In The Field Privacy Policy

WELCOME

IntelliShift, Inc (“IntelliShift“, “we“, “our“, or “us“) is committed to protecting and respecting your privacy.

IntelliShift operates a service that allows you to speak to and share your location with other users in your business, or as you designate (each group, a “Business Unit“), which we make available through our apps and our website https://www.IntelliShift.com (the “Service“).

This Privacy Policy explains our practices regarding the collection, use, disclosure, transfer, storage, and protection of personal information that is collected through our Service, as well as your choices regarding the collection and use of information.

Our Service is available in many countries, which may have different standards and requirements in respect of the information we provide in the Privacy Policy and how we use personal information.

Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that is relevant to you.

Privacy Policy for North American users

Our Service is available for users throughout North America, this Part of our Privacy Policy explains how we collect, use, disclose and protect information that is collected through our Service from our users in North America as well as your choices regarding the collection and use of information.

1. HOW WE COLLECT AND USE INFORMATION

Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use.

We collect the following types of information about you:

Registration and Profile Information. When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number. We may collect a photo, if you or a Business  Unit member associate a photo with your account. If you want to add a member’s to your account, we collect the member’s name, email address, and mobile phone number. We may also collect billing information.

Data collected through use of the Service.  After you set up your account, we may ask for other profile and demographic information. You may also customize your map by labeling locations, such as “work” to make it easy to spot your favorite places and to provide alerts when members leave and arrive.

Geolocation.  We collect your location information through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. We collect and maintain location data to provide you the features and functionality of the Service. We may also share location information with our partners for attribution, analytics, research and other purposes, as described in Section 2 “Sharing of Your Information” below.

Driving Event Data.  We collect, and may use a third party partner to collect, sensory and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass and Bluetooth, in order to calculate and detect driving events such as speeding, hard braking, crash detection and other events. We may also share this information with third party partners for marketing, research, analytics and other purposes.

Messages and User Content.  We collect information when you message other members of your Business Unit through use of the service. We may also retain any messages you send to us.

We use this information to operate, maintain, and provide to you the features and functionality of the Service and to communicate directly with you, such as to send you alerts on the movements of your Business Unit, etc.

Social Media.  When you interact with our site through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to IntelliShift’s website or Service.

Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information, such as:

• Information about how you access the Service, for example, referral/exit pages, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.
• Information about how you use the Service, for example, the features you use, the links you click, the ads you view and click on, purchase transaction information, your location when you access or interact with our Service, and other similar actions.
• Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/ model/ manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, and other such information. With your permission, we may also access your photo or camera roll.

We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

We use this information to (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide custom, personalized content and information, including targeted content and advertising; (iii) track your location and movements; (iv) identify and contact you across multiple devices; (v) provide and monitor the effectiveness of our Service and our marketing campaigns; (vi) monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns; (vii) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs; and (viii) detect or prevent fraud or other harmful activities; (xi) automatically update our mobile application on your system and related devices; and (x) otherwise plan for and enhance our Service.

If you prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. These browser settings that block cookies may have no effect on non-cookie technologies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time.

We and our third party partners may also use information collected through tracking technologies for advertising purposes. Please see “Third Party Tracking and Online Advertising” below to learn more.

2. SHARING OF YOUR INFORMATION

Personal Information:  We share your personal information with third parties outside the Company and its controlled subsidiaries and affiliates in some circumstances, as follows:

• We share your personal information, including name, email, precise location and driving event data, with others within your Business Units.
• As we develop new features in the future, we may share personal information with third parties that you have connected to your IntelliShift account to facilitate the features or services. For example, if you enable the IntelliShift Action on any Google Assistant-enabled device or use other voice-assistant services, IntelliShift will respond to any query received through the Action and disclose your personal information we well as the personal information (such as name, current location, and other data) of your Business Unit members through screen display or audio response. Google and the equipment the Google Assistant is installed on, may record your interactions with the Action and the response data in accordance with your agreements with Google. You are solely responsible for the use of the IntelliShift Action to access information about your Business Unit members on your Assistant-enabled devices, including in the case of any unauthorized access to your device by a third party, and for the consequences of enabling the Action on any of your devices.
• Any information or content that you voluntarily post to the website or to our Facebook page will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile app or link your reviews to third party websites.

Other instances in which we may share your information: We may also share your information for business purposes, as follows:

• We may share your personal information with our third-party business partners, vendors and consultants who perform services on our behalf or who help us provide our Services, such as accounting, managerial, technical, marketing or analytic services, and to other third-party partners or service providers who contractually agree to process personal information solely as necessary to provide services or features to our users.
• We may at any time buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personal information such as customer names and email addresses, and other user information related to the Service will likely be one of the items transferred in these types of transactions. We may also share, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.
• We may disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) when required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of IntelliShift, our Users or others.

IntelliShift is a USA-based organization and we store your personal information in the USA, which may be outside your jurisdiction of residence. Our partners and service providers may also store your personal information outside your jurisdiction of residence. Accordingly, your personal information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such jurisdictions.

De-Identified Information:  We may also share your information with third parties in a form that does not reasonably identify you directly.  These third parties may use the de-identified information for any purpose.

3. HOW WE PROTECT YOUR INFORMATION

IntelliShift cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable andjhk we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

4. YOUR CHOICES ABOUT YOUR INFORMATION

You may, of course, decline to submit any personal information through the Service, in which case IntelliShift may not be able to provide its Services to you.

Modifying Your Account Information and Settings:  You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. If you have any questions about reviewing or modifying your account information, you can contact us directly at privacy@IntelliShift.com.

Close Your Account or Delete Personal Information:  We retain your information for as long as your account is active or as reasonably necessary to maintain the Service, meet legal and accounting obligations, and for the other purposes described in this Privacy Policy. If you wish to close your account, and/or request to delete your personal information, please contact us at privacy@IntelliShift.com. When account information is deleted or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing and tax purposes.

Emails and Notifications:  You can control your receipt of email and text alerts by visiting “Settings” and “Alert Options” within the mobile app. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of Service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices).  You may also unsubscribe from receiving SMS text messages by replying “STOP” to the number sending the message. We make every effort to promptly process all unsubscribe requests.

Location and Movement Data Collection and Sharing:  As described in Section 2, we collect precise location data and driving event and movement data (such as accelerometer data, magnetometer data, gyro data, etc.) from your device to provide the IntelliShift Services, and may share your personal information, including location and movement data, with other IntelliShift users in your Family Business   Unit or other Business   Unit you belong to, and with third parties for crash detection, research, analytics, attribution and tailored advertising purposes. You have many options to control this data collection and sharing activity through the App Settings:

• Limit location sharing with your Business   You may turn location sharing “OFF” for one or more of your Business   Units through your App settings.  If you turn off location sharing in one or more of your Business   Units, we will not share your location with such Business   Units; however, we will continue to collect your location information in order to provide the Service (for example, to provide our emergency services, to share your location with the other Business   Units, or to provide location-based advertising). Note: if you press “Check In” or “Automated SOS” in the App, your location will update in every one of your Business   Units even if location sharing is turned off for one or more of your Business   Units.
• Limit Drive Detection.  You can limit the collection and display of location and movement data through the Drive Detection feature in the in-App Privacy settings. When you turn Drive Detection “off,” your location is not visible to your Business Units and your location and drive history will not show on Individual or Family Driver Reports. Please note that your IntelliShift app may not be able to provide all of our Services to you turn off Drive Detection. When Drive Detection is turned “off,” Crash Detection services will be disabled and safety services like SOS Help Alerts and 24/7 Dispatchers will not be available.
• Limit data sharing with third party data partners through in-App Privacy Settings. To opt-out of IntelliShift sharing personal information (including location and movement data) with data partners for targeted advertising, research, attribution and similar purposes, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security settings. If you opt-out, IntelliShift will continue to collect your device location and movement data and to share such data with your Business   Units and with third parties as needed to support and provide the IntelliShift services or other services you engage, but we will no longer share data about you with our third party data partners for their own advertising and other commercial purposes. Please note, some third party data partners may continue to send you location-based ads based on your previous location or may approximate your location based on other data.
• Limit driving event sharing with Arity. We share data with our partner Arity to support important App features like driving behaviour and Crash Detection. Arity may also use data for research or to provide and service insurance company products and analytics services. To opt-out of permitting Arity to use and learn from your data for its own research, marketing and analytics purposes, you can opt-out through the Driving Services page in the in-App Privacy Settings.
• Disconnect Location Data and Movement Data in Device Settings.  You may also be able to turn off device location data collection through your mobile device settings.  For example, depending on your mobile device, you may be able to “Turn location services ‘off,’ which restricts access to your device location data. You can also adjust your device settings to withdraw permission for the IntelliShift app to access device location data and/or motion data (depending on the device type, this may be called “Fitness and Motion” data). Please note that your IntelliShift App may not be able to provide all of our Services to you if you disable access to location and movement data through your device settings.

 Third Party Tracking and Online Advertising: We may share information about your use of our Services over time, including location information, with third party ad networks, social media companies and other third parties so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices or advertising channels. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third party ad partners collect and use information such as click stream information, timestamp, hashed email address, device ID or AdID, your use of third party applications and/or precise geolocation data and other information, and may combine this information with information they collect directly through tracking technologies or that they receive other partners, both online and offline, so that they may recognize you across other browsers or devices you use, including computers, mobile devices and Smart TVs. These third parties 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.

• To opt-out or control third-party tracking and advertising: Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of the use of your personal information to inform and display targeted advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu.
• Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).  You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
• Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
• Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
• Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferencesor by vising NAI’s online resources at http://www.networkadvertising.org/choices.
• To opt–out of IntelliShift sharing data with third parties for advertising purposes. To opt-out of IntelliShift sharing personal information (including location and movement data) with data partners for their own targeted advertising, research, attribution and similar purposes, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security settings. Please note, some third party data partners may continue to send you personalized or location-based ads based on your previous location or data they have collected from other websites and mobile apps.

You may request access to, or correction of, your personal information by contacting us at privacy@IntelliShift.com.

5. LINKS TO OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.

6. CHANGES TO OUR PRIVACY POLICY

IntelliShift may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the top of this page. If there are material changes to this Privacy Policy or in how IntelliShift will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.

7. YOUR CALIFORNIA PRIVACY RIGHTS

This section applies to you if you are a resident of the state of California (a “consumer”). California law requires us to disclose certain information regarding the categories of personal information we collect. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with an identifiable consumer or device.

Collection and use of personal information. We collect personal information from and about you for a variety of purposes explained in this Privacy Policy.

In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your name, address, phone number, email address, unique device identifiers or other similar identifiers;
• California customer records, such as birth date and payment information;
• Commercial information, such as records of services purchased, obtained or considered;
• Internet/Network information, such as device information, logs and analytics data;
• Geolocation data, such as precise location data from your mobile device (e.g., GPS coordinates) or generated based on your IP address;
• Inferences about your interests and preferences, generated from your use of our services; and
• Other personal information, such as driving event and movement data collected from your mobile device, or content or messages you send through the Service.

We collect this information directly from you, from our business partners, from your browser or device when you visit our websites, download or use our mobile app, and from third parties that you permit to share information with us.

Disclosure of Personal Information. We share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see Your Rights and Choices below). The categories of third parties to whom we disclose your personal information may include: (i) other users with whom you elect to share such information; (ii) our service providers and advisors, (iii) third party businesses that provide features or services you may use in connection with our Service; (iv) marketing and strategic partners; (iv) ad networks and advertising partners; (v) analytics providers; and (vi) social networks. To learn more about how we disclose personal information to third parties, please refer to Section 2 of this Privacy Policy.

In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose: Identifiers, California customer records, Commercial information, Internet/Network information, Geolocation data, Inferences, and Other personal information.

In the previous 12 months, we have sold the following categories of personal information to third party data partners and advertising partners for targeted marketing, attribution, analytics and research purposes (subject to your settings and opt-outs):  Identifiers, Internet/Network information, Geolocation, Inferences, and Other personal information, including driving event and movement data. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.

Your Rights and Choices.  As a California resident, you may be able to exercise the following rights (subject to certain limitations under law):

• The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: (i) the specific pieces of personal information we have collected about you; (ii) the categories of personal information we have collected about you; (iii) the categories of sources of the personal information; (iv) the categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; (v) the categories of personal information we have sold and the categories of third parties to whom the information was sold; and (vi) the business or commercial purposes for collecting or selling the personal information.
• The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
• The Right to Opt Out of Personal Information Sales to third parties now or in the future.

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

To Submit your California Consumer Rights Requests. You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account.  In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

• To exercise your Right to Know or your Right to Request Deletion:  Submit a request through the App by clicking on “Additional Information for California Residents” page in your in-App Privacy & Security Settings. Then, select “Request Your Data” or “Delete Your Data” to submit your request. We will process your request and send an email confirmation once your request has been fulfilled.
• To exercise your Right to Opt Out of App-based Personal Information Sales: In the App, click on the “Do Not Sell My Personal Information” link in your in-App Privacy & Security Settings and adjust the Personal Information Sales toggle.
• To exercise your Right to Opt Out of web-based Personal Information Sales: On our website, please click the “Do Not Sell My Personal Information” link in the footer of the website and adjust the Personal Information Sales toggle.   Please note this setting does not affect App-based sales. If you wish to opt out from the sale of data that is collected through the IntelliShift mobile application, you must opt out separately by following the instructions above.
• To submit your request via email: Alternately, you may submit a request to exercise your California Consumer Rights via email by contacting us at privacy@IntelliShift.com and including your account name and mobile telephone number as well as the consumer right you would like to exercise. We may need to contact you to request additional information to verify your request.  For faster response times, we recommend users submit all requests through the in-App Privacy & Security Settings.

Authorized Agents. You may authorize another person (your “agent”) to submit a California consumer rights request on your behalf. Authorized agents must submit the request via email to privacy@IntelliShift.com and include a signed letter from the IntelliShift user confirming the agent has permission to submit the request on the user’s behalf. In certain circumstances, we may need to request additional information to verify the identity of the user about whom the request is being made and/or to verify that the user has provided the authorized agent permission to submit the request, and it may take additional time to fulfil agent-submitted requests. Please note that for privacy and security reasons, we will direct future communications to the IntelliShift user on whose behalf the request was made. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.

California’s “Shine the Light” Law. California’s “Shine the Light” law (Civil Code Section § 1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click the “Do Not Sell My Personal Information” link available in the in-App Privacy & Security Settings and adjust the Personal Information Sales toggle.

8. YOUR NEVADA PRIVACY RIGHTS

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacy@IntelliShift.com or visit www.IntelliShift.com/opt-out.

9. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at privacy@IntelliShift.com

IntelliShift
ATTN: Privacy
152 Veterans’ Memorial Highway

Commack, NY 11725