Last modified: October 19th, 2020
CalPro ADAS Solutions, a division of CalPro Holdings, LLC (“Company,” “we,” “us,” or “our,”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:
- Our data practices and your privacy options;
- The types of information we may collect or that you may provide when you purchase, install, access, or use our ADAS IdentiScan mobile application and the related paired dongle device (together the “App”); and
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy DOES NOT apply to information that:
- We collect offline or on any other Company apps or websites, including websites you may access through this App.
- You provide to or is collected by any third party (see Third-Party Information Collection).
Our websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Children Under the Age of 16
The App is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at firstname.lastname@example.org.
Information We Collect and How We Collect It
We may collect personal information about you in connection with your use of our System. This information may be collected
- Directly from you when you voluntarily provide it to us.
- Automatically when you use the App.
Information You Provide to Us
When you download, register with, or use this App, we may ask you provide information:
- By which you may be personally identified, such as name, postal address, email address, telephone number, and other contact information by which you may be contacted online or offline (“personal information”).
- That is about you but individually does not identify you, such as financial information necessary to process a purchase or other request; business affiliations; and other information related to your requests or inquiries.
This information includes:
- Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App, subscribing to our service and/or requesting further services. We may also ask you for information when you report a problem with the App.
- Information that you provide when you enroll in our Data Management Reporting Program.
- Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
- VIN numbers and other identifying information about your customers’ vehicles (“customer information”).
Automatic Information Collection and Tracking
Some of the personal information we collect from you may happen automatically. We use tracking technologies such as cookies, log files, and pixel tags to automatically collect information when users visit our System. Information we collect includes but may not be limited to:
- Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, your transaction history relating to the use of our products and services, and other communication data and the resources that you access and use on or through the App.
- Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
- Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, or videos.
- Location Information. This App does collect and use location data, including the real-time geographic location of your device. We use such information to insure your compliance with the restrictions in our End User License Agreement (the “App EULA”). Disabling our access to your location data will terminate your access to the System.
If you do not want us to collect this information do not download the App or delete it from your device. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
- Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access or utilize certain elements of our App.
- Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying System and server integrity).
Third-Party Information Collection
When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
- Analytics companies.
- Your mobile device manufacturer.
- Your mobile service provider.
These third parties may use tracking technologies to collect information about you when you use this App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
How We Use Your Information
We collect information about you in order to provide you with services and products, and also to collect information that is necessary for the System to work properly. We use personal information and customer information for a variety of purposes related to our business, including but not limited to:
- Providing services and support: Performing the essential functions of the System including responding to inquiries, fulfilling orders and requests, processing payments, providing support and troubleshooting, and communicating with users about their use of the System or regarding a user initiated inquiry on the System.
- Communicating with users about products or services: Sending or initiating direct marketing programs, such as newsletters or information about new products or services we are offering; giving you notices about your subscription, including expiration and renewal notices; notifying you when App updates are available, and of changes to any products or services we offer or provide though it.
- Analytics and System improvement: Tracking information about your use of the System to allow us to provide better service; using certain online preferences in the aggregate across all users to evaluate the System and develop additional products and services to offer.
- Compliance with legal obligations: Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the App EULA or for billing and collection; sharing information to comply with the law or a legal proceeding, such as in response to a subpoena or court order.
The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our App according to your individual interests.
- Increase the speed and performance of the App.
- Recognize you when you use the App.
Disclosure of Your Information
In addition, we may disclose personal information and customer information that we collect or you provide:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor 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 about our App users is among the assets transferred.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
Further, we may disclose personal information, but not customer information, in the following instances:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce our rights arising from any contracts entered into between you and us, including the App EULA, and for billing and collection.
- If we believe disclosure is necessary or appropriate to protect our rights, property, or the safety of our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
- Promotion by the Company. If you do not want us to use your email address to promote our own or third parties’ products or services, you can opt-out by by clicking on the unsubscribe link in any communication received from us, or by emailing us at email@example.com.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Accessing and Correcting Your Personal Information
You may also send us an email at firstname.lastname@example.org to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Your California Privacy Rights
If you are a California resident, you have certain rights under California Consumer Privacy Act and other data protection laws, including:
- The right to know the sources of your personal information we have collected in the last twelve months, what we use that information for, whether it is being disclosed or sold, and to whom it is being disclosed or sold.
- The right to “opt-out” of our sale of your personal information to any third parties.
- The right, with some exceptions, to have your personal information deleted from our possession or control.
- The right to receive equal service and pricing from the Company even if you exercise any of your privacy rights.
You may submit requests for access or erasure of your personal information by calling toll-free (within the U.S. only) 1-844-4CALPRO (1-844-422-5776) or emailing email@example.com.
If you submit a request for access or erasure of personal information, you will be required to verify your identity by answering certain questions. We will not disclose or delete any information until your identity is verified.
If you are making a request for erasure, we will ask you to confirm again that you want us to delete your personal information before processing your deletion request.
If you are making a request for access, we may not be able to provide specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your personal information, your account with us, our network or the System.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.
Agents making requests on behalf of California residents must verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.
Our response to a request is at no cost to you. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
Under the California “Shine the Light” law, California residents may request information about our disclosures of certain categories of personal data to third parties (i.e., our affiliates) for such third parties’ direct marketing purpose, by emailing firstname.lastname@example.org or writing to: CalPro Holdings, LLC, Attn: Head of Customer Care, 2905 Casco Point Road, Wayzata, MN 55391.
If you are under 18 years old, a California resident, and a registered user of the System where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to email@example.com. Your request does not ensure complete or comprehensive removal of what you have posted and the law may not require or allow removal even if requested.
We have implemented measures designed to secure your personal information and customer information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
or via our toll-free number: