LAST UPDATE: January 1, 2020
This Policy describes the types of personal information we collect through the Site and how that personal information may be used and/or with whom it may be shared. This Policy also describes how you can reach us to update your personal information, access and control the use of the personal information, or get answers to questions you may have about our privacy practices at this Site. Please read this Policy carefully, because by accessing and using this Site you are acknowledging that you understand and agree to the terms of this 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.
- 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.
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.
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.
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.
- GENERAL PRINCIPLES FOR THE PROCESSING OF PERSONAL INFORMATION
Personal information will be collected, stored, processed and transmitted in accordance with MobilityWorks’ established policies and applicable federal, state, local and foreign laws, rules and regulations.
The principles of MobilityWorks with respect to the processing of personal information are as follows: (1) personal information will be processed fairly and lawfully, (2) personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal information collected by MobilityWorks will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and processed, (4) personal information collected by MobilityWorks will be accurate and, where necessary, kept up to date to the best of our ability, (5) personal information collected by MobilityWorks will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected, and (6) personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
If MobilityWorks engages in the processing of personal information for purposes other than those specified in this Policy, MobilityWorks will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.
- THIRD-PARTY SITES AND SERVICES
This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property on this Site does not imply endorsement of it by us or by our affiliates.
Third parties may offer products and services on the Site and collect information about you by requesting certain information necessary to provide a particular product or service (including, for example, insurance coverage for your MobilityWorks products or reports of insurance claims). MobilityWorks may also obtain certain information about its users from third-party customer research groups (e.g., demographic information) which MobilityWorks uses to learn more about its customers. MobilityWorks does not control the policies and practices of third parties in relation to the use and disclosure of any information about users collected by third parties on the Site or in market research programs conducted by such third parties and any use or disclosure of such information by third parties is not governed by this Policy.
- CHOICES AND ACCESS
We give you choices regarding our use and disclosure of your personal information. MobilityWorks provides you with the opportunity to receive information by email, regular mail or telephone calls from MobilityWorks, or third parties which may be of interest to you, including information relating to new products and services offered on the Site by MobilityWorks, or other third parties. If you do not want to receive any information by email, regular mail or telephone calls, you may opt out of further communications provided by MobilityWorks at any time by: (i) submitting a request at firstname.lastname@example.org; or (ii) writing to MobilityWorks at MobilityWorks at the address listed below, Attention: Customer Service. Please note that MobilityWorks can only comply with requests relating to email, regular mail, or telephone communications provided by MobilityWorks. If you no longer wish to receive further information by email, regular mail, or telephone from any third party, you will need to contact such third party directly to opt out of further communications being provided to you. We will seek to comply with your request(s) as soon as reasonably practicable.
If applicable, and you would like to review, correct, update, or delete the personal information that you have provided via this Site, please contact us. We will try to comply with your request as soon as reasonably practicable.
It is your responsibility to provide MobilityWorks with accurate personal information. Except as otherwise set forth in this Policy, MobilityWorks shall only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, MobilityWorks shall take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.
- YOUR RIGHTS OVER YOUR INFORMATION
You can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. You can also ask for it to be erased and you can ask us to give you a copy of the information. You can also ask us to stop using your information and limit how we use your information.
Your California Privacy Rights
The California Consumer Privacy Act (“CCPA”) provides California residents with the following privacy rights:
- Right to Know: Consumers have a right to request information about the personal information that we collect, use, disclose, and sell.
- Right to Delete: Consumers have a right to request the deletion of personal information that we have collected from them, though we may be permitted to retain personal information for certain purposes.
- Right to Opt-out of Sales: We do not share your information with third parties in exchange for money. We do share your information with third parties to enhance your experiences with us, to improve our ability to serve you, and to keep you aware of our products, services, and offers. California law may treat some such disclosures as sales, and consumers have a right to direct us not to sell their personal information.
- Right to Opt-out of Financial Incentive Programs that we may offer.
- Non-Discrimination: We may not discriminate against you for exercising your rights under the CCPA. We may, however, provide a different level of service or charge a different rate if the difference is reasonably related to the value of your information.
If you are a California resident, or an authorized agent acting on behalf of a California resident, and would like to exercise one of these rights, please send an email message to email@example.com with “CCPA Consumer Request” on the subject line and in the body of your message. We will provide the requested information to you at your email address in the response. Please note that we may require additional information from you in order to honor your request, and there may be circumstances where we will not honor your request, as permitted under the CCPA. For example, if you request deletion, we may need to retain certain personal information to comply with our legal obligations.
If you are a California resident under the age of 18, and a registered user of our Site, California Business and Professions Code Section 22581 permits you to request and obtain removal of content that you have publicly posted. To make such a request, please send an email with a detailed description of the specific content to us via the email address set forth below. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information that you have posted and there may be circumstances in which the law does not require or allow removal even if requested.
- RETENTION PERIOD
We retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law or to otherwise fulfill a legal obligation.
MobilityWorks has implemented security measures designed to protect personal information provided by you against unauthorized access and use. MobilityWorks also uses commercially reasonable efforts to establish secure connections with your web browser for any transactions conducted online using a credit card or other financial information you may provide to MobilityWorks. Please be aware, however, that no-data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the CONTACTING US section below.
- USE OF SITE BY MINORS
We do not intentionally collect information from individuals under the age of 16. The Site is not directed to individuals under the age of 16, and we request that these individuals not provide personal information through this Site.
- COMPLIANCE WITH LOCAL LAWS
Notice about the European Union’s General Data Protection Regulations (“GDPR”):
You may have certain rights under the European Union’s GDPR 2016/679. The GDPR is a complex regulatory scheme and we do not intend to provide every detail here. If interested you should read the GDPR and the relevant guidance provided by the applicable authorities for a fuller explanation.
The GDPR provides the right, where applicable, to (a) access, (b) publication, (c) erasure, (d) restrict processing, (e) object to processing, (f) data portability, (g) complain to a supervisory authority, and (h) withdraw consent.
Where applicable, the GDPR provides the right to confirm whether MobilityWorks has processed your Personal Data (as defined in the GDPR) and, when MobilityWorks, to access those data, together with certain other information including the purposes of the processing, the categories of Personal Data concerned, and the recipients of the Personal Data. Where applicable, and providing that we do not affect the rights and freedoms of anyone else, we will supply you with one copy of your Personal Data. The first copy is free. We may charge a reasonable fee for additional copies.
Where applicable, the GDPR provides the rights to rectify any inaccurate Personal Data about you and, taking into account the purposes of the processing, to complete any incomplete data about you.
In some circumstances the GDPR provides you the right to erase your Personal Data without undue delay, including when we no longer need the Personal Data for the purposes for which we collected or processed the Personal Data, if you withdraw your consent to consent-based processing, if you object to the processing of the Personal Data under certain rules of the GDPR, if the processing is for the purpose of direct marketing, and if the Personal Data have been unlawfully processed. However, the GDPR provides exceptions or exclusions to the right to erase, including where the processing is necessary for the exercise of free expression and information, to comply with a legal obligation, or to establish, exercise, or defend a legal claim.
In some circumstances the GDPR provides the right to restrict the processing of your Personal Data, such as to contest the accuracy of the Personal Data, where the processing is unlawful but you oppose erasure, when we no longer need the Personal Data for the purpose of our processing but you require Personal Data to establish, exercise or defend a legal claim, and you have objected to the processing pending the verification of that objection. When processing has been restricted on this basis, we may continue to store your Personal Data. But we will process your data otherwise only with your consent, to establish, exercise or defend a legal claim, or to protect another natural or legal person’s rights, or for reasons of important public interest.
If applicable, the GDPR provides the right to object to our processing of your Personal Data on grounds relating to your situation, but only to the extent that the processing is necessary for a task carried out in the public interest or to exercise any official authority vested in MobilityWorks, or for a legitimate interest pursued by MobilityWorks or someone else. If you object, we shall stop processing the Personal Data unless we can demonstrate compelling legitimate grounds to process the information that override your interests, rights and freedoms, or the purpose of the processing is to establish, exercise or defend a legal claim.
You may object to our processing of your Personal Data for direct marketing purposes including profiling for direct marketing purposes. If you notify us of such an objection, we shall stop processing your Personal Data for that purpose.
You may object to our processing of your Personal Data for scientific or historical research or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for a task carried out in the public interest.
If the legal basis for our processing your Personal Data is consent or that the processing is necessary to perform a contract to which you are a party, or in order to take steps at your request before entering into a contract, and such processing is carried out by automatic means, you have the right to receive your Personal Data from us in a structured, commonly used, and machine-readable format. But this right does not apply when its Site will adversely affect the rights and freedoms of others.
If you believe that our processing of your Personal Data infringes any data-protection statute, rule or regulation, you may lodge a complaint with the appropriate authorities responsible for data protection. If applicable, you may lodge that complaint in the European Union member state of your habitual residence, your workplace, or the place of the alleged infringement.
To the extent that we base our processing of your Personal Data on your consent, you may withdraw that consent at any time. But your withdrawal of that consent will not affect the lawfulness of any processing we do before your withdrawal.
If applicable, you may exercise any of your rights in relation to your Personal Data by emailing MobilityWorks at firstname.lastname@example.org.
We may change this Policy. Please review the LAST UPDATE legend at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on this Site. Your use of this Site following these changes means that you accept the revised Policy.
MobilityWorks will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented, and accessible. If you believe that your personal information has been processed or disclosed in violation of this Policy, MobilityWorks encourages you to raise any concerns using the contact information provided in this Policy. MobilityWorks will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.
- CONTACTING US
If you have any questions about this Policy, please contact us using the contact information below.
Mailing: 4199 Kinross Lakes Parkway, Ste. 300 Richfield, OH 44286