MobilityWorks Privacy Policy

COLLECTION AND USE OF PERSONAL INFORMATION

As you interact with MobilityWorks, there may be opportunities for you to provide us with your information. Additionally, we may collect certain information about you or your MobilityWorks products and services as further described below.

You may provide us with information about you or your MobilityWorks products and services through a number of sources: MobilityWorks websites, applications, products, and related events, surveys, social media platforms, sweepstakes or contest entries, and through our customer contact centers. We also receive information about you through MobilityWorks sales and support records provided upon purchase and we may obtain, with your consent, data obtained from your MobilityWorks product.

The types of information that MobilityWorks collects about you may include, but are not limited to:

• Contact information (such as name, address, city, state and ZIP code, age or date of birth, occupation, email address and telephone number)
• Payment information (such as your bank account information, credit card number, debit card number, bank or investor account, CVV code, expiration date, and payment history)
• Information related to your creditworthiness, assets, income, or liabilities
• Information about your MobilityWorks product (such as license plate number, MobilityWorks product identification number (VIN), make, model, model year, selling dealer, servicing dealer, date of purchase or lease, lease/financing term, service history, mileage, oil/battery status, fuel or charging history, electrical system function, gear status, and diagnostic trouble codes)
• Demographic information (such as gender, date of birth, marital status, and household composition)
• Photographs and videos such as those that you may submit for contests, sweepstakes, and social sharing
• Social Security Number (in limited circumstances MobilityWorks may collect SSN, for example, if you win a sweepstakes or receive compensation that must be reported for government tax purposes)
• The kind of MobilityWorks product you purchased
• The kind of service provided to you

The information MobilityWorks collects about you and your MobilityWorks products may be used:

• To provide products and services and maintain customer relationships
• To improve the quality, safety, and security of our products and services
• To administer your account(s) and process your payments for products and services
• To operate our websites and applications, including registration processes
• To autofill data fields on our websites to improve your online experience
• To develop new products and services
• To provide customer and MobilityWorks product support and service (such as recall information)
• For warranty administration and validation
• To provide information and product updates
• To evaluate MobilityWorks product performance and safety
• For research, evaluation of use, and troubleshooting purposes
• To verify eligibility for MobilityWorks product purchases or incentive programs
• For marketing and analytics purposes
• To support the electronic signature and delivery process between you and the dealer
• To customize and improve communication content
• To comply with legal, regulator, or contractual requirements

Communications with you in connection with these uses may be via mail, telephone, e-mail, text message, social media, or other electronic messages, or via our websites and applications.

Personal Information You Provide

The privacy and security of the personal information that MobilityWorks collects from you is a priority for MobilityWorks. When you visit this Site you may be asked or choose to provide personal information that could reasonably be used to contact you or to identify you personally including, but not limited to: your name, address, telephone number, and email address. If you choose to purchase any products or use services offered on the Site, MobilityWorks may ask you to provide your name, mailing address, telephone number and email address, as well as certain financial information for the purposes of credit checks, payment, and processing of any order.

• If you purchase products from the Site, we request that you provide your name, email address, billing and shipping address, credit card information, and any other information necessary to complete the transaction.
• You may choose to finance your purchase of products from MobilityWorks pursuant to one of several financing options made available by third-party financial institutions. If you choose to finance your purchase of any products, you will be directed to one of the third-party financial institutions with which MobilityWorks has a business relationship to make an application directly through that financial institution in connection with which the financial institution will ask you for the personal and financial information applicable to their own application process, the privacy and security of which will be governed by their privacy policies.
• Depending upon the choices you make in connection with your purchases of any products or services offered by MobilityWorks or a third party with which MobilityWorks does business, you will be asked for personal information including your name, mailing address, telephone number, email address and certain financial information such as a credit card number to be used for order processing and payment.
• You may choose to receive certain communications from MobilityWorks via your email address upon interaction with the Site. From time to time MobilityWorks may include surveys, information requests, or other features on the Site which ask you to provide personal information such as your name, telephone number, email address or mailing address. Any information you may provide will be used by MobilityWorks to allow you to participate in the particular feature being offered. MobilityWorks may also retain any information you provide in order to send you information about MobilityWorks’ products and services that may be of interest to you. MobilityWorks will provide you with the opportunity to opt out of receiving such communications. We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third parties without your permission.
• From time to time, MobilityWorks may offer sweepstakes, games, and other contests on the Site either by itself or in conjunction with a third-party partner. You may be asked to provide your name, mailing address and/or email address and date of birth, as well as certain other information on an optional basis (e.g., your gender, annual household income or other types of MobilityWorks products that you have purchased), in order to participate in such sweepstakes or contest. This information may also be used by MobilityWorks or its third-party partner to send you information about MobilityWorks’ or such third-party partner’s products and services in the form of an email or regular mail communication or a telephone call. MobilityWorks will provide you with an opportunity to opt out of receiving such communications from MobilityWorks each time you receive such a communication. However, MobilityWorks does not control, and shall not be responsible for, the privacy policies or practices of its third-party partners. If you no longer wish to receive such communications from any third-party partner of MobilityWorks in sweepstakes or other contest that you may enter, you will need to contact such third-party partner directly.

You will be informed what personal information is required and what information is optional when asked to submit personal information to us. By submitting personal information to MobilityWorks at this Site, you hereby consent to MobilityWorks’ collection, use, and disclosure of such personal information.

We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources (including information from your publicly available social media profiles), and other third parties.

Passive Information Collection and Use

As you navigate around this Site, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies. We passively collect and use information in a variety of ways, including:

• Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We may collect similar information, such as your device type and identifier if you access this Site through a mobile device.
• Cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on this Site, pages visited, and language preferences. We and our service providers use the information for security purposes, to facilitate navigation, and display information more effectively. In addition, we use cookies to gather statistical information about Site usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us in resolving questions regarding it.
• You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. If you set your browser to reject cookies, part of the Site may not work for you.
• Pixel tags, web beacons, clear GIFs, or other similar technologies: These may be used in connection with some Site pages to, among other things, track the actions of Site users and compile statistics about Site usage and response rates.
• IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits this Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering this Site.
• Device Information: We may collect information about your Device, such as a unique device identifier.
• Do Not Track Requests: Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytics and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or Device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of Device or browser, it may not be possible to delete or disable all tracking mechanisms on your Device.

THIRD-PARTY PIXELS AND COOKIES

Notwithstanding anything else in this policy, we and our partners may use pixels and pixel tags, including GetEmails pixel tags, and place, read or use cookies to collect information from your device and Internet browser.  These cookies do not contain personally identifiable information.  However, it may be possible for our third-party business partners to combine it with other information in order to identify your email address or other information about you.  For example, the cookies may reflect de-identified demographic or other data linked to data you have voluntarily submitted to us, e.g., your email address, which we may share with a data provider solely in hashed, non-human readable form.  Visitors can also express their choices for display advertising, through the following platforms: the Digital Advertising Alliance’s opt-out platform at https://optout.aboutads.info/?c=2&lang=EN or the Network Advertising Alliance’s opt-out platform at http://optout.networkadvertising.org/?c=1.

We permit third-party advertising partners to use the foregoing tracking technologies to collect information about your browsing activities over time and across different websites when you use the Site. For example, we use advertising services provided by third-party ad partners, such as Google, to market our service to you on other websites and online services. Through a process called “retargeting,” each service places a cookie on your browser when you visit the Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal. Additionally, many advertising companies are members of the NAI or DAA and/or provide opt outs on those industry pages at networkadvertising.org/choices or aboutads.info/choices.

We utilize Google Analytics on the Site. Google Analytics is a website analysis service provided by Google, Inc. (“Google”). Google utilizes the data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. For more information on Google’s Privacy Policy go to https://www.google.com/intl/en/policies/privacy/. Users can opt out of Google Analytics tracking at https://tools.google.com/dlpage/gaoptout/.

Some additional Google Analytics features that MobilityWorks uses are:

• Google Analytics Demographics and Interest Reporting – allows MobilityWorks to see the age, gender and interests of website visitors to better understand them and personalize advertising.
• Google Display Network Impression Reporting – for banner ads.
• Remarketing through Google Analytics for Display Advertising – allows personalization of ads on our ad networks.
• User ID Extension for Google Analytics – allows MobilityWorks to connect multiple devices, sessions and engagement data.

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt-Out page or by using the Google Analytics Opt-Out Browser add on.

Integrated Accounts and Social Media Information

We may implement applications or "widgets" from third-party providers (e.g., Facebook, Twitter, Instagram, LinkedIn, etc.) that allow interaction, integration or content sharing with third-party services. These widgets or applications may be visible on a page you visit on our Site or may require log-in through the third-party provider’s service. The third party providing the widget or integration may offer controls for you to manage your interactions. Any interaction with a third-party widget or application typically allows the third party to collect some information about you (whether through cookies, registration information or otherwise). These third parties may even track you when you do not interact with the widget. If you have engaged any of these third-party service providers, their respective privacy policies will govern their tracking and collection of information. You should review these third-party policies to understand these practices.

How We Use and Disclose Information

We use and disclose personal information you provide to us as described to you at the point of collection, such as when you (1) register for a user account, (2) submit payment or credit card information, (3) submit your name and e-mail address to receive product updates and marketing information, and (4) send e-mail messages or feedback, or transmit other information by e-mail. When you elect to engage in such activities, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), e-mail address, mobile telephone numbers, and payment information.

We also use and transfer personal information from or about you:

• to respond to your inquiries and fulfill your requests, such as to send you documents you request or e-mail;
• to send you information regarding our relationship with you or regarding this Site, changes to our terms, conditions, and policies and/or other administrative information; and
• for our business purposes, such as marketing new products and services, data analysis, audits, developing new products or services, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our Site.
• to our third-party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, credit card processing, IT services, e-mail services, marketing services, auditing services, and other services, in order to enable them to provide services;
• to verify your information, approve your registration as a user of the Site, authenticate payments and process orders, MobilityWorks may disclose certain financial and other information you provide to MobilityWorks to third parties offering products and services for sale on the Site, as well as to third parties that provide credit reporting, payment or order fulfillment services;
• 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); and
• when we otherwise have your consent. For example, if you sign up for programs offered by our partners, we may share certain information with the partner. This could include but is not limited to, enrollment information and the activation status of your device.

In addition, we use and disclose personal information collected through this Site as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our agreements and terms of use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose personal information collected through this Site in other ways, with your prior consent.

We also use and disclose information we collect passively as described above, under "Passive Information Collection and Use," and for any other purpose, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as personal information). In addition, we may use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

Use of Information for Marketing Purposes

MobilityWorks and our affiliates may send you regular promotional communications about our products, services, events, and promotions. Such promotional materials may use the “MobilityWorks” brand and may be sent to you via different channels, such as email, phone, SMS text messages, postal mailings, and third-party social networks.

In order to provide you with the best-personalized experience, sometimes these communications may be tailored to your preferences (for example, as you indicate these to us, as we may have inferred from your Site visits, or based on the links you click in our emails). When required by applicable law, we will obtain your consent before starting these activities. In addition, you may withdraw your consent (opt out) at any time.

In particular, you can opt out from receiving marketing-related emails by following the unsubscribe instructions provided in each email. If you can sign-in to your MobilityWorks account, you may be able to change your communication preferences under the relevant section of the Site. You can also contact us using the contact details provided below to opt out from receiving marketing-related communications.

Please note that even if you opt out from receiving marketing communications, you might still receive administrative communications from us, such as technical updates of our products, order confirmations, notifications about your account activities, and other important notices.