Effective Date: January 28, 2018


CarHub. (“CarHub”) makes driving easier, safer and less expensive by providing tools to connect you with your car, diagnose , and improve your driving. In order to provide these valuable services, CarHub collects information about you, your car and driving habits and uses this information to identify ways that you can save on car repairs, insurance and other similar services. CarHub does not share information about you or your driving habits with the third parties who provide these special offers unless you tell us to do so. You control whether your information is shared with third parties for marketing purposes.CarHub understands that privacy is important to you so we are providing a plain English summary of each section of the Privacy Policy below. This Privacy Policy explains the details of how we collect, use, share and protect the information we collect from you.

Our commitment to user privacy is summarized by the following Privacy Principles:

We treat your personal data as private and confidential.
We do not share your personal information for marketing purposes unless you expressly agree.
We are transparent about our privacy practices – they are disclosed in plain language in this easily accessible policy.
We use industry standard safeguards to protect your personal information.
 

Introduction


This Privacy Policy applies to the personal information we collect on CarHub.co (the “site”), the CarHub mobile app (the “app”), and the CarHub Key telematics device (the “Key”) (collectively, the “Service”). In some cases, a part of the Service may provide additional detail about our privacy practices.

This Privacy Policy describes the types of personal information we collect on the Service, how we may use that information and with whom we may share it. We also tell you how you can reach us to ask us to update your preferences regarding how we communicate with you or answer any questions you may have about our privacy practices.

 

This Policy addresses our privacy practices relating to the use of the Service. Anyone who visits, browses or otherwise uses the Service (collectively, “you” or “user”) is subject to this Privacy Policy. Before using and submitting any information to the Services, please read this Privacy Policy. By using the Services, including the submission of any personal information, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to having your data transferred to and/or processed in Trinidad and Tobago. If you do not agree to this Privacy Policy, you are not permitted to use the Services. This Privacy Policy does not create rights enforceable by third parties.

Information We Obtain


Information You Submit


You may choose to provide us with personal information through the Services, like:

• Contact information, such as your name, address, telephone number and email address.

• Vehicle information, such as your VIN number, that may be associated with you.

• Personal information in communications and other content you submit or share, such as photographs and video clips.

• Information about activities and purchases related to your vehicle such as service performed, battery replacement, mileage or other data points relevant to the maintenance of the vehicle.


Information We Collect by Automated Means With the App
If you use the app, we may collect the following information by automated means:

• The geolocation of your mobile device over time, and information that may be inferred from it, such as your driving speed at a particular time.
• The type of device you use and its operating system.
• Identification details of your device (e.g., unique device identifier).
• IP address.
• Information about your use of the app.
• Information collected in conjunction with the Key, as described below.

Information We Collect by Automated Means With the Key


When you install the Key and use it in conjunction with the app, we may collect details about your vehicle’s use, operation, performance and maintenance status, such as

• Speed
• Braking and acceleration metrics
• Engine start/stop and idle times
• Battery voltage levels
• Diagnostic codes as reported by the vehicle per the OBD II standard*
• Engine pre-check results
• Other codes related to the operation and performance, specific to the make/model of the vehicle
• The geolocation of the Key

*See http://en.wikipedia.org/wiki/On-board_diagnostics

De-Identified and Non-Personally Identifiable Information
We may de-identify personal information, including information about your driving habits, that we have collected from you through the site, app or Key and combine it with de-identified information about other users, information from third parties, and/or publicly available information.

Information We Collect by Automated Means On Our Site


Like most websites, we use technologies to automatically collect information about your use of the our site and the equipment that you use to access our site. Additional details are provided here.

Customized Offers and Your Choices


Data gathered from the usage of our app and/or the Key may be used to identify discounts tailored to your needs and interests. And we may use this data to tell you about a special offer, such as a discount on car repairs or insurance. If you do not wish to receive such offers, you can tell us by sending us an email to support@rainworkstt.com or indicating your preference on a settings page in the app.

In some cases, an offer may require you to share more information with a third party such as your personal information, your car data or driving data. If so, we let you know exactly what is requested so you may authorize us to share that data. It’s up to you, in each case and we only share this data with our partners for marketing purposes if you agree.

Disclosure of Information and Your Choices


The privacy and confidentiality of your information is important to CarHub. This section describes the information that is shared internally at CarHub and with third parties and the choices that you have to prevent such sharing.

CarHub Engineers and Operational Staff: Our engineers and support staff may have access to your information in order to diagnose and resolve problems or to provide support to you. CarHub employees are required to maintain the privacy and confidentiality of this information and follow this Privacy Policy. CarHub cannot provide the Services without this support. If you do not wish to have data shared with our staff, you should not use the Services.

Service Providers: CarHub may share your information, including some personal information, with third parties who perform services on our behalf, including credit-card and billing, survey administration, technical or customer support, shipping, and provision of email and data analytics. These third parties are contractually required or bound by law to protect your information and only are permitted use such information in accordance with our agreements with them. CarHub cannot provide the Services without this support. If you do not wish to have data shared with these third parties, you should not use the Services.

Third Party Partners – Personal Information: CarHub may share your personal information, including driving habits, with our third party partners that we trust, only if you agree to the sharing of such data. For instance, if you agree, CarHub may share certain selective data about you, your driving habits or information about your car so that you can receive valuable discounts or offers from insurance companies or car repair/maintenance companies. In some instances, our partner may request additional information from you, such as your driving score. You will always be presented with the details of any request and the information only will be shared if you agree.

Third Party Family or Friends: At your request, we may share profile information and information about your geolocation and driving habits with members of groups you create or join. You decide whether this information is shared and with whom.

Groups: If you have joined a group, the group creator may add new members and may change whether you share location information with other members after you have joined the group. It is your responsibility to monitor these activities. The group creator controls the sharing. If you do not want such sharing to occur, you should communicate with the group creator.

Community Forum: If you submit feedback or ideas through the community forum on the site and/or app, any information that you submit, including personal information, will be included in your post and will be public. If you do not want your personal information posted in the community forum, do not include it in your feedback or ideas. Your name will be included in any posts that you make to the Community Forum.

Third Party Vendors or Partners – De-Identified Information: CarHub may share de-identified and other non-personal information with third parties for purposes of analytics, marketing and other uses. This information is not intended to identify you personally. If you do not wish to have this information shared, you should not use the Service.

Law Enforcement; Protection of CarHub and Others: We may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a court order or subpoena; (ii) in response to legal requests by government agencies; or (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.

Business Transfers: Your information may be disclosed as part of any merger, acquisition, sale of company assets or transition of service to another provider. In the unlikely event of an insolvency, bankruptcy or receivership, you information also may be transferred as a business asset. If CarHub is involved in a transition of service to another provider, merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a conspicuous notice on our Site or in the app, which will include any choices you may have concerning your Information.

Additional Controls You Have


Phone-based location data
You may choose to turn off phone location data collection either within the App or within your phone’s Location Services settings. This may disable any features that use this data, such as location sharing, but other capabilities will still be available such as vehicle diagnostic alerts. You may also choose not to accept invites to share from other users, or leave an account or group.

Car Location data
You can disable the collection of car location data by unplugging the Key from the car. Expectedly, this disables all car-related capabilities within the service but can be resumed seamlessly when you choose to reconnect the Key. You may also chose not to invite any other friends or family into your CarHub sharing network, ensuring that your car’s location is never shared with anyone else. Finally, you always have the option of canceling the service at which point your Key ceases to collect data and any existing personal data is removed from the system.

Diagnostics & Driving Metrics
Diagnostics codes and driving data are collected as long as the Key is connected and active. But this information is only shared explicitly by the user, either with their social network, such as sharing details about a trip taken, or with a merchant who may request data in order to present an offer – see Disclosure of Information and Your Choices.

Your CarHub Profile
Where applicable, you may amend your preferences regarding how we communicate with you by updating your profile or settings within your CarHub authenticated account or contacting us as described in How to Contact Us. You also may use settings pages within your CarHub authenticated account to modify certain preferences regarding the collection of data (such as geolocation) and the sharing of certain data. You may unsubscribe from marketing-oriented emails by clicking on the “unsubscribe” link in emails you receive from CarHub.

Data Security
We maintain a variety of commercially reasonable safeguards designed to protect your information from unauthorized access and disclosure. For example, we use industry accepted tools and techniques to protect against unauthorized access to our systems.

You should be aware, however, that CarHub has no control over the security of other websites or applications that you might visit or use even when a link to those websites or applications is available in or through the Service. If you share your computer or wireless device or use a computer or wireless device that is accessed by the general public, remember to sign off and close the app and/or web browser when you have finished your session. This will help to ensure that others cannot access your information.

We want you to feel confident using the Service. However, no system can be completely secure. Therefore, although we take commercially reasonable steps to secure your information, we do not promise, and you should not expect, that your information or other communications always will remain secure. In the event of a breach of the confidentiality or security of your personal information, we will notify you if reasonably possible and as reasonably necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the e-mail address we have on record for you. You should also take care with how you handle and disclose your personal information.

Updates to Our Privacy Policy


This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices or relevant laws. To inform you of any change, we will post the updated Privacy Policy on our site and indicate at the top of the Privacy Policy when it was updated. We will provide separate notice to you of material changes to the Privacy Policy.

How to Contact Us


If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us as indicated below.

Rainworks Ltd
support@rainworkstt.com