Last Updated: 05/11/2019
DriveWayz collects information about you both online and offline. Offline information about you originates from our interactions with you where your information is subsequently entered into our system, for example, through customer service calls or applications of employment. Online information about you originates from your interactions with our Application and our Sites.
Who We Are
Collection and Use of Personal Data
Personal Data We Collect
How We Collect Personal Data
Ways we Process Personal Data
Cookies and Similar Tracking Technologies
How we Process Data for Specific Purposes
Internal Processes and Service Improvement
Other Disclosures with Your Consent
Your Rights & Choices
Additional Information for EU Users
Legal Bases for Processing
Rights of EU Users
Changes to Our Policy
This is the Policy of DriveWayz, LLC (“us,” “our,” or “we”). You can contact us here.
This Policy applies to our “Services” which include:
• Our mobile application available on IOS and Android (the “Application”).
• Our website at https://www.drivewayz.io, and other websites where we link to/post this Policy, including any subdomains or mobile versions (the “Sites(s)”).
This Policy applies to all “Users” of our Services including:
• Hosts: Users who list and rent out Parking Spaces.
• Consumers: Users who reserve Parking Spaces.
• All other Users who provide information to DriveWayz in connection with an application to use our Services, or whose information DriveWayz otherwise receives in connection with its services such as general inquiries or employment applications.
Your use of our Services indicates your acknowledgement of the practices described in this Policy.
In order to provide our Services, we may collect and process information that relates to identified or identifiable individuals (“Personal Data”). We collect and process the following categories of Personal Data (note, specific Personal Data elements are examples and may change):
Personal Data about you and your identity, such as your name, username, date of birth, gender, and other Personal Data you may provide on registration forms or as part of an account profile.
Personal Data used to contact an individual such as phone number, email address, physical address, and social media or communications platform usernames/handles.
Personal Data used to create your User profile and Host listing such as photo/avatar, physical address of the Parking Space, vehicle description, license plate number, Parking Space availability, and description of Parking Space.
Personal Data we collect in connection with a reservation or other transaction such as the Parking Spaces you reserved, the price, Parking Spaces reserved in relation to events we advertise, and zip code.
Personal Data relating to your device, browser, or application. This can include IP addresses, operating system, MAC addresses, application ID/AdID/IDFA identifiers from cookies, session history and similar browsing metadata, and other data generated through applications and browsers, including via cookies and similar technologies.
Personal Data relating to your precise location, such as information collected from your device’s GPS, Wi-Fi network, cell towers, or other precise localization service.
Personal Data relating to certain financial information such as your bank account or credit card information, CVC2/CVV2 code, or other information necessary to facilitate the processing of payments.
We collect information about your interactions with the Services such as your searches for Parking Spaces, bookings you have made, amount of revenue generated by your Parking Space, any reviews you have left, daily user engagement, and other longitudinal statistics.
Personal Data included in content provided by users of the Platform in any free-form or unstructured format, such as in a “contact us” box, free text field, in a file or document, in an image, messages to us, messages to other Users, and reviews of Parking Spaces.
We collect Personal Data from you directly, for example, when you input information into an online form, or contact us directly.
We receive Personal Data from third parties with whom we have a relationship in connection with a certain transaction.
We may collect certain Personal Data automatically. For example, we collect Device/Network Data automatically using cookies and similar technologies when you use our Services, or when you open our marketing communications.
Users may register and create an account through our Services. If you choose to register, we will process Identity Data, Contact Data, Profile/Listing Data, and Transaction Data in connection with the creation, operation, and maintenance of that account. We may also collect certain User Content from you, for example, when listing a Parking Space, creating a Consumer account, in response to a request for information, questionnaire responses, file uploads, or similar matters.
We use Identity Data, Contact Data, Profile/Listing Data, Transaction Data, and User Content as necessary to create, maintain, and provide you with important information about your account. Subject to Your Rights & Choices, and consistent with our business interests, we may process Identity Data and Contact Data in connection with Marketing Communications, Aggregate Analytics, Internal Processes and Service Improvement, and for the other lawful purposes described below.
We use Contact Data, Profile/Listing Data, Transaction Data, Device/Network Data, Payment Information, Usage Information, and User Content in connection with the operation and use of your account, for example, when you search for listings, rent a Parking Space, create a new list Parking Space listing, or otherwise complete a transaction through our Service.
We use this data as necessary to perform our contract with you and enable your use of our Services. This may include Host listings, Consumer reservations, general interactions with the Services, and ticket purchases through our third-party providers. Subject to Your Rights & Choices, and consistent with our business interests, we may also process this data in connection with Marketing Communications, Aggregate Analytics, Internal Processes and Service Improvement, and for the other lawful purposes described below.
We use Location Data in connection with the operation and use of certain Services, for example, when you opt-in to using turn-by-turn directions or when you allow the Application to search for listings based on your current location.
Subject to Your Rights & Choices, we use Location Data to enable your use of our Services, and in connection with certain features you may enable or use. For example, when you request turn by turn directions, or search for Parking Spaces in your area, we may collect Location Data relating to your current location and real time updates to that data when the feature remains active. We will only process Location Data with your consent, which you may revoke at any time.
We may process Identity Data, Device/Network Data, Usage Information, and Contact Data in connection with marketing communications (such as emails), which you might receive if you register for an account, choose to receive marketing communications, or engage in a transaction allowing us to send you those marketing communications. We may also collect Device/Network Data when you open or interact with those marketing communications.
Subject to Your Rights & Choices, we use Identity Data and Contact Data as necessary to customize, deliver, and otherwise process marketing communications, and in order to tailor certain communications to individuals’ preferences and requests including to determine incentives for a particular User. Additionally, we may process Device/Network Data and Usage Information from devices receiving those marketing communications as part of our business interest in understanding whether our emails are opened or other aspects of engagement with such marketing communications.
When you contact us though the Services, we process certain Personal Data such as Identity Data, Device/Network Data, Profile/Listing Data, Transaction Data, and any Personal Data contained within any User Content.
To the extent that you provide it, or processing is necessary in connection with your request, we may use Identity Data, Contact Data, Profile/Listing Data, Transaction Data,User Content. Subject to Your Rights & Choices, we may also use Identity Data and Contact Data in connection with Marketing Communications, if relevant to your request (such as when you request more information about our Services), and for Internal Processes and Service Improvement, and for other lawful purposes described below.
We, and certain third parties, may process Identity Data, Contact Data,Usage Information, Location Data, and Device/Network Data when you interact with cookies and similar technologies on our Services. We may receive this data (or Aggregate Data derived from it) from third parties to the extent allowed by the applicable partner. Please note that the privacy policies of third parties may also apply to these technologies and the Personal Data collected through them.
Subject to Your Rights & Choices, we may use this information as follows:
for “essential” or “functional” purposes, such as to enable certain features of the Services, or keeping you logged in during your session;
for “analytics” and “personalization” purposes, consistent with our business interest in how the Services are used or perform, how users engage with and navigate through our Service, what sites users visit before visiting the Service, how often they visit the Service, and other similar information, as well as to greet users by name and modify the appearance of the Service to usage history, tailor the Service based on geographic location or Client, and understand characteristics of users in various technical and geographic contexts; and
for “retargeting” or similar advertising purposes on our Service, so that you can see advertisements from us on other websites. These technologies and the data they collect, may be used by advertisers to deliver ads that are more relevant to you based on content you have viewed, including content on our Service. These tracking technologies may also help prevent you from seeing the same advertisements too many times, and help us understand whether you have interacted with or viewed ads we’ve delivered to you. This collection and ad targeting may take place both on our Service, as well as and on third-party websites that participate in the ad network (e.g. any advertisements delivered by that ad network on a third party website).
Some of these technologies can be used to identify you across platforms, devices, sites, and services.
Subject to Your Rights & Choices, we will collect and aggregate your Personal Data and information about your use of the Services in order to identify certain trends in how our Services are used and perform, the individuals who use our Services, and the products and services most relevant to users (“Aggregated Data”). Aggregated Data will not contain information from which you may be individually identified. We may use this information in order to create analytics that help us better identify patterns and trends among markets, User engagement, and interest in advertised events.
Subject to Your Rights & Choices, we may use any Personal Data we process through our Services as necessary in connection with our business interests in improving the design of our Services, to create a personalized user experience (such as greeting you by name and suggesting Parking Spaces based on your preferences), and for ensuring the security and stability of the Service. For example, we may use Personal Data to understand what parts of our Services are most relevant to users, how users interact with various aspects of our Services, how our Services perform or fail to perform, etc., or we may analyze use of the Services to determine if there are specific activities that might indicate an information security risk to the Services or our Users.
If we process Personal Data in connection with our Services in a way not described in this Policy, this Policy will still apply generally (e.g. with respect to Your Rights & Choices) unless otherwise stated when you provide it.
Note that we may, without your consent, also process your Personal Data on certain public interest grounds. For example, we may process Personal Data as necessary to fulfill our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest. Please see the Data Sharing section for more information about how we disclose Personal Data in extraordinary circumstances.
Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients or in connection with specific business purposes, each described below.
In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other lawful business interests, we may share your Personal Data with service providers or subprocessors who provide certain services or process data on our behalf. For example, we may use cloud-based hosting providers to host our Services or disclose information as part of our own internal operations, such as security operations, internal research, etc.) When we disclose information for business purposes we may disclose Identity Data, Contact Data, Device/Network Data, and User Content, Profile/Listing Data, Transaction Data, Location Data, Payment Information, and User Content. For example, to enable the use of turn-by-turn directions and Parking Space suggestions based on your current location, we share Location Data and Usage Information with Mapbox.
Your Personal Data may be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
In order to streamline certain business operations, share promotions and content we believe would be of interest to you, and develop products and services that better meet the interests and needs of our customers, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.
We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
Some information that you provide may be available to other Users. After a Consumer reserves a Parking Space, (1) the address of the Parking Space will be available to the Consumer and (2) the Consumer’s identification information (e.g. profile picture, name, and vehicle information) will be available to the Host.
Some information may be available to the public such as photographs of available Parking Spaces, the type of Parking Space (e.g. residential driveway, apartment parking, or parking lot), comments, and reviews.
For purposes of the California Consumer Privacy Act, we do not sell your Personal Data.
To the extent required under applicable law, and subject to our rights or obligation to limit or deny access or disclosure, you may have the following rights in Personal Data (users in the EU may wish to review the “Additional Information for EU Users” below, in addition to the rights and choices listed in this section):
You may receive a list of the specific Personal Data about you that we process.
You may correct any errors in Personal Data that we hold about you.
You may request that we delete your Personal Data from our systems. If required by law we will grant a request to delete your information, but you should note that in many cases we must keep your information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
You may request that we send you a copy of your Personal Data in a common, portable format of our choice.
You have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. Your appropriate local data protection or consumer protection authority varies based on your location and jurisdiction.
Residents of California (and others to the extent required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. You may also request that we provide you a copy of your Personal Data, direct us to stop selling or disclosing Personal Data for certain purposes (if we have done so), and receive information regarding: (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected or sold your Personal Data; (4) the categories of third parties with whom we have disclosed your Personal Data, or sold, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.
You may exercise these rights by contacting us at the address below and submitting a request. We respond to only verifiable requests, and we may require that you provide additional Personal Data to exercise these rights, e.g. information necessary to verify your identity.
Note: We are able to fulfill rights requests regarding Personal Data that we control or process. We may not have access to or control over Personal Data controlled by third parties, including our Clients. Please contact the third party directly to exercise your rights in third party-controlled information.
You may have the following choices regarding the Personal Data we process, to the extent required under applicable law:
If you consent to processing, you may withdraw your consent at any time. You may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of our Services. If you withdraw your consent to the processing of Location Data then we will no longer be able to perform certain aspects of our Services such as turn-by-turn directions.
You have the choice to opt-out of or withdraw your consent to marketing communications. You may have a legal right not to receive such messages in certain circumstances, in which case, you will only receive direct marketing communications if you consent. You may exercise your choice via the links in our communications or by contacting us re: direct marketing.
You may have the right under applicable law to object to our processing of your Personal Data for certain purposes, including without limitation, situations where we process in accordance with our business interests. You may do so by contacting us re: data rights requests. Note that we may not be required to cease processing based solely on your objection.
We implement and maintain reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and though we may enter contracts to help ensure security, we do control third parties’ security processes. We do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.
We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.
Our Sites are neither directed at nor intended for use by minors under the age of majority in the relevant jurisdiction. Further, we do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it.
We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S. The U.S. does not provide the same legal protections guaranteed to Personal Data in the European Union. Accordingly, your Personal Data may be transferred to the U.S. pursuant to the EU’s Standard Contractual Clauses, or other adequacy mechanisms, or pursuant to exemptions provided under EU law. Contact us for more information regarding the mechanisms we use to ensure adequate protection of data subject to EU Law.
In general, DriveWayz, LLC is the data controller for Personal Data collected through the Service. However, if you interact with third party services, such as advertisements or partner programs, those third parties may act as separate or joint controllers with respect to your personal data.
The legal bases for our processing of your Personal Data are described in the table below. If you have questions about the legal basis of how we process your Personal Data, contact us at firstname.lastname@example.org
Processing is necessary to perform the contract governing our provision of the Services to you or the Client, or to take steps that you request prior to such engagement. This may include processing that is in connection with operations that are necessary to provide the Services themselves.
The following processing activities constitute our legitimate interests (also called our “business interests” in this Policy. We balance any potential impact on you when we process your Personal Data for our legitimate interests. You may object to this processing as permitted by law. For example, our legitimate interests include:
Direct marketing of our products and services to our Clients, Authorized Users, and other parties with whom we do business.
Determining the effectiveness of marketing campaigns; providing cost-effective services; personalizing content for individual Users.
To create, provide, support, maintain, and improve the functionality and performance of our Services, and operate our business.
To secure our Platform and network, investigate suspicious activity or violations of our terms or policies; and to protect the safety of Personal Data, including to prevent exploitation or other harms to which users may be vulnerable.
Processing is necessary to comply with our legal obligations, for example, tax laws, fraud reporting, etc.
Note, we may process and disclose Personal Data where it is in the vital interests of a data subject, to comply with a legal obligation to which we are subject, in the public interest, for research, or other appropriate legal ground which may apply under applicable law.
In addition to the applicable rights set forth above under Your Rights & Choices, users of our Service in the EU may have the following additional rights:
Where we process data on the basis of our legitimate interests, you can object to that processing to extent allowed by law. Note that we must only limit processing where our interests in processing do not override an individual’s interests, rights, and freedoms, or the processing is not for the establishment exercise, or defense of a legal claim.
You may have the right to restrict processing of your Personal Data where the accuracy of the Personal Data is contested, the processing is unlawful but you object to deleting the Personal Data, or we no longer require the Personal Data, but it is still required for the establishment, exercise, or defense of a legal claim, or while we assess an objection to processing.
We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Services following notice of any changes indicates acceptance of any changes.
Feel free to contact us with questions or concerns using the appropriate address below.