Membership Agreement | Rental Agreement
Zerology Privacy Statement
Last Issued: December 28, 2019 (Version 1.0)
This Privacy Statement (this “Privacy Statement“) explains how Mobility Transformation, Inc. and its affiliates and subsidiaries including Zerology, LLC (collectively, “Zerology“, “we“, “our” and “us“), may collect, use, and share your personal information when you use or interact with Zerology products and services including, without limitation, Zerology vehicles (each a “Vehicle” and collectively, “Vehicles”), www.zerology.com (our “Site”) and our Zerology mobile application (“Zerology Mobile App”) (collectively, “Zerology Services”). This Privacy Statement does not apply to other products and services even if accessed via Zerology Mobile App. By using Zerology Mobile App, you consent to and accept our use and other processing of your personal information as set forth in this Privacy Statement. If you do not agree with the terms of this Privacy Statement, please do not submit any personal information to us and please do not use Zerology Mobile App. This Privacy Statement is incorporated into, and part of the Membership Agreement and Rental Agreement, which govern your use of Zerology Mobile App. If you have any questions or complaints regarding out Privacy Statement or practices, please contact us at [email protected] or one of the other ways provided below.
Key points about our information practices:
|We collect personal information about you such as your name, address, driver’s license information, vehicle location and photographic image through your use of Zerology Services, and third-parties who share your personal information with us.See “Personal Information We Collect” below to learn more.
||We use your personal information to enable you to register for Zerology Services and verify your identity, improve the quality, safety, and security of Zerology Services, to develop new products and services, and for marketing purposes. See “How We Use Your Personal Information” below to learn more.
||We share your personal information with third-party service providers to provide you with Zerology Services, to improve the quality, safety, and security of Zerology Services, to comply with applicable law, to respond to your requests, and to allow our third-party service providers to use your personal information for marketing or other related purposes subject to your consent where required.See “How We Share Your Personal Information” below to learn more.
||You have choices regarding how we use and share your personal information for marketing and other purposes including your decision to opt-out. See “Your Choices” below to learn more.
||If you use the Vehicle’s touchscreen media system during your reservation (for example, to input contacts, perform address look-ups, or save map addresses), you are responsible for deleting this personal information at the end of your reservation. See “Your Obligations” below to learn more.
|Cookies and Tracking
|Third Party Products and Services
||In connection with Zerology Services, you may be offered the opportunity to use third-party products and services that are not owned or controlled by Zerology and are governed by separate user terms and privacy statements.See “Third Party Services Applications and Websites” below to learn more.
|Access and Update
||You may access your online account to update your personal information or you may contact us to learn about how to do so. See “Access and Updates to Your Personal Information” below to learn more.
||We maintain reasonable and adequate security controls to protect your personal information and require our third-party service providers by contract to do the same.See “How We Safeguard Your Personal Information” below to learn more.
||We keep personal information for so long as appropriate to provide you Zerology Services, operate our business, and comply with legal obligations.See “How Long We Keep Your Personal Information” below to learn more.
||We do not intentionally collect personal information from children under the age of 13.See “Children’s Privacy” below to learn more.
|International Data Transfers
||We do not intentionally collect personal information from individuals who are not residents of the U.S. See “International Data Transfers” below to learn more.
||We will notify you of any material changes by posting the updated version of this Privacy Statement and taking other steps as required by law. See “Your Consent” below to learn more.
||Please contact us by mail, e-mail or phone with any questions.See “How to Contact Us” below to learn more.
PERSONAL INFORMATION WE COLLECT
We collect personal information through your use of Zerology Services and related marketing events. We may also collect your personal information from licensees, affiliates, dealers, partners, service providers, and other third-party service providers and subcontractors (collectively, “ServiceProviders“). We collect the following types of your personal information:
- Information about you and your accounts with us. This includes your name, address, telephone number, date of birth, driver’s license number and the jurisdiction in which you are licensed, photographic image, e-mail address, login information, enrollment and reservation information, demographic data, account password and/or PIN, emergency contact information, and billing information (your credit card number, CVV code and expiration date). We may also collect information such as your driver record from you, from regulatory bodies where you live, or from third parties. We use this information to complete your account activation and to provide to you Zerology Services.
- Information about your use of the Vehicle, including operational and safety related information. This includes global positioning system (GPS) location, speed, air bag deployments, crash avoidance alerts, autopilot alerts, impact data, safety system status, braking and swerving/cornering events, event data recorder (EDR) data, seat belt settings, vehicle direction (heading), trip start/end time and date, camera image and video, sensor data, voice command information, stability control or anti-lock events, security/theft alerts, infotainment system and WiFi usage. GPS information is collected and utilized to allow you to lock, unlock and operate the Vehicle, to track the location and movement of the Vehicle, and to provide you with the location of the Vehicle. Depending on the mobile device preferences you have selected, you may share GPS information with us even when you are not participating in Zerology Services.
- Information about your device and how you interact with Zerology Services. When you visit our Site, we automatically collect your IP address, browser type, device location, unique device identifier, cookie data, associated identifying and usage information from your mobile phone, laptop, or other device. We collect and use such personal information to personalize yourZerology Services experience. We may also record information about your browsing session on our Site, including which pages you visited and any forms you filled in. We review this information to identify any technical issues in the operation of our Site and to improve the user interface of our Site. If we use a third-party to help us with this service, this information will be passed to that third-party for this purpose. When you download and use the Zerology Mobile App, we may use mobile analytics software to help us better understand the functionality of the Zerology Mobile App on your mobile device. Our analytics may record how often you use the Zerology MobileApp, how you use the Zerology Mobile App, aggregated usage performance data and from where you download the Zerology Mobile App. In addition, you may elect to provide us access to certain information such as your mobile device photographs and camera. If you grant us such access, this enables us to verify your identity prior to operating the Vehicle and to complete your Vehicle rental by you taking interior and exterior photographs of the Vehicle.
- Biometric data. We may collect, use, store and retain your biometric data to confirm your identity. Biometric data includes “biometric identifiers” and “biometric information” such as your facial geometry or other unique physical representation. We retain your biometric data only for the amount of time it is needed to fulfill the legitimate purpose for which it was collected or to satisfy a legal requirement not to exceed three (3) years from your last interaction with Zerology. We use a reasonable standard of care that is the same or as more protective than the manner in which we store, transmit and protect other personal information to store, transmit and protect from disclosure biometric data. If you reside in Illinois and certain other states, you must agree to our Biometric Information Privacy Agreement incorporated in this Privacy Statement by reference as applicable.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information in order to:
- provide you access to Zerology Services;
- improve the quality, safety, and security of Zerology Services;
- develop new products and services including, without limitation, autonomous vehicles and car sharing products and services;
- maintain customer relationships and communicate with you;
- personalize your experience; •administer your account including verification of your identity;
- process your payments; •operate our Site and applications, including our online registration processes;
- provide customer and vehicle support and service (for example, charging station usage, vehicle servicing and maintenance);
- provide product and service updates;
- evaluate and maintain the quality, safety, security and integrity of our products and services;
- collect outstanding debts relating to products and services, and parking, charging and moving violations and damages to vehicle;
- assist in locating or recovering a Vehicle that is missing, reasonably identified as stolen or being used in an unauthorized manner;
- for research, evaluation of use, and troubleshooting purposes;
- protect the safety of you or others;
- verify eligibility for incentive and discount programs and to evaluate ongoing program and membership eligibility;
- perform and/or send marketing communications, including interest-based marketing and advertising (with required consents, as applicable);
- administer quizzes, surveys, promotions and offers;
- customize and improve communication content and your experience with Zerology Services; and
- comply with legal, regulatory or contractual requirements;
- detect and deter fraud, theft or abuse of Zerology Services;
- assist emergency service providers; and
- engage in other activities in the normal course of operating a car sharing service
We may also use your personal information for any other purpose with your consent. Where required, we will anonymize your personal information in a way that it can no longer reasonably be associated with you or the Vehicle. We may use anonymized personal information or share it with third parties for any legitimate business purpose including, without limitation, general demographic and general marketing purposes. Communications with you in connection with these uses may be made via mail, telephone, e-mail, text message and other electronic messages through Zerology Services. See “Your Choices” below to learn how to manage your communication preferences.
HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your personal information as follows for the uses described above (and where required we will obtain additional consent or anonymize your personal information):
Electronic Vehicle Original Equipment Manufacturers (OEM): With Tesla and/or any other Zerology Vehicle fleet partners.
Emergency Service Providers: With emergency service providers, such as law enforcement, roadside assistance providers, and ambulance providers.
Business Partners and Independent Third Parties: With business partners, such as research institutes who assist us with research and development (for example, improving highway safety), OEM fleet providers, for service maintenance of the Vehicles, and marketing activities. We may also share your personal information with third parties where you have elected to receive a service from them and you have authorized them to request data from Zerology.
Service Providers: With our third-party product and service providers including, without limitation, companies that perform eligibility services (such as identity verification to prevent theft and fraud) administer our contests and promotions, host and/or operate our Site, send communications, perform data analytics, credit card processors, or system providers necessary to process, store, or manage credit card personal information (we will not otherwise share your credit card personal information).
Where Required or Permitted by Law: Such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution, or similar legal process, when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, to detect, investigate and prevent fraud, or to conduct screening to ensure you are not on any government list of restricted parties.
Business Transfers: In connection with a corporate transaction, a prospective or completed sale, transfer, restructuring, bankruptcy or financing of Zerology or its assets.
You have certain choices regarding how we use and share your personal information. For example, you can restrict our access to and our ability to collect and share the location of your mobile device by disabling location-sharing in the settings feature on your mobile device. However, some of the products and services require access to and collection of the location of your device (for example, we require your mobile device’s location to unlock, lock and operate the Vehicle, start and complete your reservation and to confirm that the Vehicle has been returned to the appropriate location). If you elect to restrict our access to location-sharing services on your device, you will not be able to reserve a Vehicle and your ability to use Zerology Services may be severely limited.
In addition, vehicle data collection, use, and sharing practices are tied to the products and services we offer. To stop the collection, use, or sharing of personal information, you may have to decline those products and services or be willing to accept limited functionality.
You may choose to limit the marketing communications we send you by managing your subscriptions. You may also contact us directly, at [email protected]
to indicate your communications preferences. We provide opt-out instructions in all of our marketing communication channels (for example, an unsubscribe option will appear at the bottom of all marketing-related emails).
If you opt out of marketing communications, your personal information may still be used for the other purposes described in this Privacy Statement (for example, vehicle support and service), including communications we are required or permitted by law to send to you (for example, certain types of transactional or account-related messages).
You may permit us to send you push notifications. We will use push notifications to provide certain services such as emergency or other service notifications, return notifications, providing information about vehicle location, and providing details regarding Zerology 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 have elected to share your geolocation with us, push notifications may also be used in conjunction with or related to your location. If you change your mind about sharing your location or receiving push notifications from the Zerology Mobile 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.
For additional personal information about your choices, please contact [email protected]
If you use the Vehicle’s touch screen media system during your reservation (for example, to sync your phone, play music, perform address look-ups or locate a destination, you are responsible for deleting this information at the end of your reservation. Zerology will, from time to time, erase profile information saved to its vehicles. However, if you do not delete this information after usage, it may remain on the Vehicle’s system for an unknown length of time and may be accessible to other Vehicle occupants, such as future Zerology Services customers. For instructions on how to delete information from the Vehicle, please refer to the Zerology Mobile App tutorials or contact customer care at [email protected]
or another method as provided below.
COOKIES AND OTHER TRACKING TECHNOLOGIES
Similarly, we may also place Cookies in our e-mails to measure the effectiveness of our e-mail campaigns which identify the individuals who open or act upon an e-mail message, when an e-mail message is opened, how many times an e-mail message is forwarded, the type of software, device, operating system and browser used to deliver the e-mail and any URL accessed through our e-mail message.
Please also refer to your browser settings to learn more about cookies and other technologies and how to manage cookie preferences. If you elect to refuse or delete cookies, you will need to repeat this process if you use another computer or change browsers. If you choose to decline Cookies, some of the functionality of our Site may be impaired.
If you are a California resident, you have the right to receive specific information about how we disclose your personal information to others for marketing purposes and your related choices. Pursuant to California Civil Code Section 1798.83(c)(2), we will not share your personal information with other parties for direct marketing use unless you agree that we may do so or as provided for in this Privacy Statement. If you are a California resident under the age of 18 and you have publicly posted any information on our Site or on the Zerology Mobile App, California Business and Professions Code Section 22581 permits you to request and obtain removal of the content or information you have publicly posted. If you wish to make such a request, please send an e-mail with a detailed description of the specific content or information to [email protected]
. Please be aware that there may be circumstances in which the law does not require or allow us to remove information even if you have made such a request.
Most web browsers and some mobile operating systems and mobile applications include a Do Not Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will update our policy related to such DNT signals in this Privacy Statement.
THIRD-PARTY SERVICES, APPLICATIONS AND WEBSITES
Certain third-party services or applications (for example, your carrier data plan, navigation services) you download, that are pre-installed, or which you may sign up for may have separate user terms and privacy statements, which are independent of our Privacy Statement. Zerology is not responsible for the personal information practices of these third-party services or applications. We recommend that you carefully review the user terms and privacy statement of each third-party service or application prior to signing up, downloading, or using them.
Similarly, our Site and the Zerology Mobile App may contain links to independent sites outside of and not controlled by Zerology or independent product review sites. These other websites or mobile applications may send their own cookies to visitors, collect data or solicit personal information, and the privacy policies of these third parties may be significantly different from this Privacy Statement. Zerology is not responsible for these other websites or mobile applications, their omissions, policies, website content or for the personal information practices of such third parties. We recommend that you read the privacy policies provided by these third parties before making a decision to use the site or provide your personal information to the website or mobile application operators.
Google utilizes IP address information to evaluate your use of our Site, compile reports on website activity and to provide further services related to our Site. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google. In addition, our Site uses the Analytics feature UserID to track interaction data. This User ID will be additionally anonymized and encrypted and will not be linked with other data. You can prevent the storage of cookies by changing your browser software settings; however, if you do this, you may not be able to use all the features of our Site to the fullest extent possible.
ACCESS AND UPDATES TO YOUR PERSONAL INFORMATION
You can access your online account to view or update your information related to and stored on your account. You may also contact [email protected]
to learn about how to access, review, correct, update or delete the personal information about you in our records. We may need to retain certain personal information for record keeping purposes, to complete any transactions that you began prior to your request or for other purposes as required or permitted by applicable law.
HOW WE SAFEGUARD YOUR PERSONAL INFORMATION
We maintain commercially reasonable procedures and technology designed to prevent the unauthorized access of your personal information that you provide to us. Zerology Services has reasonable technical, administrative and organizational security measures in place to protect the loss, misuse or unauthorized alteration of information under our control. However, we cannot guarantee that unauthorized third parties will never be able to defeat those security measures or otherwise obtain access to your personal information.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We generally keep your personal information only for so long as necessary to provide Zerology Services to you including, without limitation, to enable us to communicate with you, for your safety, for our research, evaluation of use, or troubleshooting purposes, as well as to operate our business, or to satisfy our legal or contractual obligations. Where required or appropriate, we will anonymize or dispose of your personal information when we no longer need it for the uses described above.
We do not knowingly collect personal information from children under 13 years of age. If you become aware that a child has provided us with personal information without parental consent, please contact us via e-mail at [email protected]
. If we become aware that a child under 13 years of age, we will take steps to remove such personal information and terminate the child’s account.
INTERNATIONAL DATA TRANSFERS
We store your personal information on servers located in the U.S. If you reside outside the U.S., please know your personal information will be transferred, processed and stored on third-party servers in the U.S, which the EU has deemed to have inadequate safeguards. Since individuals who are not residents of the U.S. are ineligible for the vehicle sharing service provided by Zerology, Zerology Services is not intended for non-U.S. residents. Accordingly, we request that non-U.S. residents refrain from providing us personal information and to refrain from utilizing Zerology Services.
CHANGES TO THIS PRIVACY STATEMENT
We may update this Privacy Statement from time to time as our business, products and services expand or change, or as required to by law. If we do, we will post the updated version of the Privacy Statement on our Site. Your continued use of Zerology Services shall be construed as your implied consent to the Privacy Statement updates.
Unless otherwise required by applicable law, this Privacy Statement, and Zerology’s collection and use of personal information, shall be governed and interpreted in accordance with the laws of the U.S. and the State of Wisconsin.
By using Zerology Services, you are consenting to our processing of your personal information as set forth in this Privacy Statement and the Biometric Information Privacy Agreement, as applicable, now and as amended by us from time to time. “Processing” means using cookies on a computer/handheld device or using or touching your personal information in any way, including, but not limited to, collecting, storing, deleting, accessing or transferring, combining and disclosing personal information, all of which activities will take place in the U.S.
HOW TO CONTACT US
If you have concerns or questions regarding Zerology’s consumer privacy practices or this Privacy Statement, please visit our Site at www.zerology.com, e-mail us at [email protected]
or call us at 800-277-1455.