Urban Robotics, Inc. (“Halo”, “we,” “us,” and “our”) takes the private nature of your personal information seriously.  This policy regarding our privacy practices (the “Policy”) describes how we treat the information we collect when you use our website at halo.car (the “Site”), our web application at app.halo.car (the “App”), and when you rent and use Vehicles from us.  We will refer to the Site, App and rental services together as the  “Services”.  

This Policy describes the types of personal information we may collect from you or that you may provide when you access or use the Services, and our practices for collecting, using, maintaining, protecting, and disclosing that information.  When you visit or use our Services, you are consenting to our practices in this Policy. Please read it carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with this Policy and practices, your only choice is not to use the Services or provide us personal information.

This Policy is subject to and incorporated into our Terms of Service (“Terms”). - Capitalized terms set forth herein that are not capitalized above have the same meaning as given to them in our Terms. 

Information We Collect About You and How We Collect It

We collect or may collect several types of  personal information both directly from you and through the use of certain automated technologies, including devices on our Vehicles.

Information We Collect Directly From You 

We collect the following information directly from you and other users of the Services:

• We collect your name, ZIP, email address, and phone number when you register to create an Account to use the App and Services.  
• When you rent a Vehicle, in addition to your name and contact information, we have third party service providers (such as identity verification services and payment processors) collect your driver's license number and the jurisdiction in which you are licensed, credit card or other payment information, a photo, and other identifying information. We may also collect auto insurance policy information if you are using your own insurance to cover the Vehicle.  We may also collect information about you such as your driving record from you, from regulatory bodies where you live, or from other third party sources. We use this information to process your application, determine your eligibility to use our services, to verify your identity, to detect and deter fraud, theft, or abuse of our service, comply with legal and recordkeeping requirements, process your payments and other purposes.
• When there is an accident, breakdown, ticker or other violation, or another incident relating to the Vehicle, we may collect information from you about the accident, breakdown or violation or incident.  

Information We Collect Automatically

We may automatically collect the following information about your use of our Site and Services through cookies and other technologies: your domain name; your browser type and operating system; web pages you view and how long your view them; links you click; your IP address; the type of device and device ID; the length of time you visit our Site or Services; and the referring URL, or the webpage that led you to our Site.  We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. 

This information helps us to improve our Services, and to deliver a better and more personalized Site and Services including enabling us to:

• Estimate our audience size and better understand usage patterns;
• Store information about your preferences, enabling us to customize the Site according to your individual interests;
• Speed up your searches; and
• Recognize you when you return to the Services

Please see the section “Our Use of Cookies and Tracking Technologies” below for more information.

Video and Location Data

We equip our Vehicles with exterior devices that record the surroundings of the Vehicles as well as vehicle tracking and anti-theft technology that uses Global Positioning System (GPS)(collectively, “Video and Location Data”). We also have a pilot that can remotely access the video device to view the surroundings of the Vehicle to verify its location.  The pilot also uses such devices and the Video and Location Data to verify the identity of the person that has rented the Vehicle and for purposes of delivering and retrieving the Vehicle.  You authorize the use of such devices to take video recording of the location of the vehicle and of you and your face for these and the other purposes described below.

Connected Car Data

Our Vehicles contain devices that monitor the car’s condition, performance and operation, track fuel consumption, distance traveled, location and other information (the “Connected Car Data”), and may transmit such Connected Car Data to us, our third party providers and/or the car manufacturer.  Some or all of these communications are turned on all the time, even when other services or other media in the car are turned off.  We cannot guarantee that a car without these features will be available for your reservation.  These devices may have been installed by us, on our behalf, or by the car manufacturer.  If the devices are installed by the car manufacturer, the car manufacturer will process the Connected Car Data in accordance with its privacy notice.  We do not provide the car manufacturer with your personal information, unless authorized by you, necessary in connection with the provision of services provided through such car manufacturer, or required by law.  We may enter into agreements with car manufacturers to receive some or all of the Connected Car Data collected by these devices.  We may use a third party to process the Connected Car Data on our behalf.  We do not provide the third party processor with your personal information, unless authorized by you, necessary in connection with the provision of services provided through such third party, or required by law.

Service Providers

We may use or partner with other third-party companies, agents, or contractors for various purposes in connection with our business and operations (“Service Providers”), including billing and payments, payment processing, identity verification, background checks, and the performance of other services on our behalf, such as gathering and analyzing information and the provision of our Services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your information. We may also share information, including your personal information, with these Service Providers in order to enable them to perform these responsibilities and to provide these services.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To provide our Services, process and complete transactions and send you related information, including the request for and the provision of our Services;
• To deliver, monitor and retrieve Vehicles you have rented from us; 
• To provide technical and other support to you;
• To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, and events; and providing other news or information;
• To enable Service Providers to perform certain responsibilities and provide certain services in connection with our business and operations;
• To fulfill any other purpose for which you provide it;
• To provide you with notices about your Account;
• To carry out our obligations and enforce our rights arising from any agreements entered into between you and us, including for billing and collection;
• To notify you about changes to Services;
• To enhance the safety and security of the Services;
• To conduct background checks on potential renters of our vehicles (please see below for more information on this);
• To verify your identity (please see further information on this below) and prevent fraud or other unauthorized or illegal activity;
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.

Identity verification and background checks

We may use identity verification services provided by a third-party provider, Berbix, to verify your identity documents, confirm your identity and protect against fraud and abuse.  When you create an account, you may be asked to submit a valid driver's license, along with a selfie image.  We have access to the data that Berbix uses to verify your identity. We are not responsible for Berbix’s data privacy practices.  For more information on the data privacy practices please see https://terms.berbix.com/terms/privacy

We may also collect information about you such as your driving record from you, from regulatory bodies where you live, or from other third party sources.  We use this information to process your application, determine your eligibility to use our Services, to verify your identity, to detect and deter fraud, theft, or abuse of our service, comply with legal and recordkeeping requirements, process your payments and other purposes. 

Disclosure of your information.

We may disclose aggregated information about customers and users of the Site and Services, and information that does not identify any individual or specific customer, without restriction.

We may disclose personal information that you provide as described in this Policy:

• To our subsidiaries and affiliates;
• To insurance companies in connection with obtaining insurance coverage and processing insurance claims;
• To Service Providers, contractors, and other third parties we use to support our business or perform functions on our behalf, including identity verification, background checks, payment processing and marketing support;
• To a potential or actual buyer, assignee, or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about you and other users of the Site or our products is among the assets that may be or are actually transferred;
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information; and
• With your consent.
  

We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any law enforcement, government or regulatory request; 
• To enforce or apply the Terms and other agreements, including for billing and collection purposes; and
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others.

We do not disclose your personal information to third parties for their direct marketing purposes. 

Use of Cookies and Other Tracking Technologies

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Services. There are two types of cookies: session and persistent cookies.

Session Cookies.

Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site. 

Persistent Cookies.

Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity. Some of these persistent cookies expire after a certain period of time, others remain on your computer indefinitely.

[We may also collect information using web beacons (also known as “tracking pixels”).  Web beacons are electronic images or other computer codes that may be used in our Site or emails and help deliver cookies, count visits, understand usage and the effectiveness of our communications and determine whether an email has been opened and acted upon.]

Third Party Analytics. 

We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and our Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties. For more information on Google Analytics, including how to opt-out of its cookies, please see Privacy controls in Google Analytics 

Third-Party Links

Our Site may contain links to third-party websites.  Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

California Do Not Track Disclosure

Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not currently honor web browser “Do Not Track” signals and other mechanisms that provide you with the ability to exercise choice regarding the collection of personal information about your online activities over time and across third-party websites or online services.

Information Choices and Changes

We offer the following ways for you to manage our use of your personal information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that all or some parts of Site may then be inaccessible or not function properly.

Email Communications.

• Administrative Emails.  If you are a customer, we may occasionally send you email and other communications, such as administrative communications relating to your account or product support and service.
• Marketing Emails. We may occasionally send you marketing materials, newsletters, or other similar emails. If you do not wish to have your e-mail address used by us to promote our own or third-parties’ products or services, you can opt-out through the unsubscribe mechanism at the bottom of the applicable email.
  

Advertising.   

We do not control third-parties’ collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe’s Preference Manager at TrustArc Preference Manager. 

Data Subject Requests 

You may send us an email at support@halo.car if you have a question about our privacy practices or want to access, obtain a copy of, review, correct, or request deletion of your personal information; we will honor such requests to the extent required by law, provided that we may retain your personal information if required to comply with law, legal process, or legal obligations or to the extent permitted by applicable law.    

Storage, Retention and Transfer of Your Information

We may store any information that we collect (personal or otherwise) ourselves or in databases owned and maintained by us, our affiliates, agents, or Service Providers. If you access or use the Site or Services outside of the United States, information that we collect about you may be transferred to servers inside the United States.  By allowing us to collect information about you, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country. We generally retain personal information for as long as necessary to provide the Services or fulfill the purpose of collecting that information, although we  may retain information for a longer period if such retention is required to comply with applicable law.  If you request deletion of your account, we will generally delete the personal information and postings associated with that account, unless we are required to keep that information by law (for example, if we have received a court order or subpoena to produce such information).

Children

No one under age 13 may provide any information on or through the Site . We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on or through the Site. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at support@halo.car.

Contact Information

We welcome your comments or questions about this Policy. You may contact us at support@halo.car. 

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.  We do not make disclosure and do not sell your personal information to the third party. If you want to learn more, please send an e-mail to support@halo.car.

Please note that at this point, Halo is not subject to the requirements of the California Consumer Privacy Act (CCPA).  If and when the CCPA applies, we will update this Policy to include any required notices and other provisions as required by the CCPA. 

Data Security

We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information. However, despite our efforts, no security controls are 100% effective and we cannot ensure or warrant the security of your personal information. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in the Site or Services.

Changes to Our Privacy Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on the Site. If you access or use the Site or provide us personal information after such changes are posted, you agree to and accept such changes. 

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