TrafficCARMA Privacy Policy

Posted December 19th 2019

TrafficCast Mobile App for Commuters

Privacy Policy

 

Effective December 19, 2019

 

Sections:

  • INTRODUCTION

  • COLLECTION OF INFORMATION

  • USE AND DISCLOSURE

  • CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS

  • SECURITY

  • USER ACCESS AND CONTROL

  • OTHER IMPORTANT INFORMATION

  • CONTACT US

 

  1. INTRODUCTION

 

TrafficCast International, Inc. ("TrafficCast") operates and manages a mobile application ("The App") and associated website which provides traffic and travel information focused on the needs of daily commuters. While The App may be promoted by, associated with, or co-branded through independent media affiliates and partners, TrafficCast controls the app itself. In this statement of our Privacy Policy, the terms "we," "us," and "our" refer to TrafficCast; "you" refers to you, as a user of the mobile application, The App.

 

As you may use The App to inform your daily commute, and may register certain types of information about yourself in order to optimize the application's benefits, TrafficCast wants you to be familiar with how we collect, use and disclose information from and about you, and to assist you in making informed decisions about using the app. This Privacy Policy describes our practices in connection with information collected through The App; by using it, you agree to the terms and conditions of this Privacy Policy. (Please note that media affiliates and partners may have Privacy Policies relevant to their own applications and websites. Those policies may align with this one, but if there is a conflict in your use of The App, this Policy applies.)

 

As set forth in our Terms of Service, The App is intended for a general audience of licensed driver age. It is not targeted to children, and TrafficCast does not knowingly collect personal information from children under 13 years of age.

 

This Privacy Policy applies to all users, including both those who use The App without being registered with or subscribing to the app, as well as those who have registered with or subscribed to The App. This Privacy Policy applies to TrafficCast's collection and use of your personal information (i.e., information that identifies a specific person, such as full name or email address) as a registered user. It also describes generally TrafficCasts's practices for handling non-personal information (for example, interests, demographics and services usage), or anonymous data that may be associated with your use of The App as either a registered or unregistered user.

 

  1. COLLECTION OF INFORMATION

TrafficCast may collect the following information from and about you:

 

Registration Information is the information you submit to register for The App, for example, to create an account, save routes, post traffic reports, receive a newsletter, or enter a contest or sweepstakes. Registration Information may include, for example, name, username, email address, gender, zip code, saved places, and routes.

 

Public Information and Posts consist of comments or content that you post to The App. Typically, such content will be reports you may make regarding observed road conditions, accidents and other traffic-impacting incidents. Information about you that accompanies this content may include a user name, location of report, "likes", and media that you may associate with the report which may include audio, video or still images. Your real name or username would be posted in such reports only if you provide it. Public Information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.

 

Information from Social Media. If you elect to access or log-in to The App through a social media service, or connect The App to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access The App through social media services or when you connect The App to social media services, you are authorizing TrafficCast to collect, store, and use such information and content in accordance with this Privacy Policy.

 

Activity Information. When you access and interact with The App, TrafficCast, and its affiliates, may collect certain information about those interactions. For example, in order to permit your connection to The App, our servers may receive and record a unique device identifier assigned to your device, geolocation data (including, your precise location) or other transactional information for that device including (potentially) an IP address, browser type, and other, software or hardware information. 

 

Cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology including cookies) are comprised of small bits of data that often include a de-identified or anonymous unique identifier. Websites, apps and other services may send this data to your browser or device when you first request a web page and then store the data on your computer or other device so the website or app can access information when you make subsequent requests for pages from that service. These technologies may also be used to collect and store information about your usage of the The App, such as pages you have visited, routes you save or edit, other content you have viewed on the application, search queries you have run and advertisements you have seen or heard.

 

Third parties that support TrafficCast and The App by serving advertisements or providing services, such as allowing you to share content or tracking aggregate usage statistics, may also use these technologies to collect similar information when you use The App or third-party services. TrafficCast does not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies. For more information about third-party advertising networks and similar entities that use these technologies, including your choices with respect to them, see the section entitled "To deliver relevant advertisements" below.

 

Most browsers and apps are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser or "Settings" on your device for more information. You can also find general information about use and value of cookies through a search on the Intenet. Please note that by blocking any or all cookies, you may not have access to certain features, content or personalization available through The App.

 

Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from TrafficCast Affiliates or business partners.

 

Do Not Track Signals.  Considering that the principal value users derive from The App is relative to their location, at this time we do not respond to browser 'Do Not Track' signals.

 

  1. USE AND DISCLOSURE

 

We use the information we collect from and about you to provide The App's services and features to you, including: to measure and improve The App services and features; to improve your experience with both online and off-line App Services by delivering content you will find relevant and interesting, including travel times, route advisories and personalized traffic information, as well as advertising and marketing messages; to allow you to comment on content, to report on traffic impacting events you may observe, and to participate in games, contests, or rewards programs that may be associated with The App; to provide you with customer support and to respond to inquiries.

 

In order to provide you with content and advertising that is more interesting and relevant to you, we may use the information from and about you to make inferences and predictions about your potential areas of interest. When the information collected from or about you does not identify you as a specific person, we may use that information for any purpose or share it with third parties.

 

We may also use the information we collect from and about you for these additional purposes:

 

To allow service providers to assist us in providing and managing The App Services. The information we collect from and about you may be made available to certain third party service providers, such as contractors, analytics and other measurement companies, agents, or sponsors, who help us analyze and understand your use, along with all other users, of The App, and manage and/or provide The App.

 

To allow social sharing functionality. If you log in with or connect a social media service account with The App, we may share your user name, picture, and likes, as well as your activities and comments with other users of The App Services users and with your friends associated with your social media service. We may also share the same information with the social media service provider. By logging in with or connecting The App account with a social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users and your friends, and you understand that the social media service's use of the shared information will be governed by the social media service's privacy policy. If you do not want your personal information shared in this way, please do not connect your social media service account with The App account you may establish, and do not participate in social sharing on The App.

 

To provide co-branded services and features. We may offer co-branded services or features, such as contests, sweepstakes or other promotions together with a third party ("Co-Branded Services"). These Co-Branded Services may be hosted on TrafficCast technology platforms or on the third party's service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party's use of your information will be governed by the third party's privacy policy.

 

To deliver relevant advertisements. TrafficCast and our service providers may use the information we collect from and about you to deliver relevant ads to you when you use The App or another service, including, without limitation, precise geolocation data accessed or collected pursuant to this privacy policy. For mobile applications, you may be able to opt-out of the use of precise data for location-based tracking by using the settings available on your mobile device; however, opting-out may impair or disable The App, or limit its relevance to your commute. For The App, ads may be selected for you based on more general information, such as location that can be inferred from IP addresses.

 

As noted above, third-party advertising networks and advertisers may use cookies, mobile advertising identifiers and similar technologies to collect and track information such as demographic information, inferred interests, web browsing and app usage, and aggregated information and activity to assist them in delivering advertising that is more relevant to your interests. To find out more about third-party advertising networks and similar entities that use these technologies, see http://www.aboutads.info. If you would like to opt-out of such advertising networks' and services' advertising practices, go to http://www.aboutads.info/choices to opt-out in desktop and mobile web browsers. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt-out in mobile apps. Note that opting out may compromise the ability of The App deliver travel- and commute-related content personalized for your route(s).

 

To contact you. TrafficCast may periodically send promotional materials or notifications related to The App. If you want to stop receiving promotional materials, you can follow the unsubscribe instructions at the bottom of each email. There are certain service notification emails that you may not opt-out of, such as notifications of changes to The App services or policies. If you wish to stop receiving push notifications through The App itself, or otherwise alter its content delivery to you, you can adjust settings either on your mobile device or through The App.

 

To share with The App Media Partners and Affiliates. TrafficCast may share your information with The App Media Partners and Affiliates for the purposes described in this Privacy Policy. Users who visit websites and mobile apps of these Media Partners and Affiliates, which may be linked directly to The App, should recognize that their privacy policies are separate from TrafficCast's and may differ in some respects from this Privacy Policy. When that is the case, use of The App is governed by this Privacy Policy.

 

To share with business partners. TrafficCast may share your information with business partners to permit them to send you information content that is relevant and marketing communications that is consistent with your choices.

 

To protect the rights of TrafficCast and others. There may be instances when TrafficCast may disclose your information, including situations where TrafficCast has a good faith belief that such use or disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of TrafficCast, our Media Partners and Affiliates, or the employees, agents and contractors thereof (including enforcement of our agreements and our terms of service); (ii) protect the safety, privacy, and security of users of the The App or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.

 

To complete a merger or sale of assets. If TrafficCast sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business (including in connection with a bankruptcy or similar proceedings), TrafficCast may transfer your information to the party or parties involved in the transaction as part of that transaction.

 

To improve The App Services and customize the user experience. We also aggregate non-personal information in order to track trends and analyze use patterns of the app, including geolocation and prevailing road speed information. This Privacy Policy does not limit in any way our use or disclosure of non-personal information, and we reserve the right to use and disclose such non-personal information to our Media Partners and Affiliates, advertisers and other third parties at our discretion.

4. California Residents: Your California Consumer Privacy Act (CCPA) Rights

Under California law, our customers who are California residents may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. As detailed above, we do not share our customer's personal information with unaffiliated third parties for direct marketing purposes without their approval.

If at any time you wish to opt out of having your personal information shared with third parties and/or receiving information from TrafficCarma/TrafficCast via e-mail about new products, services, or promotions, you can do so. You may contact us at TrafficCarma Customer Support, Attn: Privacy Office, 1800 Deming Way, Suite 100, Middleton, WI 53562. You can also contact us by e-mailing us at privacy@trafficcast.com. Please indicate what publications or services you no longer wish to receive so that we may better address your needs. You can also log in and adjust your privacy settings via the mobile app or via the web at https://my.trafficcarma.com/privacy

Information We Collect

Our website and mobile app collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, our website and mobile app has collected the following categories of personal information from its consumers within the last twelve (12) months:

Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). NO
 
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase.

  • Indirectly from you. For example, from observing your actions on our website.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose [or sell your personal information, subject to your right to opt-out of those sales (see Exercising your Rights)]. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. [The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.] Refer to the section of the privacy policies under "COLLECTION OF INFORMATION" and "USE AND DISCLOSURE" to fully understand how this data is shared with our partners and 3^rd^ parties.

We share your personal information with the following categories of third parties:

Advertising Platforms (Google Ad Manager)

Digital Marketing (Airship, HubSpot)

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose, other than the uses in the "Sharing Personal Information" section above.

Sales of Personal Information

In the preceding twelve (12) months, Company had not sold personal information.

California Privacy Rights for Minors

California residents under the age of 18 have the right to remove, or request the removal of, content or information they have posted. This request can be made by contacting us at TrafficCarma Customer Support, Attn: Privacy Office, 1800 Deming Way, Suite 100, Middleton, WI 53562. We can also be reached via e-mail at privacy@trafficcast.com. Please again be advised that any information submitted along with Traffic Incident Reports is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive information at any time.

Please note that residual copies of content and/or information that have been deleted may remain on our backup servers. We are not required to remove posted content or information if it has been rendered anonymous or if we are required by law to retain it. Additionally, we do not have control over third parties (e.g., other users) who may have copied or reposted the content or information.

What do you do if you want to correct or delete your personal information?

If for any reason you are concerned with the way we are using your personal information, or would like to correct or request that we delete such personal information, please contact TrafficCarma Customer Support, Attn: Privacy Office, 1800 Deming Way, Suite 100, Middleton, WI 53562. We can also be reached via e-mail at privacy@trafficcast.com. We will respond to any request for access within 30 days. In some cases, we may not be able to delete your personal information and will retain and use our information as long as necessary to comply with our legal obligations, resolve disputes, and/or enforce our agreements. Please note that the deletion of your data will lead to the termination of your account and all applicable services.

Exercising your Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us:

  • Send a letter to: Privacy Office, 1800 Deming Way, Suite 100, Middleton, WI 53562.

  • Send an e-mail to privacy@trafficcast.com

  • Visit our online privacy tool at https://my.trafficcarma.com/privacy

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we've collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact TrafficCarma Customer Support, Attn: Privacy Office, 1800 Deming Way, Suite 100, Middleton, WI 53562. We can also be reached via e-mail at privacy@trafficcast.com.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  1. SECURITY

TrafficCast uses commercially reasonable administrative, technical, personnel and physical measures that meet industry standards in order to safeguard information in its possession against loss, theft and unauthorized use, disclosure or modification. However, no one can guarantee the complete safety of your information.

 

  1. USER ACCESS AND CONTROL

 

If you would like to access, review, correct, update, suppress, or otherwise limit our use of your personal information you have previously provided directly to us, you should first attempt adjustments through the edit functions and/or Settings page within The App. You may also contact us as outlined in section 8 below. If your request is via such contact, please identify The App service you are registered with, the Media Partner or Affiliate that may be associated with your registration, and the specific service or technology to which your request pertains (e.g., text alerts, personalized route advisories or email blasts). Please specify clearly what information you would like to access, change, update, or suppress.

 

If you are a California resident, you may also request that we not share your personal information on a going-forward basis with Media Partners, Affiliates or unaffiliated third parties for their direct marketing purposes by contacting us as outlined in section 8 below.   We will try to comply with your request(s) as soon as reasonably practicable. Note that such requests may compromise the ability of The App deliver travel- and commute-related content personalized for your route(s).

 

  1. OTHER IMPORTANT INFORMATION

 

Updates to Privacy Policy. TrafficCast may modify this Privacy Policy. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on The App.

 

Location of Data Management.  The App is hosted in and managed from within the United States.  Data may be collected, stored and processed through "Cloud Services" providers. If you are a user located outside the United States, you understand and consent to having any personal information processed in the United States. United States data protection and other relevant laws may not be the same as those in your jurisdiction. This includes the use of cookies and other tracking technologies as described above. As a result, please read this Privacy Policy with care.

 

Linked Services. The App may also be linked to sites operated by Media Partners and Affiliates, unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by companies not owned or controlled by TrafficCast, which is not responsible for the privacy practices of Media Partners, Affiliates and unaffiliated companies. Once you leave The App or click an advertisement you should check the applicable privacy policy of the other service.

 

In addition, TrafficCast is not responsible for the privacy or data security practices of other organizations, such as Facebook, Tumblr, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with The App.

 

Collection of Personal Financial Information by a Payment Service. In some cases, or in a future release of The App, we may use an unaffiliated payment service to allow you to purchase a product or make payments ("Payment Service"). If you wish to purchase a product or make a payment using a Payment Service, The App will direct you to a Payment Service page. Any information that you provide to a Payment Service will be subject to the applicable Payment Service's privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service's use of information collected through any Payment Service.

 

Data Retention. We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

 

Remember that even after you cancel your account, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services. Because of the nature of caching technology, your account may not be instantly inaccessible to others. We may also retain backup information related to your account on our servers for some time after cancelation for fraud detection or to comply with applicable law or our internal security policies. It is not always possible to completely remove or delete all of your information due to technical constraints, contractual, financial or legal requirements.

 

Sensitive Information. We ask that you not send us, and you not disclose, any sensitive personal information (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through The App or otherwise directly to us.

 

  1. CONTACT US

If you need to contact us about this Privacy Policy, please contact us at:

TrafficCast International, Inc.

1800 Deming Way, Suite 100

Middleton, WI 53562

Legal Department, - Att: Privacy

Or

privacy@trafficcast.com Please note "Privacy" in the Subject Line.

 

When contacting us, please identify The App service(s) you are registered with, the Media Partner or Affiliate that may be associated with your registration, and the specific service or technology to which your request pertains (e.g., text alerts, personalized route advisories or email blasts). Please specify clearly what information you would like to access, change, update, or suppress. Also, please note that communications not related to this Privacy Policy may not be acknowledged or responded to.

Contact

Have questions or concerns about TrafficCARMA, our Privacy Policy? Contact us at privacy@trafficcarma.com.