Posted December 19th 2019
TrafficCast Mobile App for Commuters
Effective December 19, 2019
COLLECTION OF INFORMATION
USE AND DISCLOSURE
CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS
USER ACCESS AND CONTROL
OTHER IMPORTANT INFORMATION
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.
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.
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.
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 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 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.
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 firstname.lastname@example.org. 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:
|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.
|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 email@example.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 firstname.lastname@example.org. 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 email@example.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 firstname.lastname@example.org.
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.
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.
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).
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.
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.
TrafficCast International, Inc.
1800 Deming Way, Suite 100
Middleton, WI 53562
Legal Department, - Att: Privacy
email@example.com Please note "Privacy" in the Subject Line.