Effective Date: June 1, 2017
Last Updated Date: July 15, 2019
- use, and
- disclose information we obtain through the “Service.”
The “Service” means any website, mobile application, or Internet service under Via’s control, whether partial or otherwise, in connection with providing Via’s online platform that connects users with vehicle-sharing transportation providers in major cities. Each reservation a user makes with such vehicle-sharing transportation providers on the Service is a “Reservation,” and each ride taken through a Reservation is a “Ride.” “Member” means any such individual who uses the Service to make Reservations and take Rides. “Driver Partner” means any such independent contractor partner who registers with the Service as a third-party transportation provider to provide Rides to Members.
“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual.
THE SERVICE COLLECTS YOUR INFORMATION
We collect Personal Information when you:
- register to use the Service;
- use the Service; and
- communicate with us.
We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Service.
Two kinds of users may use the Service, Members and Driver Partners. We collect different types of information from these two types of users.
Personal Information Collection – Members. You must register to make a Reservation through the Service. To register, you may need to provide Personal Information, such as your name, phone number, email address, billing address, and credit card information. You may also provide other optional information.
Personal Information Collection – Driver Partners. To register as a Driver Partner, you may need to provide Personal Information such as your name, email address, phone number, date of birth, vehicle information, driver’s license information, insurance information, banking information and social security number (SSN) in the United States or National ID Number in the European Union. This type information is collected from Driver Partners to enable our compliance with local and state laws and regulatory requirements applicable to the Service, compliance with tax laws, and to process payments to Driver Partners. Information collected from Driver Partners may be shared with federal and state tax agencies or local regulators as required by law.
Using the Service. We collect information you post through the Service. For example, when you make a Reservation, the Service will collect the information you provide in such submissions, including any Personal Information. We will also store your transaction history.
Making Payments. When you make payments through the Service, you may need to provide Personal Information to our third-party service providers, such as your credit card number. We (or our service providers on our behalf) may store this information for your convenience.
Customer Support. We may collect Personal Information through your communications with our customer-support team.
Location and Other Information from Your Mobile Device. We collect and store your location information if you enable your mobile device to send it to us. We may also collect information that identifies the mobile device you are using. Collection of this information improves the provision of the Service. You may opt-out of location-based services at any time by editing the setting at the device level.
Promotions and Co-Branded Services. We or our advertisers and other business partners may conduct or sponsor special contests, sweepstakes, and other promotions (“Promotions”) that users may enter, register for or otherwise participate in through the Service. Certain of these Promotions may be co-branded with one of our advertisers, business partners, charities, sponsors or other third parties (“Third-Party Partners”). Such co-branded services will identify the Third-Party Partner. In these instances, the Third-Party Partner may collect your Personal Information directly on its website or another online service may collect your Personal Information and share it with us and/or the Third-Party Partner. If you enter a Promotion, your Personal Information may be disclosed to Third-Party Partners or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and publication of a list of winners, as required by law or permitted by the Promotion’s rules.
Information You Provide About a Third Party. If you use our referral program to tell a friend, relative or someone you know about our Service (a “Referred Person”), we will ask you to provide the Referred Person’s name and e-mail address. We will automatically send the Referred Person an e-mail inviting them to try our Service. We may also send a follow-up e-mail or e-mails, at our discretion. If a Referred Person no longer wants to receive communications from us, they can e-mail email@example.com with their request and we will discontinue further communications.
Cookies, Automatic Data Collection, and Related Technologies. The Service and our third party partners collect and store information that is generated automatically as you use it, including your preferences and anonymous usage statistics. When you visit the Service, we and our third-party service providers receive and record information on our server logs from your browser, including your unique device ID, IP address, and from cookies and similar technology. Cookies are small text files placed in visitors’ computer browsers to store their preferences. We may use information collected through these tracking technologies to remember information so that you won’t have to re-enter it on subsequent visits, to provide and monitor the effectiveness of the Service, to provide custom, personalized content including targeted advertising, to automatically update the Service on your mobile devices and for other purposes. Most browsers allow you to block and delete cookies, though depending on your mobile device you may not be able to delete tracking technologies from your device. Deleting or blocking cookies and other tracking technology may cause the Service to not work properly. Although we do our best to honor the privacy preferences of our members, we are not able to respond to Do Not Track signals from your browser at this time. Please see the Online Advertising section below to learn more about how tracking technologies may be used to serve advertising that is relevant to your interests.
By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.
HOW VIA USES YOUR INFORMATION
We use Personal Information to
- facilitate and improve our services; and
- communicate with you.
We may use aggregate information for any purpose, including for marketing purposes.
Internal and Service-Related Usage. We use information, including Personal Information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Service. We may use and retain any data we collect to provide and improve our services.
Communications. We may send email or text messages to the email address or phone number you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.
Marketing. We may use information, including Personal Information, to facilitate transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you, and to serve you personalized advertising content that may be relevant to your interests.
Aggregate Data. We may anonymize and aggregate data collected through the Service and use it for any purpose.
VIA MAY DISCLOSE YOUR INFORMATION
We may share your information:
- with our Driver Partners or Members only to facilitate your Rides;
- with our third-party service providers;
- in the context of a Driver Partner referral;
- with insurance companies, government agencies or law enforcement;
- to comply with legal obligations;
- to protect and defend our rights and property; and
- with your permission.
We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission.
Driver Partners and Members. When a Member requests a Ride, we may share your first name and last initial and location with a Driver Partner in order to provide the Service. We will not share your e-mail address, phone number or other information with Driver Partners without your permission. With respect to Driver Partners, we may share your name, location and a masked phone number with a Member in order to provide the Service. In connection with a Member’s request to retrieve a lost and found item from a vehicle, we may share your phone number with a Member. Otherwise, we will not share your e-mail address, phone number or other information with Members without your permission.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Service. We will share information, including Personal Information, with our third-party transportation providers as necessary to provide the Service. If we transfer personal information to a third party, we will take reasonable and appropriate steps to ensure that the third party collects, processes and discloses personal information only for limited and specified purposes. Under Via’s Privacy Shield obligations, Via may be liable if such third parties fail to meet those obligations.
Driver Partner Referrals. If you are a Driver Partner who has been referred to Via by another Via Driver Partner, we may share with your referrer certain information relating to your activity during the applicable referral promotion period, if any (such as your status in the Via system and the number of rides you completed during the promotion period).
Marketing. We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission. We may share or allow access to data collected through tracking technologies to serve you personalized advertising content that may be relevant to your interests. Please see the Online Advertising section below to learn more.
As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena or to meet national security requirements; respond to your requests; or protect yours’, ours’ or others’ rights, property, or safety.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.
We may also disclose your Personal Information with your permission.
SECURITY OF YOUR INFORMATION
By using the Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at firstname.lastname@example.org.
We may retain your information for as long as your account is active and for up to three years after you close your account or it becomes inactive, in accordance with our data retention policy. In certain circumstances, we may retain your information for longer periods of time in order to provide you with services, comply with our legal obligations, resolve disputes and enforce our agreements, in accordance with our data retention policy.
We do not knowingly collect information from children under 13 and we do not want it. We will take steps to delete it if we learn we have collected it.
No part of our Service is directed towards children under the age of 13 and we do not knowingly collect, maintain, or use Personal Information from children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account, in compliance with the Children’s Online Privacy Protection Act (COPPA).
By using the Service, you will transfer data to the United States.
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information, you consent to any transfer and processing in accordance with this Policy.
YOUR CHOICES FOR LIMITED USE AND DISCLOSURE OF YOUR DATA
You control your account information and settings. You may update your account information and email-communication preferences at any time by logging into the app and changing your settings under Edit Profile.
Communications. You can stop receiving promotional e-mail communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt-out of Service-related communications (e.g., account verification, texts informing you of where your vehicle is located and the status of your live rides, receipts, reminders, changes/updates to features of the Service, technical and security notices).
Online Advertising. We may permit third party online advertising networks to collect information about your use of our website over time so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites or apps. Typically, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Note that disabling cookies may disable many features available through the Service. (To learn more about cookies, clear gifs/web beacons and related technologies, and to learn how you may be able to opt-out of interest-based advertising from many online advertising networks, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org). You may also manage certain advertising cookies by visiting the EU-based Your Online Choices www.youronlinechoices.eu. If you access our service on your mobile device, you may not be able to control tracking technologies through changing your settings in your profile.
ACCESSING, UPDATING, OR DELETING YOUR INFORMATION.
HOW TO RESOLVE COMPLAINTS
Via Transportation, Inc.
160 Varick Street, 4th Floor
New York, New York 10013
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim. Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint.
Via is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).