This website is operated by Cleared to Drive Services LLC, a New York limited liability company (hereinafter, “Cleared to Drive”, “We”, or “Us”). This Privacy Policy (the “Privacy Policy”) governs your access to the Cleared to Drive website: https://www.clearedtodrive.com and any other web services owned, controlled, or offered by Cleared to Drive now or in the future (all collectively referred to as, the “Services”). The term “You” or “User” shall refer to any individual that views, uses, accesses, browses or submits any content or material to the Services.
Since we may gather certain types of information about our users, we feel you should fully understand our policy and the terms and conditions surrounding the capture and use of that information. This Privacy Policy discloses what information we gather and how we use it. The private information you provide on the Services will be used only for its intended purpose.
BY VISITING, SIGNING UP, USING, BROWSING, OR ACCESSING THE SERVICES, YOU CONSENT TO THE DATA PRACTICES DESCRIBED IN THIS STATEMENT. IF YOU DO NOT AGREE WITH OUR PRIVACY PRACTICES, DO NOT USE THE SERVICES.
1.INFORMATION WE COLLECT
We may collect certain information, including Personal Health Information, Personal Information and Non-Personal Information, when you interact with us and the Services, for example when you:
2.PERSONAL HEALTH INFORMATION (PHI) and HIPAA
Certain demographic, health and/or health-related information that Cleared to Drive collects about its Users as part of providing the Services to Providers may be considered “Protected Health Information” or “PHI” under the Health Insurance Portability and Accountability Act (“HIPAA”). Specifically, the results of your visual acuity test may be considered PHI. However, Personal Information that you provide to Cleared to Drive outside of the foregoing context is not PHI. For example, when you provide information directly to us, such as when creating an account or using our interactive tools and services, or when you voluntarily provide information in free-form text boxes through the Services or through responses to surveys and questionnaires, or when you send us an email or otherwise contact us, that information is not PHI. HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. Cleared to Drive may only use and disclose PHI in the ways permitted by law.
3.PERSONAL INFORMATION
“Personal Information” means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you. As a general rule, we do not collect Personal Information about you when you visit and/or use the Services, unless you choose to provide such information to us. Submitting Personal Information through the Services is voluntary. By doing so, you are giving us your permission to use the information for the stated purpose.
(a) LEGAL BASIS FOR COLLECTING YOUR PERSONAL INFORMATION
We collect, process and use your Personal Information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:
With Your Consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time.
When Performing This Agreement: We collect and process your Personal Information in order to provide you with the Services, following your acceptance of this Privacy Policy; to maintain and improve our Services; to develop new services and features for our Users; and to personalize the Services in order for you to get a better user experience.
Legitimate Interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfill our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Terms and our billing process.
(b) INFORMATION WE COLLECT AND HOW WE COLLECT INFORMATION
Through the Services, we may collect information that can identify you when you voluntarily submit it to us. Your Personal Information may include your:
(c) STORAGE OF PERSONAL INFORMATION
We will take reasonable precautions, as well as physical, technical, and organizational measures in accordance with industry standards, as described herein, to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Computer safeguards, such as firewalls and data encryption, may be used to protect your information. We authorize access to your information only for those employees or agents who require it to fulfill their job responsibilities and these individuals are required to treat this information as confidential.
However, the security of information on or transmitted via the Internet cannot be guaranteed. Unauthorized entry of use, hardware or software failures, and other factors may compromise the security of your Personal Information. All information you send to us electronically or through email is at your own risk, as the transmission of information via the Internet is not completely secure.
4.NON-PERSONAL INFORMATION
We collect and temporarily store certain information about your usage of the Services. Non-Personal Information means information that alone cannot identify you, including data such as cookies, pixel tags, web beacons, and device information. The information includes, without limitation:
Device Data: We may collect information such as: the type of computer and/or mobile device you use; the unique device ID of your computer and/or mobile device; the IP address of your computer and/or mobile device; the operating system of your computer and/or mobile device; and the type of Internet browsers of your computer and/or mobile device.
Usage Details: When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the App.
Location Information: When you first visit or use the Services we may request permission to collect and use your device’s precise geolocation. You can opt not to permit the collection of this information, but you may not be able to use the Services provided by Cleared to Drive without access to your location. We need your location information in order to provide our Services. You can control how and whether we collect your precise geolocation information through your device’s settings.
We may use information that is neither Personal Information nor PHI (including non-PHI Personal Information that has been de-identified and/or aggregated) to better understand who uses our Services and how we can deliver a better experience, or otherwise at our discretion.
If you do not want us to collect this information, you may either change your device’s privacy settings or DO NOT ACCESS OR USE THE SERVICES.
5.INFORMATION COLLECTION TECHNOLOGIES
The technologies we use for automatic information collection may include:
Cookies (or mobile cookies): We may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. The purpose of a cookie is to tell the web server that you have returned to a specific page and to store information to offer a better experience to you. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Services.
Local Storage: We may use local storage to make your experience more seamless. Local storage is a file created by a website in your device data that persists even if you refresh the page or close the browser. Local storage may be disabled by accessing the cookie and data storage settings on your browser.
Retargeting/Advertising Cookies: Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
Web Beacons: The Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Services statistics.
Social Ad Platforms: We may also use Google Analytics, Facebook, Instagram, Twitter, and similar marketing services functionality of re-marketing through their tracking cookies and pixel-based retargeting services. This means that if you provided your consent to Google, Facebook, Instagram or Twitter (the “Social Ad Platforms”) to be provided with personalized commercial offers, you may be served with ads (including advertisements of third parties) based on your access to the Services, outside of the Services and across the internet. In such event, the Social Ad Platforms, will place cookies on your web browser and use such cookies to serve you ads based on past visits to our Services.
Please visit the Social Ad Platforms Privacy policy to find out how they use such information:
Facebook: https://www.facebook.com/about/privacy/
Instagram: https://help.instagram.com/478880589321969/
Mobile Device Identifiers. Mobile device identifiers help Cleared to Drive learn more about our users’ demographics and Internet behaviors. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location, and tracking data, including without limitation IP address, domain server, type of device(s) used to access the Services, web browser(s) used to access the Services, referring webpage or other source through which you accessed the Services, and other statistics and information associated with the interaction between your browser or device and the Services).
Cross Device Matching. To determine if users have interacted with content across multiple devices and to match such devices, we may work with partners who analyze device activity data and/or rely on your information (including demographic, geographic, and interest-based data). To supplement this analysis, we may also provide de-identified data to these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of Services across devices.
6.CHANGING YOUR DATA COLLECTION SETTINGS
We strive to provide you with choices regarding the Personal Information you provide to us. You may need to adjust the settings on your computer and/or device to restrict the collection of information by the Services, but this may prevent you from accessing all of the features of the Services.
Tracking Technologies: You may be able to set your browser or device to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.
Location Information: You can choose whether or not to allow the Services to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts or all of the Services may be inaccessible or not function properly.
Social Ad Platforms: If you wish to opt-out of re-targeting and tracking functionality of the Social Ad Platforms, you may do so through each platform directly. PLEASE NOTE that these tracking and targeting by Social Ad Platforms, is provided pursuant to your engagement with the Social Ad Platforms and the actual nature and scope of Personal Information collection and processing performed by such Social Ad Platforms may not be fully known to us. If you would like to learn more or make further inquiries with respect to such nature or scope, please refer to each Social Ad Platforms directly.
You can decide whether or not to accept Cookies through your Internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. You can also delete all Cookies that are already on your computer. Although you are not required to accept Cleared to Drive’s Cookies, if you block, reject, or delete them, you may have to manually adjust some preferences every time you visit a site and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org.
In addition, if you wish not to receive ads from us based on information we obtain from use of cookies and pixel tags, please send us an e-mail to support@clearedtodrive.com and we will respond within a reasonable timeframe and in accordance with applicable laws.
7.THIRD-PARTY AUTOMATIC INFORMATION COLLECTION
When you use the Services or its contents, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different websites, mobile applications and other online sites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
8.HOW WE USE YOUR INFORMATION
We use information collected as described in this Privacy Policy for the following:
(1) Operation
(2) Usage and Analytics
(3) Location: We will use location data for the following reasons:
9.HOW WE DISCLOSE YOUR PERSONAL INFORMATION
The Personal Information you provide to us, whether voluntarily or automatically, may be used and disclosed without limitations, in the following instances:
10.HOW WE DISCLOSE YOUR NON-PERSONAL INFORMATION
We may also disclose Non-Personal Information:
11.HOW TO ACCESS, UPDATE, WITHDRAW CONSENT OR DELETE YOUR INFORMATION
If the laws applicable to you grant you such rights, you may ask to access, correct, or delete your Personal Information that is stored in our systems or that we otherwise control. You may also ask for our confirmation as to whether or not we process your Personal Information or ask to withdraw any consent you have previously provided to Cleared to Drive in connection with our use and processing of your Personal Information. Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any Personal Information the accuracy of which you contest while we verify the status of that data.
If you wish to exercise any of these rights or withdraw your consent, please contact us at: support@clearedtodrive.com. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates, or as we are otherwise permitted under such law applicable to you. While we strive to honor all reasonable requests, please be aware that we back up the data to prevent accidental or malicious destruction of your information. Information on backup servers may take some time to be completely deleted from the system. If you request that we remove you from our system and delete all your information, please note that you may still receive materials while your request is being processed.
If you request that your information be deleted, we will keep your information for a period of time in order to deter fraud. However, if you request to delete your information, your Personal Information will not be used by us or our third- party providers for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.
12.SECURITY AND DATA RETENTION
The security of your Personal Information is important to us. We seek to protect your Personal Information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Information and how we are processing that data. We endeavor to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and in storage. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Information. We store and process your information on our servers in the United States and abroad. We maintain what we consider industry standard backup and archival systems. Although we work to protect the security of the data that we hold in our records, for example, by making good faith efforts to store Personal Information in a secure operating environment that is not open to the public, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot and do not guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.
If at any time during or after our relationship we believe that the security of your Personal Information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at support@clearedtodrive.com. Please include your address when you submit your request. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.
We retain Personal Information about you consistent with all internal policies and procedures. We may retain Personal Information to comply with our legal obligations, resolve disputes or collect fees owed, or as is otherwise permitted or required by our data retention policies and procedures.
13.COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS
We represent and warrant that we will comply with all applicable laws, rules, regulations, directives and guidelines regarding the collection, use and disclosure of data collected from or about Users or specific devices which apply to the services utilized hereunder (collectively, the “Rules”). The term “Rules” shall include, without limitation, (i) United States Federal Trade Commission laws regarding the collection, use and disclosure of data from or about users and/or specific devices; (ii) the Children’s Privacy Protection Act of 1998 (COPPA); (iii) The California Consumer Privacy Act of 2018 (“CCPA”) and (iv) if applicable, the Rules of any other jurisdiction, including and European Union General Data Protection Regulation (“EU GDPR”), rules, regulations and/or directives promulgated by a pertinent Data Protection Act, and all amendments and updates to them or regulations as replaced or superseded from time to time.
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. If you have any questions about this section or whether any of the following applies to you, please contact us at support@clearedtodrive.com and indicate “California Rights” in the subject line of your communication.
14.CHILDREN’S PRIVACY
The Services are not directed to or intended for use by children under 13 years of age. If you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Information. By accessing, using and/or submitting information to or through the Services, you represent that you are not under the age of 13. As noted in the Terms and Conditions, we do not knowingly collect or solicit Personal Information from children under the age of 13. If we learn that we have received any Personal Information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. We will then subsequently delete that child’s Personal Information. If you believe that a child under 13 may have provided us with Personal Information, please contact us at support@clearedtodrive.com.
15.UPDATES TO THIS POLICY
We reserve the right to change, modify, update, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. If you opt out of receiving communications, you may not receive certain notifications, however, they will still govern your use of the Services, and you are responsible for proactively checking for any changes. We encourage you to check this Privacy Policy frequently to stay up to date on any changes. You can determine if changes have been made by checking the effective date on the Privacy Policy. Continued use of the Services after the effective date of any change in this Privacy Policy will constitute acceptance of such changes and it will signify that you agree to abide by and be bound by the modified Privacy Policy.
16.CONTACT US
If you have questions, comments, or concerns regarding this Privacy Policy, please contact us and we will respond to your request within a reasonable timeframe. Please include the following information in your request: (a) Your name; (b) Your contact information, including phone number and email address; and (c) The precise nature of your request, inquiry, or complaint. You may contact us at:
Cleared to Drive Services LLC
support@clearedtodrive.com
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