Urgently Inc.

Privacy and Cookie Policy

Effective Date: February 10, 2020

1. Your Privacy Matters

Urgently’s Roadside as a Service™, the only global digital roadside assistance platform, continues to reimagine the roadside assistance industry to the benefit of global brands, roadside assistance professionals, and consumers. Urgently’s solution delivers the quickest, safest and most innovative roadside assistance service, products and technology by combining location-based services, real-time data, AI and machine-to-machine communication. Urgently’s platform powers roadside assistance solutions in North America, Europe and Asia for leading brands across the automotive, insurance, telematics and other transportation-focused verticals. Central to this mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared. This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy, Cookie Policy, Settings and our Help Center.

2. Introduction

This privacy and cookie policy (“Policy”) describes how Urgent.ly Inc. (“Urgently” “we,” and “our”) collects, uses and shares personal data when using this website geturgently.com (the “Site”) and/or the Urgently application(s). Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it. By using the Services, you consent to such use of your information and personal data and agree to the terms of this Privacy Policy.

Over 425,000 drivers across America have found better roadside assistance service through Urgently. In addition, millions of drivers have direct access to Urgently through its integration in a broad range of mapping and connected car platforms.

2.1 Services

This Privacy Policy applies to Roadside Assistance. For California residents, additional disclosures required by California law may be found in our California Residents section below.

This Privacy Policy, including our Cookie Policy, applies to your use of our Services.

2.2 Data Controllers and Contracting Parties

Urgently will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services.  As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy and other documents referenced in this Privacy Policy, as well as updates.

Where and how we may control your data.

2.3 Change

Changes to this policy:  We will post any modifications or changes to the Policy on our Services.  We reserve the right to modify the Policy at any time, so we encourage you to review it frequently.  The “Effective Date” legend above indicates when this Policy was last changed.  If we make any material change(s) to the Policy, we will put a notice on our Services prior to such change(s) taking effect.

Changes to the Privacy Policy apply to your use of our Services after the “effective date.”

3. Data We Collect

We collect information about you in a range of forms, including personal data. As defined by EU General Data Protection Regulation (GDPR), ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. As defined the California Consumer Protection Act (CCPA), ‘personal data’ means individually identifiable information about an individual consumer collected online by the operator from that individual and maintained by the operator in an accessible form, including any of the following:

  • A first and last name,

  • A home or other physical address, including street name and name of a city or town,

  • An e-mail address,

  • A telephone number,

  • A social security number, (not collected by Urgently)

  • Any other identifier that permits the physical or online contacting of a specific individual,

  • Information concerning a user that the Web site or online service collects online from the user and maintains in personally identifiable form in combination with an additional identifier.

We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to Services. If you created a profile/registered with us, you will have been asked to agree to provide this information in order to access our services and/or purchase our products. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Services. We collect information about you in the following ways, as detailed below.

3.1 Data You Provide Us

  • Personal data you provide when you register to use Services, including your‎ name, postal address, email address, telephone number, username, and password.

  • Personal data that may be contained in any video, comment or other submission you upload or post to Services;

  • Personal data you provide in connection with our rewards program and other promotions we run on Services;

  • Personal data you provide when you report a problem with Services or when we provide you with customer support;

  • Personal data you provide when you make a purchase of the Services; and

  • Personal data you provide when you correspond with us by phone, email, text or otherwise.

We need certain personal data in order to provide you with access to Services.

3.2 Information from Social Networking Sites

Our Services include(s) interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS. SNS include but are not limited to Facebook, Twitter, LinkedIn, Instagram, YouTube and Vimeo.

If you connect to a SNS through our Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS.

3.3 Information We Get from Others

We may get information about you from other sources, for example, if you have agreed to share information with one of our partners, or service providers, we may add this to information we get from our Services.

3.4 Information Automatically Collected

We automatically log information about you and your computer or mobile device when you access our Services. For example, when visiting our Services, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Services. We collect this information about you using cookies. Please refer to the sections on cookies, Flash Technology and Pixel Tags below.

We collect this information about you using cookies.

3.5 Automated Decision Making and Profiling

We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.

We want to make sure you are aware.

3.6 Service Use

We use your data to authorize access to our Services and will honor your settings.

3.7 Cookies and Similar Technologies

We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Services. We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Services; and (2) third party cookies, which are served by service providers on our Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

By continuing to visit or use our Services, you are agreeing to the use of cookies and similar technologies for the purposes described in this policy.

3.7.1 What technologies are used and what are they used for?

Type of Technology

Functional Cookies

Description

These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Services and how users use our Services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Services work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. You can find out more about how Google protects your data here: https://support.google.com/analytics/answer/6004245. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Targeted and Advertising Cookies

You can disable cookies which remember your browsing habits and target advertising at you by visiting https://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see advertisements, but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as, but not limited to, Facebook, Twitter or Google+. The social network will record that you have done this.

Flash Technology

We may also use Flash cookies (which are also known as Flash Local Shared Object (“LSOs”)) on our Services to collect and store information about your use of our Services. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash cookies stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. You can also control Flash LSOs by going to the Global Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager03.html and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Services.

Pixel Tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

Disabling Cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.

3.8 Your Device and Location

We may, from time to time, offer certain location or pinpoint based services, such as location assisted navigation instruction. If you elect to use such location-based services, we must periodically receive your location in order to provide such location-based services to you. By using the location-based services, you authorize us to: (i) locate your hardware; (ii) record, compile and display your location; and (iii) publish your location to third parties designated by you by means of location publication controls available within the applications (for example, settings, user preferences). As part of the location-based services, we may also collect and store certain information about the users who elect to use such location-based services, such as a device ID. This information will be used to provide you the location-based services.

Use of Location-Based Services provides authorization to:    

1. Locate your hardware    
2. Record, compile, and display your location    
3. Publish your location to third parties designated by you by means of location publication controls available within the applications

3.9 User Generated Content

You may share personal data with us when you submit user generated content to our Services, including via rewards programs, forums, message boards and blogs on our Services. Please note that any information you post or disclose on our Services will become public information and will be available to other users of our Services and to the general public. Such personal data and other information will not be private or confidential once it is published on our Services. If you provide feedback to us, we may use and disclose such feedback on our Services, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first and last name along with your feedback on our Services. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.

We urge you to be very careful when deciding to disclose your personal data, or any other information, on our Services.

3.10 Other

Our Services are dynamic, and we often introduce new features, whichmay require the collection of new information. If we collectmaterially different personal data or materially change how wecollect, use or share your data, we may modify this Privacy Policy.

We are improving our Services, which means we get new data and create new ways to use data.

4. How We Use Your Data

4.1 Services

We may use your personal data to operate, maintain, and improve our Services, as well as, to process payments you make via our Services.

4.2 Communications

We may use your personal data to manage your account, including to communicate with you regarding your account, if you have an account on our Services.

Use of personal data for communication

We may use your personal data to link or combine user information with other personal data.

We may, from time to time, offer certain location or pinpoint based services, such as location assisted navigation instruction. We may use third-party providers to help provide such location-based services through mobile systems and we may make information available to such providers to enable them to provide their location-based services, provided that such third party providers may use the information only in accordance with this Policy.

Communication for location or pinpoint based services

4.3 Reselling of Personal Information

Urgently does not sell or resell your Personal Information.

We do not resell your personal information.

4.4 Advertising

We may use your personal data to operate and administer our rewards program and other promotions you participate in on our Services.

Rewards Program

4.5 Marketing

We may use your personal data with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you

We promote our Services to you and others.

4.6 Insights That Do Not Identify You

When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies.  We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you.  We use this anonymous data to analyze usage patterns in order to make improvements to our Services.

We use data to generate insights that do not identify you. We use this anonymous data to analyze usage patterns in order to make improvements to our Services.

4.7 Customer Support

We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

We use data to help you and fix problems.

5. How We Share Information

5.1 Our Services

Roadside Assistance Services

This is a service we contract to our customers.

5.2 Others’ Services

We may share your personal data with third parties where you have provided your consent to do so.

Third Parties Designated by You

5.3 Related Services

We may share some, or all, of your personal data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our affiliates where you wish to receive marketing communications from them.

We share your data across our different Services and Urgently affiliated entities.

5.4 Service Providers

We may share your personal data with our third-party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and delivery of other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.

We may use others to help us with our Services.

5.5 Legal Disclosures

We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

5.6 Change in Control or Sale

We may share personal data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. Such deals could include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

6. Your Choices & Obligations

6.1 Data Retention

We will retain your personal data until you close your account/cancel your subscription unless a longer retention period is required or permitted by law (for example for regulatory purposes).

We keep most of your personal data for as long as your account is open.

6.2 Rights to Access and Control Your Personal Data

For personal data that we have about you, you can:

Opt-out

You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the European Economic Area (EEA). Please note that your use of some of the Services may be ineffective upon opt-out.

Access

You may access the information we hold about you at any time or by contacting us directly at dataprivacy@urgent.ly.

Amend

You can also contact us to update or correct any inaccuracies in your personal data at dataprivacy@urgent.ly.

Move

Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.

Erase and forget

In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data by emailing us at dataprivacy@urgent.ly. If you wish to exercise any of these rights, please contact us using the details in Contact Information section below. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce.  For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

6.3 Account Closure

We generally delete closed account information within 30 days of account closure, except as noted below. We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Policies), enforce our User Agreement, or fulfill your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.

We keep some of your data even after you close your account.

6.4 Third Party Sites

Our Services may contain links to third party websites and features.  This Policy does not cover the privacy practices of such third parties.  These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies.  Please read their privacy policies before you submit any data to them.

Please read third-party privacy policies before you submit any data to them.

6.5 Our Policy on Children

Our Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us using the details in the Contact Information section below. We will delete such information from our files as soon as reasonably practicable.

Our Services is/are not directed to children under 16.

6.6 Sensitive Personal Data

Subject to the following paragraph, we ask that you not send us and that you not disclose any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us. If you send or disclose any sensitive personal data to us when you submit user generated content to our Services, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our Services.

Do not disclose sensitive personal data on or through the Services.

7. Other Important Information

7.1 Security

We seek to use reasonable organizational, technical and administrative measures to protect personal data within our control. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in “Contact Information” section below.

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

7.2 Cross-Border Data Transfers

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

We may store and use your data outside your country.

7.3 Lawful Basis for Processing

We will only collect and process personal data about you where we have lawful basis. Lawful basis includes consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Urgently Services you have requested) and “legitimate interests.”

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

At any time, you can withdraw consent you have provided.

7.4 Direct Marketing and Do Not Track Signals

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about "Do Not Track," please visit https://allaboutdnt.com/.

We currently do not respond to do not track signals.

7.5 California Residents

The California Consumer Privacy Act provides some California residents with the additional rights listed below.

Right to Know.
You have the right to know and see what data we have collected about you over the past 12 months, including:    

• The categories of personal information we have collected about you;    
• The categories of sources from which the personal information is collected;    
• The business or commercial purpose for collecting your personal information;    
• The categories of third parties with whom we have shared your personal information; and    
• The specific pieces of personal information we have collected about you.

Right to Delete.

You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:    

• Complete your transaction;    
• Provide you a good or service;  
• Perform a contract between us and you;    
• Protect your security and prosecute those responsible for breaching it;    
• Fix our system in the case of a bug;    
• Protect the free speech rights of you or other users;    
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);    
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adhere to all other applicable ethics and privacy laws;    
• Comply with a legal obligation; or    
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

Other Rights.

You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.

Exercising Your California Privacy Rights.

To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us at dataprivacy@urgent.ly.

7.6 EU-U.S. Privacy Shield

Urgently Inc. complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the EU to the United States. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall take precedence. To learn more about the Privacy Shield program, the Privacy Shield Principles and to view our certification, please visit www.privacyshield.gov. As described in the Privacy Shield Principles, Urgently Inc. is accountable for personal data that it receives and subsequently transfers to third parties. If third parties that process personal data on our behalf do so in a manner that does not comply with the Privacy Shield Principles, we are accountable, unless we prove that we are not responsible for the event giving rise to the damage. In compliance with the Privacy Shield Principles, Urgently Inc. commits to resolve complaints about our collection or use of your personal data. EU individuals with inquiries or complaints regarding this Policy should first contact us at: dataprivacy@urgent.ly. Urgently Inc. has further committed to refer unresolved Privacy Shield complaints to Jams, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit www.jamsadr.com for more information or to file a complaint.  The services of Jams are provided at no cost to you. As further explained in the Privacy Shield Principles, binding arbitration before a Privacy Shield Panel will also be made available to you in order to address residual complaints not resolved by any other means. Urgently Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

7.7 Contact Information

You may contact us in writing at:
8609 Westwood Center Drive
Suite 810
Vienna VA, 22182
USA
or dataprivacy@urgent.ly

You can contact us or use other options to resolve any complaints.