CABLR PRIVACY POLICY

1. Introduction

At Cablr, we want to connect people through transportation and bring communities together. We understand the trust that is being given to us when you provide use with your personal information. And we can unequivocally state that we are committed to keeping that trust and protecting your privacy. This relationship of trust begins with the responsibility we have to help you understand our privacy policy. In this privacy policy, we tell you what information we receive from Cablr riders and drivers, and how we use it to connect riders with drivers and continue to improve our services.

2. Scope of this Privacy Policy

Cablr (“Cablr,” “we,” “our,” and/or “us”) values the privacy of individuals who use our application, websites, and related services (collectively, the “Cablr Platform ”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from Cablr users (“Users”), comprised of Cablr riders (“Riders”), transportation companies and their drivers who provide ground transportation services using the Cablr platform (“Independent Affiliate Operators”), companies who use the Cablr business partner portal to manage the transportation needs of their organization (“Business Partners”), individuals who sign up to become Cablr brokers (“Brokers”) and Cablr drivers (including Driver applicants) (“Drivers”). Beyond the Privacy Policy, your use of Cablr is also subject to our Terms of Service (www.cablr.com/terms-services).

3. Information We Collect

A. Information You Provide to Us

Registration Information. When you sign up for a Cablr account, you give us your name, email address, and phone number.

Payment Method. When you add a credit card or payment method to your Cablr account, a third party that handles payments for us will receive your card information.. Cablr utilizes a third party, Stripe, to store and process payments. Stripe’s privacy and terms can be viewed at https://stripe.com/privacy.

Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.

Driver/Partner/Broker Application Information. If you decide to join our Cablr driver community, as a Driver, Business Partner, Independent Affiliate Operator or Broker, in addition to the basic registration information we ask you for your date of birth, physical address, Social Security number, driver’s license information, vehicle information, car insurance information, and in some cases we may collect additional business license or permitting information. We share this information with a third-party partner Checkr.com who help us by running background checks on Drivers to help protect the Cablr community. Checkr.com’s privacy policy can be viewed at https://checkr.com/privacy-policy

Payment Information. To make sure Drivers get paid, we keep information about Drivers’ bank routing numbers, tax information, and any other payment information provided by Drivers.

B. Information We Collect When You Use the Cablr Platform

Location Information. Cablr is all about connecting Drivers and Riders. To do this, we need to know where you are. When you open Cablr on your mobile device, we receive your location. We may also collect the precise location of your device when the app is running in the foreground or background. If you label certain locations, such as “home” and “work,” we receive that information, too.

Your location information is necessary for things like matching Riders with nearby Drivers, determining drop off and pick up locations, and suggesting destinations based on previous trips. In addition to the reasons described above, Drivers’ location information and distance travelled is necessary for calculating charges and insurance for Cablr rides. If you give us permission through your device settings or Cablr app, we may collect your location while the app is off to identify promotions or service updates in your area.

Device Information. Cablr receives information from Users’ devices, including IP address, web browser type, mobile operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens. We collect mobile sensor data from Drivers’ devices (such as speed, direction, height, acceleration or deceleration) to improve location accuracy and analyze usage patterns.

Usage Information. To help us understand how you use the Cablr Platform and to help us improve it, we automatically receive information about your interactions with the Cablr Platform, like the pages or other content you view, your actions within the Cablr app, and the dates and times of your visits.

Call and Text Information. We work with a third-party partner plivo.com to facilitate phone calls and text messages between Riders and Drivers who have been connected for a ride. We receive information about these communications including the date and time of the call or SMS message, the parties’ phone numbers, and the content of any SMS messages. For security purposes, we may also monitor and/or record the contents of phone calls made on the Cablr Platform, such as those between Riders and Drivers. You will be given notice that your call may be recorded, and by proceeding you agree to allow Cablr to monitor and/or record your call. plivo.com’s privacy policy can be viewed at www.plivo.com/legal/privacy/ .

User Feedback. At Cablr, we want to make sure Users are always enjoying great rides. Riders and Drivers may rate and review each other at the end of every ride. We receive information about ratings and reviews and, as we explain below, give Riders information about Drivers’ ratings and reviews and vice versa.

Address Book Contacts. If you permit Cablr to access the address book on your device through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate invitations and social interactions that you initiate through our Platform and for other purposes described in this privacy policy or at the time of consent or collection.

Information from Cookies and Similar Technologies. We collect information through the use of “cookies”, tracking pixels, and similar technologies to understand how you navigate through the Cablr Platform and interact with Cablr advertisements, to learn what content is popular, and to save your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Cablr Platform. You should consult your web browser(s) to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may be missing out on certain features of the Cablr Platform.

C. Information We Collect from Third Parties

Third Party Services. If you choose to register for Cablr or otherwise link your Cablr account with a third party’s service, we may receive the same type of information we collect from you (described above) directly from those services.

Third Party Partners. We may receive additional information about you, such as demographic data, payment information, or fraud detection information, from third party partners and combine it with other information that we have about you.

Partner Programs. If your company, university, or organization participates in one of our Partner programs such as Cablr Auto Dealerships, we may receive information about you, such as your email address, from your participating organization. We also may give your participating organization the opportunity to request a ride on your behalf, in which case they may provide us with your name, phone number, and the pickup and drop off location for your ride.

Background Information on Drivers. Cablr works with third party partners to perform driving record and criminal background checks on Drivers, and we receive information from them such as publicly available information about a Driver’s driving record or criminal history.

4. How We Use the Information We Collect

We use the information we collect from all Users to:

  • Connect Riders with Drivers;
  • Provide, improve, expand, and promote the Cablr Platform;
  • Analyze how the Cablr community uses the Cablr Platform;
  • Communicate with you, either directly or through one of our partners, including for marketing and promotional purposes;
  • Personalize the Cablr experience for you and your friends and contacts;
  • Send you text messages and push notifications;
  • Facilitate transactions and payments;
  • Provide you with customer support;
  • Find and prevent fraud; and
  • Respond to trust and safety issues that may arise, including auto incidents, disputes between Riders and Drivers, and requests from government authorities.

Additionally, we use the information we collect from Drivers for the following purposes related to driving on the Cablr Platform:

  • Sending emails and text messages to Drivers who have started the driver application process regarding the status of their application;
  • Determining a Driver’s eligibility to drive for Cablr
  • Notifying Drivers about ride demand, pricing and service updates; and
  • Calculating and providing Cablr’s auto insurance policy and analyzing usage patterns for safety and insurance purposes.

5. How We Share the Information We Collect

A. Sharing Between Users

Sharing between Riders and Drivers. Riders and Drivers that have been matched for a ride are able to see basic information about each other, such as names, photo, ratings, and any information they have added to their Profiles. Drivers see the pick-up location that the Rider has provided. Riders see a Driver’s vehicle information and real-time location as the Driver approaches the pick-up location. Riders’ ratings of Drivers are shared with Drivers on a weekly basis. We de-identify the ratings and feedback, but we can’t rule out that a driver may be able to identify the Rider that provided the rating or feedback.

Sharing Information With Other Riders. Information is also shared when Riders split a fare among themselves or when using Cablr Touch. Cablr Touch is a system that provides the opportunity to monitor loved ones during their ride even when they are using their own separate Cablr account. Cablr may share your ETA, location and your trip information with a friend or family member at your request, when you use Cablr Touch.

We do not share your actual phone number or other contact information with other Users. If you report a lost or found item to us, we will seek to connect you with the relevant Rider or Driver, including sharing actual contact information with your permission.

B. Sharing Between Cablr and Third Parties

API and Integration Partners. If you connect to the Cablr Platform through an integration with a third party service, we may share information about your use of the Cablr Platform with that third party. We may share your information with our third party partners in order to receive additional information about you. We may also share your information with third party partners to create offers that may be of interest to you.

Third Party Services. The Cablr Platform may allow you to connect with other websites, products, or services that we don’t have control over (for example, we may give you the ability to order a drink for your trip from a restaurant from within the Cablr app). If you use these services, we will provide the third party with information about you to allow them to provide the service to you (for example, we would give the restaurant your name, phone number and address to drop off the food). We can’t speak to the privacy practices of these third parties, and we encourage you to read their privacy policies before deciding whether to use their services.

Service Providers. We work with third party service providers to perform services on our behalf, and we may share your information with such service providers to help us provide the Cablr Platform, including all of the things described in Section 3 above.

Partner or Broker Programs. If you participate in a partner or broker program and charge a ride to your organization’s billing method or credits, we will provide your organization’s account holder with information about your use of the Cablr Platform, including ride details such as date, time, charge, and pick up and drop off locations.

Other Sharing. We may share your information with third parties in the following cases:

  • While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets;
  • If a government authority requests information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process;
  • With law enforcement officials, government authorities, or third parties if we think doing so is necessary to protect the rights, property, or safety of the Cablr community, Cablr, or the public.
  • To comply with a legal requirement or process, including but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures.
  • If you signed up for a promotion with another User’s referral or promotion code, with your referrer to let them know about your redemption of or qualification for the promotion;
  • With our insurance partners to help determine and provide relevant coverage in the event of an incident;
  • To provide information about the use of the Cablr Platform to potential business partners in aggregated or de-identified form that can’t reasonably be used to identify you; and
  • Whenever you consent to the sharing.

6. Cookies

Cablr, along with our affiliates, third parties, and other partners use cookies and other identification technologies on our websites, mobile applications, email communications, and other online services for a number of purposes, including: authenticating users, remembering user preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our Services.

Cookies and Related Technologies Overview

Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements that are used to remember your browser or device during and across website visits. At Cablr, we use Firebase analytics and you can find their policy here: https://firebase.google.com/policies/analytics

When visiting the website, Cablr will set the required cookies, which are technically necessary, to improve the functionality or make the use of Cablr services more user-friendly (e.g. language, login status). Cablr also uses its own cookies, as far as possible in order to analyze and improve the usage of Cablr services, to detect and remedy interruptions and technical or process-related problems and to prevent illegal usage of Cablr services (e.g. fraudulent booking, cyber attacks).

Additionally, Cablr may use its own cookies, pixels or similar technologies or those from advertising partners (e.g. search engine providers, advertising networks or distribution partners) in order to improve Cablr services or to measure, evaluate, design and improve advertising measures. Cablr uses different analysis tools in this regard. As far as possible, Cablr seeks to carry the evaluation out in a manner that anonymous.

When registering as a user of Cablr’s services, you agree that we may process, in personalized form, the data collected by means of the cookies and similar technologies mentioned in the Cookie Policy for the mentioned purposes in connection with your account. This consent may be revoked at any time without any additional costs and with effect for the future.

You may prevent the storage of cookies at any time using your browser settings and delete any cookies present. However, this may mean that some functions of Cablr’s services may not be available or available only to a limited extent. The storage duration is different depending on the cookie and can be inspected in your browser.

7. Your Choices

Email Subscriptions. You can always unsubscribe from our commercial or promotional emails but we will still send you transactional and relational emails about your account use of the Cablr Platform.

Push Notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Cablr Platform (such as receiving a notification that your ride has arrived).

Profile Information. While your name will always be shared with Drivers, you can delete any additional information that you added to your Profile at any time if you don’t want Drivers to see it. Riders will always be able to see Drivers’ names, rating, profile photos, and vehicle information.

Location Information. While you can prevent your device from sharing location information at any time through your Device’s operating system settings, Rider and Driver location is core to the Cablr Platform. If you choose to prevent your device from sharing location information, you can still have the option of providing your location information manually on your device.

Editing and Accessing Your Information . You can review and edit certain account information by logging in to your account settings and profile (Drivers may edit additional information through the Driver portal). If would like to terminate your Cablr account, please contact us through our Help Center with your request. If you choose to terminate your account, we will deactivate it for you but may retain information from your account for a certain period of time and disclose it in a manner consistent with our practices under this Privacy Policy for accounts that are not closed. We also may retain information from your account to collect any fees owed, resolve disputes, troubleshoot problems, analyze usage of the Cablr Platform, assist with any investigations, prevent fraud, enforce our Terms of Service, or take other actions as required or permitted by law.

8. Other

Data Security. We are committed to protecting the data of the Cablr community. Even though we take reasonable precautions to protect your data, no security measures can be 100% secure, and we cannot guarantee the security of your data.

Children’s Privacy. Cablr is not directed to children, and we don’t knowingly collect personal information from children under 13. If we find out that a child under 13 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 13 has given us personal information, please contact us at our Help Center.

Changes to Our Privacy Policy. We may make changes to this Privacy Policy from time to time. If we make any material changes, we will let you know through the Cablr Platform, by email, or other communication. We encourage you to read this Privacy Policy periodically to stay up-to-date about our privacy practices. As long as you use the Cablr Platform, you are agreeing to this Privacy Policy and any updates we make to it.

Contact Information. Feel free to contact us at any time with any questions or comments about this Privacy Policy, your personal information, our use and sharing practices, or your consent choices by contacting our Help Center.