GoSedan PRIVACY POLICY

GoSedan is dedicated to protecting your personal information and informing you about how we use it. This privacy policy applies to transactions and activities and data gathered through the GoSedan Platform and Services. Please review this privacy policy periodically as we may revise it in accordance with the terms of the GoSedan Terms of Service Agreement (the “Agreement”). This privacy policy was last revised on June 10, 2014. Each time you use the GoSedan Platform and Services or otherwise provide us with your information, you are accepting the practices described in this privacy policy at that time. Capitalized terms that are not defined in this privacy policy have the meanings given to them in the Agreement.

INFORMATION WE COLLECT

PERSONALLY-IDENTIFYING INFORMATION

In order to use the GoSedan Platform and Services, we collect “Personal Information” disclosed by you that could be used to contact or identify you without using the GoSedan Platform, such as your first and last name, phone number, and e-mail address. Personal Information also includes your financial information, such as your credit card information, which are used to process transactions through the Services.

If you wish to register for the GoSedan Platform as a driver or a passenger, we may collect Personal Information from you such as your photo, photo of your vehicle, your vehicle make, model, and year, driver’s license number, automobile registration information, automobile insurance policy information, as well as any information you permit us to collect as part of a background check.

If you choose to connect your social network accounts such as Facebook, we collect your login credentials to those accounts.

SERVICE BASED INFORMATION

We and our third-party service providers may use certain technologies in order to collect “Usage Information” about your use of the GoSedan Platform and Services. Usage Information includes the type of browser you use, any referral URL(s) used, the areas of the GoSedan Platform that you visit, and other information. In order to provide you with the Services, we also collect as “Usage Information” your IP address and/or unique identifiers for your computer and/or mobile device which you use to access the GoSedan Platform.

Usage Information also includes location tracking information if you use the Services in order to arrange a ride with other Users. This necessarily includes your geographic area information. Whether you are a driver or passenger, your location information will be used to help identify and locate you in relation to other Users. Your location information is also used by us for other purposes, such as determining the charge that should be applied for any rides requested, providing customer support, sending you promotions and offers, enhancing the functionality of any Services, and our own internal business purposes. We may also offer certain Services features that allow you to share your location tracking Usage Information with the people you choose.

We may use a variety of methods to collect your Usage Information, including without limitation, any of the following:

Cookies. A cookie is a data file placed on your computer or mobile device when it is used to access the GoSedan Platform or Services. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences, and tracking your visits to our websites. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. Cookies can be disabled or controlled by setting a preference within your web browser or on your device. Keep in mind however, that if you choose to disable cookies, some features and areas of the GoSedan Platform and/or Services may not function properly or may otherwise be unavailable for your use.

Web Beacons. Web beacons, or clear GIFS, are small graphic images or other web programming code may be included in our web and mobile pages and messages. 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. Web beacons are embedded invisibly on web pages and help us better manage content on the GoSedan Platform by, for example, informing us what content is effective, count Users of the Services, monitor how Users navigate the Services, and informing us how many e-mails that we send were actually opened.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the GoSedan Platform and Services, such as the links you click on, and what kind of device or browser you view a web page. These scripts may be provided to us by our third-party service providers for tools such as Google Analytics. Script code is temporarily downloaded onto your device and is active only while you are connected to the GoSedan Platform or Services, and is deactivated or deleted thereafter.

NON-PERSONAL DEMOGRAPHIC INFORMATION

We may also collect “Demographic Information” about you that is not Personal Information, such as browsing and search history information, and any voluntarily submitted information that you choose to share with us, including without limitation, your age, gender, home city or state.

MOBILE APP INFORMATION

If you access the Services through the GoSedan mobile application, you acknowledge and agree that we will collect and use technical data and information about your device and application software. The mobile application may collect and store some or all of the following information, which includes Personal Information, Usage Information, and Demographic Information, including without limitation, your preferred language, phone number or unique device identifier, IP address, manufacturer and model of your mobile device, mobile operating system, and geo-location.

HOW WE USE YOUR INFORMATION

GoSedan uses your information in order to provide you with the Services, and to improve and enhance your use of the GoSedan Platform and Services.

We use your Personal Information and Usage Information in order to communicate with you in response to requests or inquiries, notify you about changes to the GoSedan Platform or Services, provide the services you request, process transactions that you requested or agreed to receive, and to manage your account. For example, we will use your preferred method of communication in order to deliver alerts of an upcoming ride, provide notice of scheduled maintenance, or to provide confirmation of a transaction with another User.

We may also use your Personal Information and Usage Information to provide you with information about offers or promotional materials from us or our third party partners, to improve the GoSedan Platform and Services as it relates to your own experience with the Services and to deliver content that is relevant to you, and for other purposes disclosed when you provide your information to us.

We use our Users’ Usage Information in order to monitor which features of the GoSedan Platform or Services are used most, provide Users with information of how they use our Services, provide assistance and suggestions for obtaining services that are provided through the GoSedan Platform, and to help us improve Users’ experiences with the Services. We will also use information collected from our mobile application to serve you the correct updated versions of the application for troubleshooting and marketing purposes.

We may use Usage Information and Demographic Information to deliver “targeted” advertisements (“ads”) that may be of interest to you. GoSedan may allow third-party ad servers or ad networks to serve ads on the GoSedan Platform. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Service, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs, see above) to compile information about your browser’s or device’s visits and usage patterns on the Services, and to measure the effectiveness of their ads and to personalize the advertising content. GoSedan does not sell, rent, or share the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.

Please note that an advertiser may ask GoSedan to show an ad to a certain audience of Users (e.g., based on demographics or other interests). In that situation, GoSedan determines the target audience and GoSedan serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach. This Privacy Policy does not apply to, and we cannot control the activities of, third-party advertisers. Please consult the respective privacy policies of such advertisers or contact such advertisers for more information.

SHARING YOUR INFORMATION

We may share Users’ non-Personal Information, such as anonymized and aggregated Usage Information and/or Demographic Information, with third parties for industry analysis, demographic profiling, targeted advertising, location-based advertising, or for other business purposes. We will not sell, share, rent, or trade your information, including your Personal Information, other than as set forth in this Privacy Policy or at the time you provide any of your information. We will not share your Personal Information with any third party for their own purposes unless you consent to such sharing at the time you provide your Personal Information.

Driver information may be shared without the drivers consent to government agencies who request/require it. The California Public Utilities Commission requires information collected about drivers to be provided to the commission in order to operate under the TNC license type.

PARTIES PROVIDING SERVICES

We may share your information with our third-party companies and individuals, including other Users such as drivers and the companies they work for, and hotel lodging providers, for the purpose of providing the Services to you. Other third-party providers host the GoSedan Platform, track the Services’ analytics, provide geo-location information for User, manage merchant services, and perform technical services. We may provide these vendors with access to your information, including your Personal Information, provided however that those business partners will be given such limited access to your information as is reasonably necessary to deliver the Services you request or agree to receive, and we will require that such third parties comply with this Privacy Policy.

If you are a driver or passenger in a ride, we will share your Personal Information with the other party to help identify you, contact you, facilitate payment, and help locate you.

INFORMATION SHARED ON THE GoSedan PLATFORM

You may also share your information as Your Content with third-parties when you post it to the GoSedan Platform. Keep in mind that any of Your Content that you make public through the GoSedan Platform is viewable and may be searchable by other Users, and that you are solely responsible for Your Content.

ADMINISTRATIVE AND LEGAL

We may also disclose your information, including Personal Information, when we reasonably determine that such disclosure is necessary to comply with applicable law and reasonable requests from with law enforcement, to enforce the terms of the Agreement, and/or to protect the interests or safety of GoSedan or other Participants in the GoSedan Platform.

GoSedan BUSINESS TRANSACTIONS

We may share your information, including your Personal Information, with our parent, subsidiaries and affiliates for internal reasons, subject at all times however to the terms of this Privacy Policy. We also reserve the right to disclose and transfer all such information to a subsequent owner, co-owner or operator of the GoSedan Platform and Services or applicable database, or in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.

VOLUNTARILY SHARED PERSONAL INFORMATION

From time to time, you may be presented with opportunities to receive information and/or marketing offers from third parties. If you agree to have your Personal Information shared, your Personal Information will be disclosed to those third parties, and all information you choose to disclose will be subject to the privacy policy and practices of those third parties. We are not responsible for the policies and practices of third parties, and we advise you to carefully review their privacy policies and practices before agreeing to disclose your information to them. You will need to contact those third parties to instruct them directly regarding your preferences for their use of your Personal Information.

STORING AND PROTECTING YOUR INFORMATION

Be aware that the information that we collect, including Personal Information, will be transferred to, stored and processed in the United States and/or any other country in which GoSedan or its parent, subsidiaries and affiliates maintain facilities. The data protection laws in the United States and these other countries may differ from those in any jurisdiction in which you are located. By using the Services, you consent to the transfer, storage, and processing of your information in the United States and/or any other country in which GoSedan or its parent, subsidiaries and affiliates maintain facilities.

We care about the security of your information, and we and our third-party business partners use commercially reasonable safeguards to preserve the integrity and security of all information collected and hosted on the GoSedan Platform. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications with us. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the GoSedan Platform may not be accessed, disclosed, altered, or destroyed. Your information and privacy settings may also be affected by changes to the functionality of third party sites and services that you use in conjunction with the GoSedan Platform and Services, such as social networks. GoSedan is not responsible for the functionality or security measures of any third party.

YOUR CHOICES ABOUT YOUR INFORMATION

CONTROLLING AND EDITING YOUR INFORMATION

You can control your account information and settings, including your email preferences, at any time by logging into your account, and selecting the account tab from a dropdown menu. The account menu will allow you to modify your personal information, password, add/remove credit card information, and enter promo codes. Keep in mind that you may not opt-out of receiving certain service-related communications, such as purchase and billing confirmations, or important notices relating to the Terms of Service.

OPTING OUT OF INFORMATION COLLECTION

By using the GoSedan Platform and Services, you consent to our use of your information for targeted, or behavioral, advertising purposes. If you would like to opt-out of any targeted advertising from us that occurs when visiting our third-party advertising partners, please refer to your mobile device or browser’s technical information for instructions on deleting or disabling cookies and other tracking and recording tools. Depending on your device or browser, it may be impossible to delete or disable tracking mechanisms. Please keep in mind that by deleting or disabling such tracking mechanisms, some features or functionalities of the GoSedan Platform or Services may no longer be available to you. Also, if you opt out, you may still continue to receive ads through the GoSedan Platform, however, these ads may not be relevant to your interests.

If you would like to opt-out of targeted advertising from our third-party advertising partners belonging to the Network Advertising Initiative, please click here to access the NAI Opt-Out page.

INFORMATION RETENTION

We retain your information for as long as your account and use of the GoSedan Platform and Services is active and need to provide the Services. Notwithstanding any termination of your account, we will retain your information indefinitely as necessary to comply with any legal or regulatory obligations, resolve disputes, conclude any activities relating to your account, investigate fraud or other similar activity, to enforce the terms of the Agreement, or for any other legitimate business reason.

GoSedan will use all commercially reasonable best-efforts to delete any User’s information upon written request. If you would like to change or update any of your Personal Information, please contact us at info@opoli.com.

NO INFORMATION FROM CHILDREN

GoSedan does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. The GoSedan Platform and Services, and the content therein, are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible.

THIRD PARTY SITES AND POLICIES

The GoSedan Platform Services may contain content that is supplied by a third party, and those third parties may collect web site usage information when web pages from any online or mobile Services are served to you. In addition, when you are using the GoSedan Platform, 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, the click may take you away from one of our websites 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.

CHANGES TO OUR PRIVACY POLICY

GoSedan may modify or update this privacy policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner we will provide Users with notice on the GoSedan Platform.

CONTACT GoSedan

If you have any questions or concerns about this privacy policy, our collection practices, or our use of your information in performance of the Services, please contact us at info@opoli.com.