Your privacy is important to us. This privacy policy (the “Policy”) describes how Co-moving Carpool Ltd (the “Company”, "us" or "we" or "our") collects and uses information from the website www.co-moving.com (the “Site”) and the "CountMein" (the "App") (together known as the "Platform"). This Policy does not apply to any of our other services unless stated otherwise.
By accessing and using the Platform and its' services, you agree to be bound by this Privacy Policy. If you do not agree to any of the provisions as set hereunder in this Privacy Policy, please do not use the Platform or any of its services.
This Policy should be read together with the Terms of Use ("TOU") which also apply to the Platform.
This Policy does not apply to other websites that post different statements, regardless of whether or not the Site links to them or not.
1. NO USERS UNDER 18.
You must be 18 years old or older to use the Platform. If you are under 18, please refrain from using the Platform and/or from providing us with any information. We do not knowingly collect information from users under the age of 18. If we become aware that we have collected personal information from a child under the age of 18 years old, we will use reasonable efforts to delete such information.
2. WHAT INFORMATION DO WE COLLECT
We collect the following information so that we can provide you with our service:
2.1. Information You Give Us. We collect your full name, phone number, email address, phone number, username, gender, geolocation (when you activate the service), age, vehicle license plate / registration number (if you register as a driver), your preferred driving route (when you activate the service), method of getting to work (bus, private vehicle etc.), city of residence, as well as other information you directly give us on our Platform (for example, information that you send to us, including, but not limited to, through the contact form or when you connect and/or interact with the Platform through other third party services or platforms, such as Facebook and Google - if your account settings on those platforms allow this).
2.2. Information We Get from Others. We may get information about you from other sources, for example, your employer (if you use the Platform through your employers carpool program), other users on the Platform (when they share a ride with you, and if you activate the service), or social platforms (such as Facebook), with which you connect to the Platform (if this applies to you and if your account settings on those platforms allow this).
2.3. Anonymous Information Automatically Collected. We automatically log anonymous information about you and the device (computer, mobile phone etc.) you use when using the Platform in order to improve our services and your experience. For example, when visiting our Platform, we log your device's operating system, browser type, browser language, and other general statistical information.
2.4. Cookies. We log information using "cookies." Cookies are small data files stored on your device. We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience on our Platform, for example, cookies help store your username when you login so that you don't have to insert this information repeatedly.
You can remove or block cookies from the Platform through your browser settings. You can also block cookies on most mobile devices under "settings". Please note that if you remove or reject our cookies, it could affect how our Platform works for you and/or prevent you from being able to access/use certain features.
This Privacy Policy does not cover the use of cookies by third parties, advertisers and/or partners on our Platform.
2. USE OF PERSONAL INFORMATION.
We use your personal information to provide you with the services on our Platform and to improve your experience on our platform. Additionally, we may use your information to:
• Operate, maintain and improve our Platform;
• Provide and deliver products and services that you may request;
• Send you information including confirmations, invoices, updates, security alerts, and support and administrative messages;
• Respond to comments and/or questions and to assist you with any technical support, log your activity and contact you;
• Protect, investigate and deter against fraudulent, unauthorized or illegal activity;
• To protect you and/or other users and prevent any use of the Platform which is unlawful or against our TOU.
• To resolve disputes and troubleshoot problems, and:
• Send you marketing emails if you agreed to these when signing up (you may ask to be unsubscribed at any time).
4. SHARING OF YOUR INFORMATION
We may share your personally identifiable information as follows:
• Your full name, vehicle registration number and driving route (when you activate the service) with your employer, if you use the service as part of your employers carpool program.
• With other users who ride with you.
• With third party service providers in order to provide you with specific services and/or features, for example, but not limited to:
o Twillio - we will share your phone number to enable the sending of operational texts messages.
o SendGrid - we will share your username and email address in order to send you operational emails.
These third parties are subject to their own privacy policies, in addition to this Policy.
• When we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
• For legal, protection, and safety purposes, for example:
o To comply with laws.
o To lawful requests and legal processes.
o To protect the rights and property of the Company, its agents, customers, and others. This includes enforcing our agreements, policies, and TOU.
o In an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
We may share your non-personally identifiable information as follows
• General aggregated and/or anonymized data (this information does not personally identify you) with third parties in order to improve the service, for their own uses, and/or to provide you with specific services and/or features. These third parties include, but are not limited to Mixpanel and/or Google Analytics.
These third parties are subject to their own privacy policies, in addition to this Policy.
5. INTERNATIONAL USERS
Our main office is in the state of Israel. If you use the Site outside of Israel, please note that your information will be saved, stored and processed in Israeli databases and will be governed by Israeli law. By using the Site you give your consent to the above and to any provisions under applicable data storage and usage laws in Israel.
6. INTERNATIONAL TRANSFER OF INFORMATION
Due to the fact that some of the services are provided by third parties located in various locations worldwide, and the fact that some of the information is saved, stored and processed on servers in the cloud, your information may be transferred to, and stored on, computers located at these other countries - outside of your country or legal jurisdiction (the "Transfer"). Additionally, the privacy laws of these countries may differ from those in your jurisdiction. By using our services and/or providing us with your personal information, you are giving us your consent to this Transfer.
7. SOCIAL SHARING FEATURES
Our services may integrate with third party social applications and/or services such as Facebook, Instagram, Twitter etc. (the "Social Apps"). These Social Apps let you share information and actions that you take on our Platform, on the Social Apps. For example, an action you take on our Platform may be published on Facebook if your account has been set-up this way. Please check your privacy settings in your profile on the Platform (as is applicable), and the settings and privacy policies of the relevant Social Apps for more information about how they handle the data you share through them.
8. PROTECTION OF INFORMATION
Your personal information is protected in several industry standard accepted ways, including firewalls, 2 tier password protection (and hash of all passwords) and access tokens. Additionally, access to your account and personal information (when relevant) is only available through a password and unique username/user ID selected by you. Additionally, your personal information is stored on secured servers of approved third party service providers, and only selected personnel have access to.
By creating an account, you agree to keep your password and user name in strict confidence and not disclose such information to any third party. Should you feel that your password or account has been compromised, please let us know immediately.
Although we use industry standard security measures to protect your personal information so that it is not made available to unauthorized parties, we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure and any information you provide is your sole responsibility and subject to this Policy and our TOU.
9. USERS' RIGHTS IN RESPECT OF THEIR PERSONAL INFORMATION
9.1 In accordance with the applicable privacy law, you have the following rights in respect to your personal information (if and when applicable). In the event that you are using the services through your employer, you will need to contact your employer to exercise the right.
• Right of access. You have the right to receive:
o confirmation of whether, and where, we are processing your personal information;
o information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
o information about the categories of recipients with whom we may share your personal information; and
o a copy of your personal information which we hold.
• Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another party.
• Right of rectification. You have the right to request that any inaccurate or incomplete personal information about you be rectified.
• Right to erasure. You have the right, in some circumstances, to request that we erase your personal information if the continued processing of that personal information is not justified.
• Right of restriction. You have the right, in some circumstances, to request that we limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
• Right to object. You have a right to object to any processing of your personal information where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. For the removal of doubt, you can object to marketing activities that apply to you specifically, for any reason.
9.2 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. If you are using our services through your employer, please contact your employer directly.
9.3 When applicable, you may also review and edit parts of your personal information by logging into your account on the Platform.
10. COMMUNICATIONS AND PROMOTIONS.
If you agreed to this when you signed up and/or registered to our services, you may receive emails with promotional content, related directly or indirectly to our services, including, for example, service suggestions and other news about products and services offered by us and our selected partners. You can opt-out of these communications at any time using the 'unsubscribe' option included in the messages, or by contacting us by email, after which we will no longer send you promotional emails. We may still send you non-commercial emails which are necessary in order to provide you with the services.
11. CHANGES TO THIS PRIVACY POLICY.
This Policy may be changed occasionally. If we make any substantial changes, we may notify you by sending you an e-mail to the last e-mail address you provided, and/or by posting notice of the changes on our Platform. Any changes will be effective upon the earlier of ten (10) calendar days following our email, or ten (10) calendar days following our posting of the notice on our Platform. These changes will be effective immediately for new users of our Platform. Continued use of our Platform following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.
12. ABUSE OF PRIVACY AND CONTACT INFORMATION.
We take your privacy seriously. If you have any concerns, please let us know. We welcome your comments and questions. You may contact us at: bp@co-moving.com
Last Updated: July 2020
ATTORNEY ASSAF BEN-DAVID © 2020
