PRIVACY POLICY

Last updated: February 14, 2020

PSterling, LLC and its affiliates (the “Company,” “us,” our” or “we”) is committed to protecting your privacy.  Our privacy policy, which applies to all users of our websites (https://psterling.com/; https://freewheel.xyz) (the “Websites”), the Company’s mobile device application (“App”) and any and all services provided by the Company through the Website and/or App (“Service”), is designed to explain the information we collect and how we use it to provide our services and give users a better experience (“Privacy Policy”).  Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms and Conditions located at (https://psterling.com/terms-conditions/) (the “Terms and Conditions”).  This Privacy Policy is part of, and incorporated into, the Terms and Conditions.

By accessing and using the Website, App and/or Service, you consent to our collection, storage, use and disclosure of your personal information and other information as described in this Privacy Policy.  

1. Types of Information We Collect

We may collect both “Personal Information” and “Anonymous Information” about you when you use the Website, App and/or Service. Personal Information is information that can be used to contact or identify you, such as your full name, email address, phone number, payment method and profile picture, as well as information that is linked to such information. “Anonymous Information” is information that cannot be used to contact or identify you and is not linked to information that can be used to do so.  It includes passively collected information about your activities on the Service, such as usage data, to the extent that information is not linked to your Personal Information.

You can access and browse certain portions of the Website and download the App without disclosing your Personal Information, although, like most website and mobile app providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system.  Please note that you can choose not to provide us with certain information, but this will limit the features of the Service you can access and use.  In order to utilize the Service, you must register with the Company through the Website or the App. Anyone who registers with the Company as a customer is a User (“User”).

a.        Voluntarily submitted information

We collect information that you provide to us during your use of the Website, App and/or Service, such as:

• Personal Information that you enter when registering for the Company services, including your full name, email address, password, phone number, payment method, billing information, profile information,  and related security information used for authentication and account access.
• Personal identification documents such as TLC license data, DMV license data, and social security numbers.  
• Communications with us or with other Users the Service.
• Information you provide in your profile preferences, to customer support services or that you post on any forums or message boards.

b.        Information collected through use of the Service

• Location data: If you access the Service through a mobile device, we may access, collect, monitor and/or remotely store “location data,” which may include the GPS coordinates or similar information regarding the location of your mobile device.
• Contacts: We may access your address book or contacts if you provide us with your permission to do so through the “prompt” message we will send to you at the time of your registration.  
• Transaction data: We collect information created during your various interactions with the Service, including the date and time of your use of the Services.

c.        Information collected via technology

•  If you are using our Website, we collect information from you, including your hardware model, browser type, operating system, Internet Protocol (IP) and domain name.  If you are using a mobile device, the Company may also receive your UDID, or another unique identifier, and mobile operating system. We may correlate this information with other Personal Information we have about you. We may also use cookies and URL information to gather information regarding the date and time you used the Service and the information for which you searched and accessed. “Cookies” are small pieces of information that a website sends to your device while you are viewing the website.  We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following general web browser help file directions.
• In connection with your use of the Service, we may receive your call data, including the date and time of calls and SMS messages, the parties’ phone numbers and the content of SMS messages that relate to your use of the Services. We may request access or permission to certain features from your mobile device, including your mobile device’s Bluetooth, camera, push notifications, and other features.
• If you log in to our Service with social media credentials (e.g., Facebook or Twitter log-in), your Personal Information may be provided to us by such social media site.
• If you choose to link your Company account with a third party payment provider (e.g., Google Wallet), your Personal Information may be provided to us by such payment provider.

d.        Information provided by others 

• We may collect information that Users provide about one another, including via ratings and postings on forums or message boards, as applicable.

2. How We Use Your Information

a.        Personal Information

We may use your Personal Information for the following purposes:

• Register and administer your account.
• Provide and maintain the Service, including sending new product, service or new feature information and/or information about changes to our terms, conditions, and policies.
• Facilitate communications between Users.
• Offer User customer support and diagnose technical and service problems.
• Send communications and administrative emails about the Service and reply to your inquiries.
• Provide you with promotional and advertisement materials, which may be based on your prior activity.
• Personalize and tailor the features, performance and support of the Website, App and Service.
• Send you promotional/marketing information, newsletters, offers or other information from us or on behalf of our sponsors or partners.
• Offer you participation in special events, programs, surveys and market research.
• Provide you with opportunities and functionality that we think would be of particular interest to you.
• Improve existing and develop new products and services and requested feedback.
• Improve the quality and safety of the Website, App and Service and perform internal operations.
• Analyze, benchmark and conduct research on User data and interactions with the Service.
• Perform accounting, auditing and other corporate procedures.
• We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• We may share your information with our business partners to offer you certain products, services or promotions.
• Prevent and identify fraud and other unlawful activity.
• Comply with and enforce applicable legal requirements, relevant industry standards and our policies.

b.        Anonymous Information

We may use Anonymous Information for the following purposes:

• Improve the Website, App and Service and customize your experience, such as by providing targeted useful features and promotions based on the type of services you seek.
• Aggregate the information collected via Cookies and similar technologies to use in statistical analysis to help us track trends, evaluate the effectiveness of our ads and analyze patterns.

3. How We Share and Disclose Information

We know how important it is to keep your information confidential. We will not rent, sell or share your Personal Information with third parties except as specifically approved by you at the time of disclosure or under the circumstances described below.

If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to (a) provide your Personal Information at any time or (b) download the App and become a User.

In addition to using the information collected by us for the purposes described in Section 2 above, we may also share your information as described below. Please review our sharing policy closely, especially with respect to your Personal Information. By becoming a User, you agree to allow us to share the Personal Information you provide to us in the ways described in our Privacy Policy. Your ability to make changes to what information is shared is described below.

a.        Users

• We share certain information about Users to enable the scheduling and provision of Service.
• Information provided on any Company online forum or message board may be viewed by any User who has access the forum or board.  

b.        Third-Party Service Providers 

We also share Personal Information with vendors, consultants and data processers who perform services on behalf of the Company, including without limitation, companies that provide email services and host the Website, App and Service. The Company has selected companies who maintain high standards with respect to privacy and agree to use the Personal Information only to perform specific services on behalf of the Company and in accordance with the terms and conditions of this Privacy Policy. We collect information through cookies and similar technologies.

c.        Compliance with Laws, Law Enforcement and Safety

We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend the Company or a third party’s, rights or property. We may also reserve the right to disclose information we’ve collected about you for purposes of protecting the health and safety of our Users, such as in the case of risk of harm or violence against any person.

d.        Anonymous information 

Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other Users (“Aggregated Anonymous Information”). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third parties, and, depending on the circumstances, we may or may not charge third parties for such information, or limit the third parties’ use of the same.

e.        Business transactions 

We may share all or some of your Personal Information with any of our subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honor this Privacy Policy.  Additionally, in the event we undergo a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any entity that acquires us, is merged with us or that acquires our assets may continue to process your Personal Information as set forth in this Privacy Policy.

4. Your Choices

By becoming a User, you consent to receive certain communications from us. You may modify or opt out of receiving messages sent for marketing purposes, or certain other communications, by adjusting your account settings or following the unsubscribe instructions in such messages. Please note that despite any indicated marketing preferences, we may send you administrative emails regarding the Website, App or Service, including, for example, notices of updates to our Privacy Policy.

5. Updating Your Personal Information

You may revise your Personal Information by adjusting your account settings on the App or by contacting us directly by using the Contact Us Page here: https://psterling.com/contact-us, by phone at (800)695-1409. However, please note that we may be required to maintain certain Personal Information, or to maintain certain Personal Information for a period of time, in which case we will comply with your deletion request if possible, only after we have fulfilled such requirements. When we delete any information, it will be deleted from our active database, but may remain in our archives. We may retain your information for fraud detection or similar purposes. Note that if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.

6. Children

You must be 18 years of age to become a User.  The Website, App and Service are not directed at or intended for anyone under 18 years of age. We do not knowingly collect or solicit Personal Information from individuals under 18 years of age and no one under age 18 may provide any Personal Information to the Company. If we later obtain actual knowledge that a User is under 18 years of age, we will take steps to remove that individual’s Personal Information from our systems and delete the account. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at Support@dryvecars.com so that we may delete and remove such information from our systems.

7. Security and Data Retention

We are very concerned with safeguarding your information. We employ all reasonable administrative, physical and electronic measures designed to protect your information from unauthorized access. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email, text or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Although guaranteed security does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. 

We will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. Your consent to such purpose remains valid after termination of our relationship with you.  

8. Third Party Websites

The Company may provide links to other websites or content that may be of interest to you. However, we are not responsible for the privacy practices employed by those websites or content providers, nor are we responsible for the information they contain. This Privacy Policy applies solely to information collected by us through the Website, App and Service; thus when you use a link to go from our Website or App to another third party website, this Privacy Policy is no longer in effect. We encourage you to read and consider the privacy policies of these other websites before using them. 

We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment.

9. Ad Networks and Third Party Cookies

We may have agreements with companies, sometimes called “Ad Networks” that serve advertising on our Website, App or Service on behalf of third parties. These Ad Networks may place or recognize a “Third Party Cookie,” on your browser. Ad Networks use cookies to understand the web usage patterns of people who see advertisements, to control the sequence of advertisements you see, to provide you with the most relevant advertising, and to make sure you do not see the same ad too many times. Ad Networks may connect information about pages you visit through our Services with information about pages you visit on other sites and show you advertising based on this combined information. We do not control Ad Networks or what they do with the information they collect. Many Ad Networks participate in the Network Advertising Initiative (NAI) and abide by NAI principles, which prohibit members from connecting Personal Information to information they collect through cookies without your explicit consent. If you wish to opt out of participating in advertising programs conducted by NAI member Ad Networks, please go to the NAI Opt-Out http://www.networkadvertising.org/managing/opt_out.asp site and follow the instructions on that site. After you opt-out, you will still see advertisements from NAI member Ad Networks, but the advertising will not be tailored to your web preferences and usage patterns.

Google Analytics.  The Website, App and Service may use Google Analytics, a website analysis service by Google Inc. (“Google”). Google Analytics uses cookies to analyze your use of the Website, App and Service. The information generated by the cookie about your use of the Website, App and Service is sent to and stored at a Google server in the U.S.  Google will use this information to evaluate your use of the Website, App and Service, to compile reports on your activities for website operators and to provide other services related to Website, App and Service and Internet activities. Google will not associate your IP address with any other data held by Google. You can prevent the installation of cookies by adjusting the settings of your browser; however, if you do so, you may be unable to use all features of this Website, App and Service. Further, you can prevent the collection of data generated by cookies and related to the use of this website by downloading and installing the “plug-in” located at the following link: http://tools.google.com/dlpage/gaoptout.

Google AdSense.  The Website, App and Service may use Google AdSense, a Google service to embed commercial information. Google Adsense uses cookies to analyze the use of the Website, App and Service. Further, Google AdSense also uses web beacons (invisible images). These web beacons help process information, such as visitor traffic, on the Website, App and Service. The information generated by cookies and web beacons about your use of the Website, App and Service (including your IP address) is sent to and stored at a Google server in the U.S. Google may also transfer this information to their contractual partners. However, Google will not associate your IP address with any other data stored at Google. You can prevent the installation of cookies by adjusting the settings of your browser; however, if you do so, you may be unable to use all features of the Website, App and Service. By using the Website, App and Service you agree to the processing of the collected information by Google, according to the above mentioned purposes. 

Lyft. The Company and its affiliates and/or partners via the Website, App or Services may provide information to Lyft, Inc., a Delaware corporation located at 185 Berry St, Suite 5000, San Francisco, CA 94107 (“Lyft”).  Lyft operates a ridesharing platform (“Lyft Platform”) which allows individuals the opportunity to request transport from one location to another (each, a “Ride”) via a mobile application (the “Lyft App”) (the Lyft Platform and Lyft App, together, the “Lyft Service”). The transportation services (“Driving Services”) are provided by authorized drivers of Lyft using their own vehicles (“Drivers”). When the Company, its affiliates and/or partners requests for a Ride on behalf a User (each a “Request”), the User consents and represents the User shall consent to Lyft receiving from the Company and any Lyft use of the “Personal Information” and “Anonymous Information” of the User including without limitation: (a)  the sending transactional SMS texts to the User relating to the Request and User’s Ride; (b) the sharing of the User Information with the Driver who accepted the Request; provided that the Lyft Driver will only receive the first name of the User and pick up and drop off location; and (c) the use of and storage of the “Personal Information” and “Anonymous Information” of the User for the internal purposes of Lyft, subject to the Lyft Privacy Policy located at (https://www.lyft.com/privacy/) (the “Lyft Privacy Policy”) which may be modified from time to time, and in the event such Lyft Privacy Policy is modified, the User will reasonably cooperate to agree to the Lyft Terms of Service in the method specified by Lyft. By using the Website, App and Service you agree to the processing and sharing of the collected information by Lyft, according to the above mentioned purposes and subject to the Lyft Privacy Policy.

10. Your California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2019 will receive information regarding 2018 sharing activities).

To obtain this information with respect to the Company’s operations please by contacting us directly by using the Contact Us Page here: https://psterling.com/contact-us with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.

Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

11. Changes to Our Privacy Policy

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out.  Your continued use of the Service after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended. We encourage you to bookmark this webpage and review this Privacy Policy regularly. 

12. Contact Us

If you have any questions regarding our Privacy Policy, you can contact us using the Contact Us Page here: https://psterling.com/contact-us] or by phone at (800) 695-1409.