December 1, 2019
This document contains the Privacy Statement of Clutch Technologies and its subsidiaries (collectively, “we,” “us,” or “our”), a Cox Automotive, Inc. company. We respect your privacy and are committed to protecting the personal information we hold about you. This policy explains what information we collect about you, how we collect it, the measures we take to keep your information secure and the uses we make of it. We also explain the options you have regarding your personal information. When you request services from us, access our websites, utilize our mobile "apps" or otherwise interact with us, for example, but without limitation, through our service centers, our in‑vehicle or in‑equipment technology, our official corporate pages on third party social networks (such as Facebook) or the "apps" on those pages, you consent to our collection, retention and use of your personal information in the manner described in this policy and accept the risks outlined in the Security Measures section below.
What We Collect: We collect the personal information we need to provide the services you request from us, for our operational and marketing uses listed in this policy and for such other purposes as you authorize. By subscribing to our services and providing personal information to us, you consent to our use and disclosure of your information for the purposes listed in this policy.
Sources: Most of the information we collect comes directly from you, through various channels including our website, computer systems and in‑vehicle and in‑equipment technology, and from companies involved in our provision of services to you, including our licensees and third party providers.
Storage: We generally retain personal information about our subscribers for as long as we believe appropriate for the purposes for which it was collected.
Security Measures: We aim to maintain appropriate physical, procedural and electronic safeguards to protect your personal information.
Access: You may access and review the personal information we retain about you and correct any factual errors.
Contact Us: We hope this policy answers your questions about our collection and use of your personal information. If you have any questions, please contact us by following the instructions in the Contact Us section below.
Changes: We may change this policy from time to time. The date at the top of this document indicates the last time changes were made to this document.
Region-specific policy supplements: Customers in certain geographic regions are subject to differing privacy policies. If you reside in such a region, the region-specific supplemental policy overrides the statements made in the body of this policy. The supplement related to the European Union can be found here. The supplement related to California can be found here. If you are unsure if your region uses a region-specific policy, please contact us using the information in the “Contact Us” section below or contact your local governmental authority.
Scope of Policy
This policy covers the personal information we collect about you in connection with our vehicle subscription platform and services that identify you as an individual. It does not address data that does not personally identify you as an individual, for example, but without limitation, aggregated anonymous data, IP addresses, computer operating systems, personal preferences, vehicle identification numbers, etc. We are free to use information that does not identify you as an individual as we wish. This policy does not apply to information collected by third party social networks (such as Facebook), mobile device manufacturers, third party "mobile apps", wireless service providers, internet service providers or the operators of any networks through which you may interact with us and we expressly disclaim any responsibility for the data collection, privacy or data security practices of those entities. With regard to pages on third party social networks, this policy only applies to personal information we collect through our pages (those with a direct link to this policy) and does not apply to any "unofficial" pages or pages of our affiliates or licensees. Our websites are not directed to individuals under the age of 13, and we do not knowingly obtain personal data from such individuals.
When you request services from us, operate a vehicle or equipment with in‑vehicle or in‑equipment technology, access our websites, utilize our mobile "apps" or otherwise interact with us, for example, but without limitation, through our kiosks, our official corporate pages on third party social networks (such as Facebook) or the "apps" on those pages, you consent to our collection, retention and use of your personal data in the manner described in this policy and accept the risks outlined in the Security Measures section.
Who We Are
We are Clutch Technologies, LLC, a Cox Automotive, Inc. company, a U.S. company based in Atlanta, Georgia, which, together with our subsidiary companies, provides and supports vehicle subscription services across the United States. All references in this policy to "we", "us" and "our" are to us and our subsidiaries. We operate a network of licensees in the provision of our services and are affiliated with many other sister companies through common ownership. As our licensees and sister companies are independent companies, they are not owned or controlled by us and are not covered by this policy, although they may have their own privacy policies to govern the personal information they collect. We are not responsible for the privacy practices of our licensees, sister companies or any other third party.
Personal information means information that identifies you as an individual, or that we can combine with readily available information to identify you as an individual.
Personal Information We Collect and How We Use It
The principal purposes for which we collect and store your personal and financial information are to process your application and subscription agreement, allow you to reserve and use our vehicles and services, authorize payment, bill you, respond to your inquiries, improve our products and services and maintain your account with us. We collect a range of information about you from a variety of sources for the purposes of our business. The examples we provide throughout this policy are illustrative rather than a complete list of our practices.
When you visit our websites or apps, our servers might automatically log certain information about your use of our websites, such as your IP address, your browser type, operating system, browser language and service provider. We also collect information about your activities on our websites and apps, such as the pages you visit or the ads or links you click on. The first time you visit our website, we may assign you a unique identifier, which is stored in one or more cookies on your computer's hard drive. These cookies help us distinguish new visitors from returning visitors and enable us to measure the effectiveness of content on the website and refine and tailor content to suit our visitors' interests. If you have subscribed for our services or provided other personal information about yourself (for example, if you send us an email), your cookie ID can be associated with you personally. When you are signed in to our mobile apps, you will be identified to us by your account email and/or phone number.
We collect information that you voluntarily submit to us, such as:
- Name, address and contact details, including telephone and mobile number, and email;
- Date and place of birth, passport number and driver's license number and a copy of your driver's license;
- Employer(s) name and address;
- Credit card information;
- Driving record and accident history;
- Location data such as geographic location of electronic devices used to contact us or to access our mobile "apps" or of the vehicle you are using;
- Information regarding the vehicles you subscribe for and use, and the operation of our vehicles during your subscription period;
- Charges you incur and other information relating to your transactions;
- Information transmitted by your computer's browser software; and
- Information about your credit history or other publicly available information about you from consumer reporting agencies.
Your telephone calls and email correspondence with us may be recorded or monitored for quality control, training and similar purposes. By using these communication methods you are consenting to the recording or monitoring of your calls and emails with us and to our use of the information you provide us for the purposes described in this policy.
If you subscribe with us, we collect personal and financial information as you proceed through the stages of our online application, subscription agreement and reservation process. In addition to your name and contact information, we will also collect your driver's license number, the jurisdiction in which you are registered, credit card or other payment information, and other information. We may also collect information such as your driving record from regulatory bodies where you live, and from third parties. This information is used to process your subscription and, if you are approved, for the purposes described below.
If you use our vehicle subscription platform and services, we collect information about the vehicles' use and your use of our services. This may include details about your reservations, the dates, times and locations of use, mileage, driving performance, accidents and other data. We use this information to bill you, respond to your inquiries, ascertain whether you are in compliance with our policies and rules, provide and improve our products and services and maintain your account with us, and to provide content and offers that we think may be of interest to you. From time to time we will send newsletter emails. To unsubscribe from our newsletters please use the opt out in the email body.
Our vehicles may be equipped with vehicle tracking and other technology. We implement Global Positioning Systems (GPS), a network of satellites that allows us to determine the location of vehicles used by our members. This information is transmitted to us and can be stored for extended periods. We use this information for a variety of important purposes. For example, we use GPS data to help find vehicles used on our platform, to provide roadside assistance, to ensure that a vehicle is available at the place and time you have reserved, to ensure that the vehicle is not driven to unauthorized locations and to locate a lost or stolen vehicle. We also maintain in‑vehicle and in‑equipment technologies to track and monitor performance of vehicles used on our platform and to assist us with ensuring that these vehicles are used only in accordance with applicable laws and our rules and policies. Disabling, disconnecting or destroying any such technology device or equipment is strictly prohibited.
We also gather personal information about you from a variety of other sources, including:
Transactions you complete with us and our vendors and licensees, including options you take, charges you incur and any incidents or accidents that may occur;
To the extent you have made such information available, from third party social networks;
Consumer and other reporting agencies; and
Other companies that have business relationships with us, such as our licensees, affiliates and business partners, including roadside assistance and other service providers and insurance companies.
Where We Hold Personal Information
We utilize servers in various locations in the United States of America. If you are accustomed to other countries’ privacy laws, please note that the laws governing the processing of personal information in the United States of America differ from laws in the United Kingdom, Canada or other nations. By subscribing for and using our vehicles and services, you consent to the transfer of your personal and financial information from your country of residence to the United States for the purposes described in this policy. Data provided by individuals residing in regions governed by the General Data Protection Regulation (GDPR) Policy have specific regulations that differ and can be referenced here.
We work hard to ensure that the personal data we retain about you is stored securely and that the information provided to us is as accurate, current and complete as necessary for the purposes for which we use it. We generally retain personal data about our subscribers for as long as we believe appropriate for the purposes for which it was collected or as otherwise required by applicable law.
Where We Can Send Your Personal Information
Except as described in this policy, we will not share your personal information with third parties outside our company group unless it is necessary to provide our services, verify information you or your approved secondary drivers provide to us, fulfill a transaction you have requested, or in other circumstances with your consent. We do however disclose your personal information within our related company group and to contractors, advisors, consultants and service providers acting on our behalf or under our instructions, including for purposes relating to the operation, maintenance, administration, improvement, and oversight of our services, websites and advertising services, or to fulfill your requests for information or service.
If you subscribe for our vehicles and services, some of the information you supply must necessarily be shared with regulatory bodies where you live and/or service providers we utilize to obtain your driving record from such regulatory bodies. In addition, if you are associated or affiliated with another, primary account (for example, if you are an associate member or affiliated with a business's or university's account), the primary account holder or administrator of that account may have access to limited information regarding your use of our services.
We may disclose your personal information in connection with a corporate transaction, proceeding, or reorganization involving the business activities for which the information is maintained. In the event that ownership of our business was to change as a result of a merger, acquisition, sale of assets or transfer to another company, your personal information may be transferred. If such a transfer results in a material change in the way your personal information is used, we will provide notice about the choices you have to decline to permit such a transfer.
We may disclose your personal information, including location/GPS data and data gathered from in‑vehicle and in‑equipment technologies, in response to legal process (for example, a court order, search warrant or subpoena) or requests from law enforcement authorities; in other circumstances in which we believe our services, our vehicles or our website are being or has been used in violation of applicable law or otherwise in the commission of a crime; when we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; or when necessary to protect our rights or property (or those of third parties).
To Provide You Services
We will share your personal information among our employees and affiliated companies and employees, our representatives and agents, our licensees and vendors, and other companies that we engage in business with, to provide services to you, including to:
- Fulfill your vehicle subscription and make your reservations for alternate vehicles;
- Process and/or confirm your transactions;
- Provide you with enhanced services, such as services provided in connection with our membership programs and similar services;
- Provide you services in connection with your use of our vehicles; such as navigation assistance or roadside emergency assistance;
- Provide you services in connection with your use of our vehicles; such as navigation assistance or roadside emergency assistance;
- Provide you with customer assistance;
- Bill and collect amounts owed in connection with your subscription and use of our vehicles and services; and
- For customer satisfaction and market research purposes to help us improve our services.
- To Communicate With You
We may use your personal information to communicate with you, including with regards to:
- Your subscription or any other transaction with us;
- Your status in our membership program(s); or
- Changes to the terms or features of your subscription or any policy or rule related thereto.
By subscribing for or using our vehicles and services, or by contacting us in any way, you give us your consent to call you or send text messages to your mobile telephone/device. You also consent to our use of auto-dialers and pre-recorded messages in connection with any such telephone call or text message, including calls or texts to mobile telephone numbers. We will not charge you for such calls or texts, although you may be charged by your mobile service provider to which you subscribe.
Disclosure To Companies You Use
We will also share your information with companies you use in connection with your subscription, including:
- Your credit card provider and other companies that process your charges;
- Any company or organization that is paying all or part of your charges
- Any service provider you use, such as a repair provider, insurance company or other vendor or provider related to any aspect of your subscription or use of our vehicles.
Protective and Legal Uses
We may use, share and disclose your personal information for legal reasons as we believe necessary or appropriate, including:
- under applicable law, including laws outside your state or country of residence;
- to process, handle or otherwise respond to claims for damages, including claims or demands for bodily injury or property damage;
- to enforce our policies and rules and the terms and conditions of your subscription;
- to recover our vehicles, equipment or any monies due, such as through debt collection agencies;
- to comply with legal process and to respond to requests from public and government authorities;
- to protect our operations, rights, privacy, safety or property, and/or that of our subsidiaries, you or others
- to allow us to pursue available remedies or limit the damages that we may sustain.
We may use personal information to present offers to you on our behalf and on behalf of business partners, but we do not share information that personally identifies you with those parties. If you do not want us to send you promotional emails, please adjust your settings or utilize our "unsubscribe" feature.
Cookies are text files that are placed in your computer's browser, and that can be used to help recognize you on our websites. Web beacons are small pieces of code placed on web pages that can be used, among other things, to count the users who visit that web page, or to deliver a cookie to the browser of a user viewing that page. Many websites, including our website, also may use Flash cookies that are similar to regular browser cookies. You can control browser cookies through your browser's settings. You may delete cookies or set your browser to alert you when cookies are being sent. If you reject all browser or flash cookies, however, some areas of our sites may not function.
Review and Correct Your Personal Information
We are committed to providing you with reasonable and practical access to your information to allow you the opportunity to identify inaccuracies. If you are a subscriber, you can review and correct personal information by navigating to the relevant section of our app or by contacting us. If you would like to access, delete and/or correct other personal information, please contact us in one of the ways provided below and we will respond to your request within 30 days. If we are informed of the inaccuracy we will make the appropriate corrections.
We will retain your information for as long as your account is active or as needed to provide you services. Please contact us if you wish to cancel your account or request that we no longer use your information to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We take reasonable measures to protect against the loss, misuse and unauthorized access or disclosure, alteration and destruction of your personal data by aiming to maintain appropriate physical, procedural and electronic safeguards to protect your personal data, including:
- Restricting access to personal data to our employees on a "need to know" basis
- Enforcing policies and procedures for our employees in their handling of personal data
- Using technologies designed to safeguard data during its transmission, such as SSL encryption for the data you provide on our websites and apps. In particular, we adhere to the appropriate standards for PCI compliance.
We try to strike a balance between the security of your information and your convenience. As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative.
For example, but not limitation, we may send you an e-mail or a text message in unencrypted form (i.e., instantly readable) because many of our customers are unable to access encrypted (i.e., coded) e-mail or messages. This means that our message, if misrouted or intercepted, could be read more easily than encrypted messages. For this reason, please do not include confidential information, such as your credit card number, in any e-mail or text you send to us or on any posting you make to a public area of a third party social network page, especially since any such posting immediately becomes public.
Destroying confidential personal data after it is no longer needed.
We have established safeguards to help prevent unauthorized access to or misuse of your personal information, but cannot guarantee that your personally identifiable information will never be disclosed in a manner inconsistent with this policy (for example, as a result of unauthorized acts by third parties that violate applicable law or our policies and those of our affiliated providers). We may use a password to help verify your identity before granting access or making corrections to any of your personal information. It is your responsibility to safeguard your password, which you should never disclose to a third party. If you contact us by phone, we will ask you to verify certain information related to your account before providing any access to personal information.
Changes to Our Policy
We may change this policy from time to time, so it is advisable to review it frequently. Changes to this policy will be announced on our website or through similar means and all amended terms shall automatically be automatically effective when posted (or as indicated in our posts).
Clutch Technologies, LLC
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, please do not hesitate to contact us at:
Attn: Privacy and Compliance
Clutch Technologies, LLC
3535 Piedmont Road NE
Atlanta, GA 30305