve the Services. In addition, we collect your IP address or other unique identifier (” Device Identifier”) for your computer, mobile or other device used to access the Services (any, a “Device”). 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. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information or a Device Identifier with your Personal Information, we will treat it as Personal Information.
In addition, tracking information is collected as you navigate through our Services, including, but not limited to geographic areas. For all drivers using our Services, the driver’s mobile phone will send your GPS coordinates, during the commute, to our servers. Most GPS enabled mobile devices can define one’s location to within 50 feet. We collect this information for various purposes – including to determine the amount of money you earn while performing the Services, to provide you with support, to send you promotions and offers, to enhance our Services, and for our internal business purposes. We may also have features that allow you to share this information with other people (such as your family, friends or colleagues) if you choose.
In addition, our advertisers can see the GPS coordinates recorded by the driver’s mobile phone for all driving time, as well as certain information about you (such as your name and other Personal Information).
A few of the methods that may be used to collect Usage Information include, without limitation, the following (and subsequent technology and methods hereafter developed):
Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web and mobile pages and messages. The web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored in a user’s computer hard drive, web beacons are embedded invisibly on Web pages. Web beacons or similar technologies help us better manage content on our Services by informing us what content is effective, count users of the Services, monitor how users navigate the Services, count how many e-mails that we send were actually opened or to count how many particular articles or links were actually viewed. We do not tie the information gathered by web beacons to your personal information.
An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
If you wish to apply for the Services on our web site, we will collect Personal Information such as your name, email address, phone number, driving history, criminal history and insurance information, and may collect additional information such as resume, gender, and your ethnicity. We use the information collected within this area of the web site(s) to determine your qualifications for the position in which you have applied and to contact you to set up an interview. We use the information collected within this area of the web site to determine your qualifications for the position in which you have applied and to contact you to set up an interview.
Specific Driver Privacy Statements
promogo may collect personal data from you during the course of your sign-up for, and use of, the Services, including location data, which information may be stored, processed, and accessed by promogo for business purposes, including for marketing, lead generation, service development and improvement, analytics, industry and market research, and such other purposes consistent with our legitimate business needs. You expressly consents to such collection and use of personal data.
Subject to all applicable laws, promogo may provide to a third party any information (including Personal Information) about you and/or the Services provided hereunder if:
Driver expressly consents to promogo’s use of location-based services, and Driver expressly waives and releases promogo and its Affiliates from any and all liability, claims, causes of action or damages arising from Driver’s use of the promogo Services, or in any way relating to the use of the geo-location and other location-based services.
If you choose to use our referral service to tell a friend about our Services, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Services. We store this information for the sole purpose of sending this one-time email and tracking the success of our referral program, and do not use this information for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality through our Services, your e-mail address may be included in the communication sent to your friend. Your friend may contact us through email@example.com. to request that we remove this information from our database.
Our Services are primarily provided through an application on your mobile, tablet computer or similar device (“Mobile Application”). You agree that we may collect and use technical data and related information, including but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to such Mobile Applications.
When you use any of our Mobile Applications, the Mobile Application may automatically collect and store some or all of the following information from your mobile device (“Mobile Device Information”), including without limitation:
Information about how you interact with the Mobile Application and any of our web sites to which the Mobile Application links, such as how many times you use a specific part of the mobile application over a given time period, the amount of time you spend using the Mobile Application, how often you use the Mobile Application, actions you take in the Mobile Application and how you engage with the Mobile Application.
Information to allow us to personalize the services and content available through the Mobile Application.
We may use information automatically collected by the Mobile Application (including the Mobile Device Information) in the following ways:
We also provide some of your Personal Information (such as your first name and your photo, if you have chosen to upload your photo to your profile) to the advertisers with whom you choose to associate with. Those advertisers, as well as promogo, are also able to access your Personal Information, including your geo-location data.
We may associate your unique mobile Device Identifier or Mobile Application usage information with any Personal Information you provide, but we will treat the combined information as Personal Information.
How do we use your information?
Our primary goal in collecting your Personal information or Usage Information is to provide you with an enhanced experience when using the Services. We use your nonpublic personal in order to match you with advertisers and to otherwise assist you and allow you to perform the Services, respond to your requests, customize your experience on the promogo site and contact you regarding your account. If you give us permission, we will also use your information to make you aware of additional products and services that may be of interest to you or to contact you regarding site changes.
Based upon the Personal Information you provide us when registering for an account, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email, telephone, or SMS or text message, in accordance with your wishes.
We use your information to closely monitor which features of the Services are used most, to allow you to view your commuting history, view any promotions we may currently be running, rates applicable to your commutes, and to determine which features we need to focus on improving, including usage patterns and geographic locations to determine where we should offer or focus services, features and/or resources.
We use the information collected from our Mobile Application so that we are able to serve you the correct app version depending on your device type, for troubleshooting and in some cases, marketing purposes.
We use your Internet Protocol (IP) address to help diagnose problems with our computer server, and to administer our web site(s). Your IP address is used to help identify you, but contains no personal information about you.
We will send you strictly service-related announcements on occasions when it is necessary to do so. F or instance, if our Services are temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
In addition, we may use your Personal Information or Usage Information that we collect about you:
Please note that information submitted to the Services via a “contact us” or other similar function may not receive a response. We will allow advertisers with whom you associate in connection with the Services to contact you via the promogo site but will not share your actual email address.
The Personal Information and Usage Information we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information and geo-location information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet or wireless communication, and any information you transmit to the Company you do at your own risk. We recommend that you not disclose your password to anyone.
With whom do we share your information?
We respect your right to privacy, so we do not provide your name or any other nonpublic personal information to any third parties, [except the advertisers you are working with] or [except that we will identify your screen name as a supporter of a project and allow the project sponsor to contact you using our service].
Notwithstanding anything else to the contrary, we reserve the right to disclose your nonpublic personal information as required by law and when we believe disclosure is necessary to protect our rights.
Your receipt of information from third parties
Third Party Content. The Services may contain content that is supplied by a third party, and those third parties may collect web site usage information and your Device Identifier when web pages from any online or mobile Services are served to your browser. In addition, when you are using the Services, you may be directed to other sites or applications that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. For example, if you click on a banner advertisement or the domain or other controlled application of any advertiser, the click may take you away from our website onto a different web site. These other web sites may send their own cookies to you, independently collect data or solicit Personal Information and may or may not have their own published privacy policies. We encourage you to note when you leave our Services and to read the privacy statements of all third party web sites or applications before submitting any Personal Information to third parties.
Administrative and legal reasons for disclosure of your Personal Information
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate:
Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion. Such disclosures may be carried out without notice to you.
Correcting inaccuracies in your information
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. promogo allows you to change or correct your personal information at any time. To do so, simply log into your account, go to your account profile, and you will find options for editing the information you have submitted. If, at any time, you have questions or concerns about promogo's privacy commitment, please feel free to email us at firstname.lastname@example.org. to contact one of our representatives.
Cancellation of your account
If you no longer desire to participate in the Services, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through email@example.com. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
California Privacy Rights
California’s “Shine the Light” law, California Civil Code § 1798.83, requires certain businesses to respond to requests from individuals in California (those who have an established business relationship with us) asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose your personal information to third parties for the third parties’ direct marketing purposes unless you first affirmatively agree to the disclosure (opt-in) or if you have exercised an option to opt-out of such information-sharing (opt-out).
We have opted for this alternative approach, and we do not share your personal information with third parties for the third parties’ direct marketing purposes unless you provide us with permission at the time you provide such information.