Privacy Policy

SimpleCar Inc., a Delaware corporation (also referred to as “we,” “us,” “our” or “SimpleCar”) respects your privacy.  This privacy notice is meant to help you understand how we collect, use, disclose, and otherwise process your personal information in connection with your use of SimpleCar.com, and our related mobile sites and applications (our “Sites”), as well as when you join our SimpleCar Vehicle Subscription Program or use our services (collectively, our “Services”).

If you have any questions or concerns regarding our Privacy Notice, please contact us in one of the ways provided below.  Terms not defined in this privacy notice have the meaning defined in your Vehicle Subscription Agreement, which you can view when you log in to your SimpleCar account (if one has been established), and the Terms of Use.

NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

Privacy Notice for California Residents can be found here. 

California Residents “Do Not Sell My Info” Notice can be found here.

INFORMATION WE COLLECT AND HOW WE USE IT

SimpleCar collects personal and financial information from you when you visit our Site.  The principal purposes for which we collect and store your personal and financial information are to process your application, allow you to subscribe to our Services and use our vehicles, authorize payment, bill you, respond to your inquiries, improve and communicate with you about our products and services and maintain your account with us.  We only require information for legal or security purposes or to better serve your needs.  Please note you may have a choice to provide or not provide additional information during subsequent visit to our Sites, but keep in mind that some of this information will be required if you wish to use our Site and Services.  

Information You Voluntarily Provide:  We may collect information that you voluntarily submit to us, which may include, but is not limited to your name, email address, postal address, telephone number, or a picture of you or identifying documents.  This also includes information in your profile, or information you provide to us via an email, text or similar message, telephone call, or by other means.  Your telephone calls and other communications may be recorded or monitored for quality control, training and similar purposes.  By using these communication methods, you are consenting to receiving information via these methods and the recording or monitoring of your calls and communications with SimpleCar.  We use this information to create your account, provide our services and communicate with you.  From time to time, we may send marketing or other communications.  To edit your preferences, please go to your account settings page, once an account has been established for you.  

Application Process: If you apply to join SimpleCar, we collect information such as personal and financial information as you proceed through the stages of our application process, membership agreement and reservation process.  In addition to your name and contact information, we will also collect your driver’s license number and the jurisdiction in which you are licensed, credit card or other payment information, a photo, and other identifying information.  In certain cases, such as if you have a non-U.S. driver’s license, we may also collect your passport information.  We may also collect information about you such as your driving record from you, from regulatory bodies where you live, or from other third party sources.  We use this information to process your application, determine your eligibility to use our services, to verify your identity, to detect and deter fraud, theft, or abuse of our service, comply with legal and recordkeeping requirements, process your payments and other purposes.

If you join SimpleCar, we also gather information about how you use our Sites and Services, such as your searches for vehicles, reservations (dates, times, locations, etc.).  We may also collect precise location if you enable location-based services on your mobile device.  We use this information to provide and optimize services for you, including for example, billing you, responding to your inquiries, providing and improving our products and services, maintaining your account with us, personalizing your SimpleCar experience (e.g., by understanding your preferences), and providing personalized content and promotional offers. To learn more about how SimpleCar customizes content and offers please see “Advertising and Personalized Content” below.

GPS Vehicle Tracking and Dash Webcam:  Simplecar vehicles may be equipped with vehicle tracking and anti-theft technology that uses Global Positioning System (GPS).  GPS is a network of satellites that allows us to determine the location (latitude and longitude) of Simplecar vehicles during your reservation.  Additionally, Simplecar vehicles may also have an on-board device that may monitor the state of the vehicle from moment to moment whether or not in a reservation, and the information may include its location and driver behavior monitoring such as crash detection factors or rate of braking or acceleration.  This information is transmitted to Simplecar and stored.  Simplecar uses this information for a variety of important purposes.  For example, we may monitor or store vehicle or GPS data to help you find a car you have reserved, to assist with roadside assistance, to assist in making a car available at the place and time you have reserved, to improve our service, to assist us in enforcing our legal rights, or to locate lost or stolen Simplecar vehicles.

INFORMATION AUTOMATICALLY COLLECTED WHEN YOU USE OUR SITES 

When you visit our Sites or use our Services, read our emails, or otherwise engage with us through a computer or mobile device, we and our third party partners automatically collect information about how you access and use the Sites and information about the device you use.  We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”) and we may use third party services or technologies to collect this information.  Information we may collect automatically about you may be combined with other personal information we collect directly from you or from other sources.

When you use our Sites, our servers automatically log certain information about your use of our Sites, such as your IP address, your browser type, operating system, browser language and service provider.  We also collect information about your activities on our Sites, such as the pages you visit or the ads or links you click on.  We use this for a number of purposes, where we have a legitimate interest to do so, such as: improving our services, developing new services based on what we learn from your activity; identifying products and marketing that may be of interest to you; personalizing our service to you; and carrying out statistical analysis and research with the purpose of allowing us to better understand our members and the products / services they want.  We also use this information to provide and adapt our services to take account of the technical capabilities of our users as well as identify issues with the website and user’s experience of it.

IP Addresses and other information collected automatically:  We may collect your IP address when you visit our websites to help us diagnose problems with our systems, for system administration, to report aggregated information to our business partners, and to audit the use of our website.  In select circumstances, we may use IP addresses to help us identify you to protect our service, site, users or others.  We also collect your browser type, Internet Service Provider (ISP), referring/exit pages, the pages viewed on our site, operating system, date/time stamp, and/ or clickstream data to analyze trends in the aggregate and administer the site.

Session Replay:  When you visit our website, we may also record information about your browsing session on the site, including which pages you visited and any forms on the website that you filled in.  We review this information to identify any technical issues in the operation of our sites and to improve the user interface on our sites.  If we use a third party to help us with this service, this information will be passed to that third party for this purpose.

Mobile Analytics:   When you download and use our apps, we may use mobile analytics software to help us better understand the functionality of our app on your mobile device. Our analytics may record how often you use the app, how you use the app, aggregated usage, performance data and where you downloaded the app from.

Mobile GPS and Push Notifications:  If you allow us, when you use our apps, we may collect location markers using the GPS in your device.  Knowing approximately where you are would help us send you push notifications or other communications based on your location. We may also use push notifications to provide certain services such as emergency or other service notifications, return notifications, providing information about vehicle location, providing details regarding our products and services etc.  We will only share this information with third party providers for the purpose of providing you these services.  To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.  If you change your mind about sharing your location or receiving push notifications from the app, adjust the settings of your mobile device to turn off transmission of geolocation data or to stop transmission of push notifications at any time.

We may also collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our services, to understand more about the demographics of our users and how users interact with our advertisements and Services. 

For more information about our use of cookies and other tracking technologies for advertising purposes, and to learn how you may control the use of your information for these purposes, please refer to the section called “advertising and personalized content” below.

CHILDREN’S PRIVACY

We do not knowingly solicit or collect individually identifying information from children under the age of 13. 

HOW WE SHARE YOUR INFORMATION

We may share your information with our service providers, affiliates, and other third parties in limited circumstances such as to provide our Services, fulfill a transaction you have requested, offer you personalized services, or in other circumstances that are permitted by law and consistent for the reasons specified above and in accordance with the Privacy Policy.  For example, we may disclose your personal information, including GPS information from any of our vehicles, within SimpleCar and to contractors, advisors, consultants and service providers acting on our behalf or under our instructions, including for purposes relating to the provision, operation, maintenance, administration, promotion, improvement, and oversight of our Services, Sites and advertising services, or to fulfill your requests for information or service.  If you apply for SimpleCar membership, some of the information you supply may be shared with regulatory bodies and/or service providers we utilize to obtain your driving record or other personal information.  Simplecar shares personal data with service providers in order to detect and prevent fraud, theft and abuse.

We may also share your personal information with our affiliate companies, including other companies owned or controlled by SimpleCar for business purposes, including internal management, administrative purposes, market research and marketing purposes as allowed by law.

Changes in Corporate Structure:  We may share your personal information in the event of a potential or actual merger, asset sale, financing, corporate divestiture, reorganization or acquisition involving our business, including any transfer made as part of insolvency or bankruptcy proceedings.  In the event that ownership of SimpleCar or its business was to change as a result of a merger, acquisition or transfer to another company, your personal information may be shared or transferred.

Finally, we may also disclose information about you as required or permitted by law, such as to comply with a subpoena, respond to inquiries from government authorities, or defend legal action.  

SECURITY 

To protect the confidentiality and security of your personal information transmitted to us, we maintain appropriate administrative, technical, and physical safeguards that comply with applicable industry.  Our Site is built upon a secure infrastructure with multiple layers of protection, and we use industry-standard encryption technologies to safeguard your information.  Please note, however, that no security system is impenetrable, and we cannot guarantee the security of our systems at all times.   It is your responsibility to choose a strong password and keep it confidential and safe.  If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps.  We may also post a notice on or through our Site in the event of a security breach.  Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

If you contact us by phone, we may ask you to verify certain information related to your account before providing any access to personal information.  We will retain your information as needed for the purposes of servicing your relationships with us, if any, and for internal analysis in compliance with applicable laws and regulations.

ADVERTISING AND PERSONALIZED CONTENT

Simplecar uses personal information to provide custom, personalized content and information and to inform our marketing and advertising efforts, which may include sending you marketing or advertising communications via email or online.  If you do not want us to send you promotional emails, please follow the instructions to unsubscribe in the footer of such emails.

Cookies:  Simplecar uses cookies, Flash objects and other tracking technologies that are placed in the browser on your computer or mobile device, and can be used to help recognize you on our Sites and improve the user experience.  Cookies are pieces of information that a website or mobile device application transfers to an individual’s devices or drives to track application and user activity.  Most web browsers automatically accept cookies and session IDs, but you may be able to disable cookies by making the appropriate selection from your browser options.  Please note, however, that by doing so, some areas of our Sites may not function well or at all. 

Additionally, we use data analytics tools like Google Analytics and other third-party technologies to understand how users interact with our advertisements and Services.  For more information, you can visit www.google.com/policies/privacy/partners/ (“How Google Uses Information From Sites Or Apps That Use Our Services”).  You may opt out of receiving certain advertising tailored to you from third parties.  If you would like to opt out of behavioral advertising or to learn more, please visit: http://www.aboutads.info/choices/ or https://policies.google.com/technologies/ads or http://optout.networkadvertising.org/?c=1#!%2F.   Options you select are browser and device specific.

Online Advertising and third-party ad networks:  SimpleCar may use third party ad network providers to serve you targeted advertisements based on your browsing history.  These providers use cookies or similar tracking technologies to collect information about your use of our Sites.  This information may include your browser type, Internet Service provider (ISP), your operating system, which of our web pages you access and how frequently you access them, referral or exit pages, click stream data, and the dates and times that you visit our Site.  We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.  The use of cookies, web beacons, or similar technologies by content and ad network providers is subject to their own privacy policies, not ours.

In addition, we may partner with third party companies that collect web viewing data from our Services as well as from other non-affiliated websites and mobile apps over time in order to infer your interests and to deliver more relevant advertising to your browser or device, as well as browsers and devices associated with you.  This type of advertising is known as interest-based advertising.  To learn more about interest-based advertising and how you may be able to opt-out of some interest-based advertising, you may wish to visit the Network Advertising Initiative's online resources, at http://www.networkadvertising.org/choices and/or the Digital Advertising Alliance's resources at www.aboutads.info/ choices. 

We may also use advertising platforms provided by Facebook, Twitter and other social media sites to promote interest-based advertisements to you (or to not show you certain advertisements) and to measure how users interact with those advertisements.  We may do this using web tracking tools or by sharing certain information (such as hashed email lists) with these platforms for this purpose.

These advertisements are governed by the privacy policies of those social media companies that provide them.  If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.  You may learn more about advertising preferences by clicking on the following links. To learn more about Facebook’s advertising privacy policies and how to opt out, visit
https://www.facebook.com/about/privacy/. To learn more about Twitter tailored ads, visit https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads. We may also use similar advertising programs for other social media sites you use.  Please note that these links are provided for your convenience only and we do not control the content or features that may be available on these third party services.


THIRD PARTY LINKS

Our Sites and Services may include links to third party sites or social media applications like Twitter, Snapchat, Instagram, or Facebook.  If you follow any links that direct you away from our Site, this privacy policy will not apply to your activity on the other websites you visit.  

We are not responsible for any personal information practices of third party websites and online services or the practices of other third parties.  We encourage you to carefully read the privacy policy of any website you visit or mobile application that you use.

YOUR RIGHTS AND CHOICES

If you join our Services, we will use and share financial information we collect from or about you in accordance with our Privacy Notice, found here.  California residents can view the California-specific opt-out notice here.  These notices supplement this Privacy Policy by offering you certain choices with respect to the use and sharing of your financial personal information.

In addition, you may visit our Privacy Hub to learn how to access or delete your personal information and exercise certain other data rights you may have with regard to your personal information.

DO NOT TRACK

At this time, our Site does not respond to Do Not Track signals.  

CHANGES TO THIS PRIVACY POLICY

As permitted by law, we may change, modify, or adjust our Privacy Policy from time to time, so it is advisable to review it frequently.  We will advise you of material changes to this privacy notice through our website or other means, and all amended terms shall automatically be effective as of the date of the amended notice.  When we make changes to this privacy notice, we will change the “last updated” date at the beginning of this privacy notice.  Your continued use of the Simplecar service or maintenance of a Simplecar account following the effective date will be deemed to be acceptance to any changes to this privacy notice. 

CONTACT INFORMATION

If you have questions about this Privacy Policy or our privacy practices, please email us at hello@simplecar.com.

Last Update: July 25, 2021