Date Last Revised: December 20, 2021
1. user consent.
2. a note about children.
We do not intentionally gather Personal Data about visitors who are under the age of 13.
3. a note to users outside of the united states.
Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.
4. types of data we collect.
We collect Personal Data and Anonymous Data (as defined below) from you when you visit our Website, when you send us information or communications, and/or when you download and use our Software and otherwise use our Services. “Personal Data” means data that enables another person to identify or contact you, including, for example, your name, address, telephone number, e-mail address and credit card information, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data and does enable another person to identify or contact you. We collect Personal Data and Anonymous Data, as described below.
4.1 Personal Data You Provide to Us. We collect Personal Data from you, such as your name, phone number, e-mail, mailing addresses, company name, credit card number and password when you create an account to log in to our network (“Account”). We also retain information on your behalf, such as your cab preferences. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply. When you participate in one of our surveys, we may collect additional profile information. We may also collect Personal Data from you via the Software or at other points in our Website that state that Personal Data is being collected.
If you wish to apply for a job on our site, we will collect personal information such as your name, email address, phone number and additional information such as your resume, gender and ethnicity. We use the information collected within this area of the site to determine your qualifications for the position in which you have applied and to contact you to set up an interview.
4.2 Personal Data Collected via Technology.
(a) To provide you the Services, if you are a user of our mobile application for drivers of vehicles for hire (a “Driver User”), we collect the GPS location of the handheld mobile device on which the Software is installed periodically. If you are a user of our mobile application for passengers (a“Passenger User”), we collect the GPS location of the handheld mobile device on which the Software is installed when you hail a vehicle or select to disclose such information to Driver Users or other Passenger Users. The Services allow Passenger Users to hail a vehicle and direct pick-up to select commercial locations, such as a nearby coffee shop or retailer. If you are a Passenger User and select a commercial location, we will collect that location.
(c) When you use the Services, we may employ clear GIFs (also known as “web beacons”) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information is allows for more accurate reporting and improvement of the Services.
4.3 Personal Data That We Collect from You About Others. If you decide to create an Account for and invite a third party to join our network, we may collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. You or the third party may contact us at the contact below to request the removal of this information from our database.
5. use of your data
5.1 General Use. In general, Personal Data you submit to us is used either to respond to requests that you make or to aid us in serving you better. We use your Personal Data to provide the Services; and to charge you for the Services; to facilitate the creation of and secure your Account; to identify you as a user in our system; to provide improved administration of our Website, Software, and other Services; to improve the quality of your experience when you interact with our Website, Software, and other Services; to send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created; to send you administrative e-mail notifications, such as security or support and maintenance advisories; to respond to your inquiries and requests; to send promotional or marketing communications for our products and services or those of third parties; to provide you with hardcopy or electronic newsletters, or surveys; or to solicit your feedback; to provide advertising to your browser or device; if you are Passenger User, to collect credit card payments; and, if you are a Driver User, to check your background and to payments to you.
5.2 Creation of Anonymous Data We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Website, Software and other Services. We reserve the right to use Anonymous Data and disclose such Anonymous Data to third parties in our discretion.
6. disclosure of your personal data
6.2 Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on Company; or (b) protect or defend the rights or property of Company or users of the Website, Software or other Services.
7. third parties
7.2 Disclosure to Third Party Service Providers Except as otherwise stated in this policy, we do not sell, trade, share, or rent the Personal Data collected from our services to other entities. However, we may share your Personal Data with third party service providers to provide you with the Website, Software and other Services that we offer you; to conduct quality assurance testing; to facilitate creation of Accounts; if you are a Passenger User, to collect credit card payments; if you are a Driver User, to process your payments; to provide technical support; or to provide specific services to your or the Company. These third party service providers are required not to use your Personal Data other than to provide the services requested by Company. You expressly consent to the sharing of your Personal Data with our contractors and other service providers for the sole purpose of providing services to you or us.
7.4 Background Check If you are a Driver User, you expressly consent to the sharing of your Personal Data with the third parties you list as references during the registration process for the sole purpose of the Company performing a background check on you.
7.5 Disclosures to Other Users. (a) To provide you the Service, the Software tracks the GPS location of the handheld mobile device on which the Software is installed. If you are a Driver User, such GPS information will be disclosed to other Driver Users and Passenger Users of the Services. If you are a Passenger User, such GPS information will be disclosed to other Driver Users and Passenger Users of the Service that you select to receive such GPS information, including, without limitation, any Driver User you hail until you select not to disclose such information to them or until the Driver User picks you up (as applicable).
(b) If you are a Passenger User and you have associated a phone number with your Account (defined below), your phone number may be disclosed to other Driver Users and Passenger Users of the Service that you select to disclose your phone number to, including without limitation, any Driver User you hail until you select not to disclose such information to them or until the Driver User picks you up (as applicable).
(c) The Service allows Passenger Users to hail a vehicle from select commercial locations (e.g., a Starbucks). If you are a Passenger User and select a commercial location, we will disclose the commercial location to other Driver Users and Passenger Users of the Service that you select to disclose your commercial location to, including without limitation, any Driver User you hail until you select not to disclose such information to them or until the Driver User picks you up (as applicable).
(d) You expressly consent to our collection, disclosure, and use of such GPS location, phone number, and commercial location (as applicable) as described above.
8. your choices regarding your personal data
8.2 Changes to Personal Data. You may change any of your Personal Data in your Account by editing your profile within the Software or by sending an e-mail to us at the e-mail address set forth below. You may request deletion of your Personal Data by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.
9. security of your personal data.
We are committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. Despite these measures, you should know that Company cannot fully eliminate security risks associated with Personal Data and mistakes may happen.
10. contact information.
11. dispute resolution.
If you believe that Company has not adhered to this Statement, please contact Company by e-mail at the contact above. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.
13. Data retention and deletion.
Flywheel retains user data for as long as necessary for the purposes described below.
Users may request deletion of their accounts at any time. Flywheel may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.
This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.
Users may request deletion of their account at any time by emailing email@example.com.
Following an account deletion request, Flywheel deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers, this generally means that we retain their account and data for a minimum of 7 years after a deletion request.