Last Updated: July 11, 2022
Welcome! This Privacy Notice explains how SF EV, LLC. (“Spring Free EV”, “Company”, “we”, “us”, or “our”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our websites, including https://springfreeev.com/ and other websites we own and operate that link to this Privacy Notice (the “Sites”), and the related content, platform, services, products, and other functionality offered on or through our online services (collectively, the “Services”). It does not address our privacy practices relating to Spring Free EV employees and other personnel.
Our Collection of Personal Information
Sometimes we collect personal information automatically when an individual interacts with our Services and sometimes, we collect personal information directly from an individual. At times, we may collect personal information about an individual from other sources and third parties, even before our first direct interaction.
If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our Services. Any information you provide to us that is not required is voluntary.
Personal Information You Provide to Us
We may collect the following personal information submitted to us by individuals through the Services:
- Contact Information: including first and last name, phone number, email address, address and communication preferences.
- Credit and Identity Information: Including your Social Security number, date of birth, driver’s license number, driver’s insurance information and other credit and identity-related information needed to facilitate the delivery of credit reports, background checks, and the identity verification process. Note that some of this information is collected directly by third-party credit or identity provider services, and not by Spring Free EV. As such, we do not retain all the information listed in this subsection in our systems.
- Driving and Gig Platform Information: Including, with your permission, your credentials, and information about your driving record and hours worked on third party gig platforms such as Uber or Instacart.
- Your Communications: Whenever you contact us (for example, by responding to one of our messages, signing up for our email newsletter, or notifying us of an incident involving the Services), we will collect any information you provide (including the content of any attachments). We will also collect information which is apparent from your communication (for example, the email address or phone number from which you contacted us). If you communicate with us by telephone, we may record the audio of our communications, consistent with applicable law. In certain instances, we may provide you an opportunity to indicate your preferences for our future communications (e.g., whether you prefer physical mail, email, text messages), and we will collect any preferences you indicate.
- Feedback: We collect feedback and ratings you provide relating to your experience as a user or any other issue related to the Services.
- Contest, Sweepstakes, and Survey Information, including information provided when you enter a contest or sweepstakes, or information included in any questions submitted through surveys or content of any testimonials.
- Other Data You Share. We also collect personal information at such other points on our Services so that we may provide the features or functionality of the Services and for other purposes described in this Privacy Notice. We may also collect your personal information or data if you submit it to us in other contexts.
Please note that although you may provide the information described above directly to us, we may also receive this information through service providers and other third parties that collect it on our behalf. These service providers and third parties include, but are not limited to, communications providers, background check providers, employment and income verification providers, marketing services providers, research and analytics providers, and our fleet managers.
Personal Information Collected When You Use the Services
- Connected Vehicle Data: All our vehicles are connected cars. A connected car is a vehicle equipped with features, telematics systems, on-board devices, or built-in services and technologies that are capable of collecting data about the vehicle and its use, including, for example, the vehicle’s condition, damage and accident events and records, performance, operation and diagnostic data, information on mileage, acceleration, braking, speed, g-force, trip durations and routes, battery state of charge and range, tire pressure, odometer, location and direction, relative proximity to other vehicles, and other vehicle-related information. Please note that while this information is associated with the vehicle and maintained as non-personal information, if we link this information to you we will treat it as personal information.
Use of features and built-in services and technologies in connected cars may be subject to your master agreement with the vehicle provider, the terms and conditions posted by the vehicle manufacturer, and/or the technology provider, which may include system and service limitations, warranty exclusions, limitations of liability, wireless service provider terms, and user responsibilities. Some or all of these features are turned on at all times, even when other services or other media in the vehicle are turned off. Depending on the technology used in your vehicle, vehicle manufacturers and built-in services such as ‘Apple CarPlay’ or ‘OnStar’ may also collect Connected Car Data or other personal information from the vehicle pursuant to their privacy policies. For more information about this third party information collection, please refer to the Third Party Collection section below.
- Device Information: We may collect information about the devices and browsers you use to access the Services. This may include your internet protocol (IP) address, operating system, browser type, browser language, screen resolution, the URL you entered and any relevant referring page/campaign, as well as information about the mobile devices you may use to access the Services from a mobile device (including your hardware model, version, any device identifiers, operating system, battery level and charging status, and screen size).
- Usage Information: We collect information about how you interact with the Services, including automatically collected log data. Usage Information may include, but is not limited to, information about the specific components of the Site, or any other aspect of the Services you visit or use, along with details about your views or use of these components including pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; any alerts or communications we send you in connection with your use of the Services; and any errors that may have occurred during your use of the Services.
- Location Information: We collect information about your location in different ways depending on how you use the Services. For example, with your permission, we may collect precise geolocation and other driving data, such as real-time latitude and longitude during your drives, as well as general location data, such as direction of travel, trip information, and distance travelled, as well as date and time information for when this information was recorded. For all other uses of the Services, we may collect general location data based on any automatically collected Device Information and Usage Information (each, as defined above).
- Cookies and Third-Party Analytics Data: Like most providers of online services and platforms, we collect information about the electronic path you take to the Services, through the Services and when exiting the Services, and your usage and activity on the Services, such as the links, objects, products and benefits you view, click, or otherwise interact with. We and our third-party service providers and business partners may collect and store information through “cookies,” related technologies (such as pixels and web beacons), and third-party analytics services (such as Google Analytics and Hubspot). We collect this information for purposes that include remembering User preferences and settings, analyzing the effectiveness of certain features of our Services, and designing and delivering marketing campaigns. For more information on our and third-party partners’ data collection and online advertising practices, please see the Third Party Data Collection and Online Advertising section of this Privacy Notice.
Personal Information from Third Parties
We may receive personal information about you from the following third parties and combine this information with other information we have:
- Social Media. When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
- Service Providers and Business Partners: We work with a wide range of third-party service providers and business partners who make it possible for us to make the Services available and also help us to improve the Services. These service providers include data storage and processing services, mapping services; customer support services; background check providers; employment and income verification providers; fraud prevention, security, and troubleshooting services; communications services; insurance providers; research and analytics providers; professional service providers, including our fleet managers; telematics service providers; payment processing services; and marketing and social media services. In certain contexts, we may work with business partners like car sharing and ridesharing gig platform providers or advertising providers, which make products or services available to drivers who wish to participate. These service providers and business partners may collect your personal information when you provide it to them or automatically when you interact with them, and they may share that information with us.
- Referrals: We may use referral promotions to encourage our users and other businesses that we work with to tell their friends, relatives, customers and other contacts (“Referred Persons”) about the Service.
- Information from Other Sources: We may collect personal information from publicly available sources (including government records or public websites) or from other third parties (including data and mailing list providers, regulators, law enforcement, the media, or insurers) to correct or supplement personal information we have collected about you from other sources.
Our Use of Personal Information
We use personal information we collect to:
- Manage our business and its day-to-day operations;
- Communicate with individuals, including via email and social media;
- For marketing and advertising purposes, including to market our services through email, direct mail, and provide you with updates on products or services we think you may be interested in;
- Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
- Facilitate customer benefits and services, including customer support;
- Conduct research and analytics on our customer and user base and our Services;
- Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
- Monitor and provide predictive maintenance and usage-based insurance;
- For fleet management;
- Recover lost, towed or stolen vehicles;
- Enable third-party vehicle applications and services;
- Improve road safety and reduce traffic;
- Prevent fraud or the recurrence of fraud;
- Identify or investigate unsafe behaviors, and to perform background checks on drivers before we authorize them to use the Services;
- Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations and to deliver the Services;
- Help maintain the safety, security and integrity of our property and Services, technology assets and business;
- Fulfill or enforce our legal or contractual obligations and requirements (including in relation to our Terms of Service), to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
- Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
- For any other lawful purpose, or other purpose that you consent to or for which you provide your information.
Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.
Aggregate/Anonymized Information: We may aggregate and/or anonymize information collected through the Spring Free EV Services so that such information can no longer be linked to you or your device (“Aggregated/Anonymized Information”). We may use Aggregated/Anonymized Information for any purpose, including without limitation for research and analytics, and may also share such data with any third parties, including partners, affiliates, services providers, and others.
Our Disclosure of Personal Information
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.
We disclose personal information in the following ways:
- Affiliates. We may share personal information with other companies owned or controlled by Spring Free EV, and other companies owned by or under common ownership as Spring Free EV, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
- Contests, Sweepstakes, and Survey Providers. We share personal information with third parties who assist us in delivering our contests, sweepstakes, or survey offerings and processing the responses.
- Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
- Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
- With Service Providers: We may share some or all of your personal information with our service providers who perform services on our behalf. Some of the categories of our service providers include:
- Data storage and processing services: The Services are hosted on cloud servers and we use third-party vendors for assistance with data collection, processing, storage, retrieval, and aggregation.
- Mapping services: We use third-party software to assist with mapping functions used in our Services.
- Customer support services: We work with third parties to provide us with support services, including through call centers, email, and chat support.
- Background check providers: In certain instances, and consistent with all applicable laws and regulations, we may engage with third parties who provide background check and identity verification services.
- Employment and income check providers: In certain instances, and consistent with all applicable laws and regulations, we may engage with third parties who provide income and employment data directly from gig platforms.
- Fraud prevention, security, and troubleshooting services: We use vendors to assist us in detecting and preventing fraudulent use of our Services, in preserving the data security of our systems and Services, and in identifying and resolving errors or incidents that may affect the Services. In certain cases, we may work with video recording and telematics service providers to promote safe use of the Services and assist in incident response.
- Communications services: We use vendors to provide communications services for functions such as managing and sending emails, text messages, or telephone calls.
- Insurance providers: We work with insurance companies, adjusters, brokers, and claims administrators to help provide insurance and process claims on implicated insurance policies.
- Research and analytics providers: We use service providers to aggregate personal information and receive insights about how the Services are used.
- Professional service providers: We may consult with or retain lawyers, accountants, government affairs or subject matter experts, and other professionals.
- Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the section Third Party Data Collection and Online Advertising for more information.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- to protect the health and safety of us and others; or
- as otherwise required by applicable law.
- With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction.
Third-Party Data Collection and Online Advertising
We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.
Please see Online Ads of the Control Over Your Information section below, to learn how you can opt out of interest-based advertising.
Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website, “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Facebook Custom Audiences advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
Control Over Your Information
You may control your information in the following ways:
- Emails and Notifications. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices). You may also unsubscribe from receiving SMS text messages by replying “STOP” to the number sending the message. We make every effort to promptly process all unsubscribe requests.
- Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at firstname.lastname@example.org .
- Cookies: To manage cookies, you may change your browser settings to: (i) notify you when you receive a cookie, so that you can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact your experience using our Services, as some features and offerings may not work properly or at all. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
- Online Ads: To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Children’s Personal Information
Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.
Links to Third-Party Websites or Services
Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
- California – Your California Privacy Rights: If you are a California resident, California Civil Code Section 1798.83 – also known as California’s “Shine the Light” – permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To opt out of having your information shared in this manner, please email us at email@example.com with the subject line “California Shine the Light Request”.
- Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at firstname.lastname@example.org with the subject line “Nevada Opt Out Request” to submit such a request.
Updates to This Privacy Notice
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to email@example.com.