COLLECTION OF INFORMATION
Voyo products use different methods to connect your car to the cloud including a Bluetooth connection provided by a user’s cell phone or a cellular modem embedded in the Voyo unit. The Voyo App allows a user to lock/unlock car doors, detect malfunctions, send alerts to other users, and increases your car’s security and fuel efficiency. We collect and store Personal Information that you provide voluntarily or we collect automatically when using our Services. Personal Information is information that can identify you as a specific individual (“Personal Information”). In order to provide these valuable services, Voyo collects the following types of information about you, your car and your driving habits in the following ways:
Information You Provide Directly: You may choose to provide us with information, including Personal Information, through registration and/or use of our Services, such as:
- Contact information, such as your name, address, telephone number and email address.
- Payment information, such as your credit card details, which you provide to our third-party processor rather than Voyo, except in the case of refunds.
- 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, or other data points relevant to the maintenance of the vehicle.
Information We Collect Automatically: We also may receive, record, share and store certain information, which may be Personal Information, about you as well as your computer, mobile device, and your vehicle’s OBD II port automatically. Automatically collected information may include:
- Vehicle information, such as your VIN number, that may be associated with you.
- Geolocation information.
- The type of device(s) you use and the related operating system(s).
- Identification details of your device (e.g., unique device identifier).
- IP address.
- Information about your use of the App and our Services.
- Information about the content you view and the features you access on our Services that we collect using cookies, web beacons, and similar technologies.
- Information collected by sensors included in the Voyo controller provided to you when you purchased the Services and related Company or third-party hardware.
- PIDs (i.e. parameter ID data, such as brake pressure, steering wheel angle or accelerator pressure).
- Information collected in conjunction with the OBD-II port, such as odometer, speed, braking and acceleration metrics, engine start/stop and idle times, battery voltage levels, diagnostic codes, engine pre-check results, weather conditions (e.g. temperature, barometer), other codes related to the operation and performance, and other operating parameter data specific to the make/model of the vehicle.
Personal Information does not include anonymized, aggregate or statistical information from which such identification cannot be reconstituted. We may de-identify Personal Information, including information about your driving habits that we have collected from you through the Site, the App, the OBD-II port, or our other Services and combine it with de-identified information about other users, information from third parties, and/or publicly available information.
USE OF INFORMATION
We use the information we collect and receive, including Personal Information, for the following general purposes:
- To provide you with access to our Services;
- To help us improve the content and functionality of our Services;
- To better understand your interests and to contact you in the future to tell you about services we believe will be of interest to you;
- To conduct research on our users’ demographics, interests, and behaviors;
- To respond to your questions and assist with any problems with our Services; and
- For any other purpose disclosed to you at the time we collect the information, or otherwise with your consent.
SHARING OF INFORMATION
We consider your Personal Information and your other information to be a vital part of our relationship with you. Voyo will not rent, sell, or share your personal information with other people or nonaffiliated companies except to provide products or services that you have requested, unless we have your permission or as provided in this Policy. There are, however, certain circumstances in which we may share your information with certain third parties without further notice to you, as set forth below:
Service Providers: Voyo may share your information, including some Personal Information, with entities that provide services to us, including companies that provide web and other analytics, data processing, advertising, e-mail distribution, payment processing, order fulfillment, and other services. When we employ another entity to perform a function of this nature, we only provide them with the information they need to perform their specific function.
Groups You Create or Join: 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. 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 administrator controls the sharing. If you do not want such sharing to occur, you should communicate with the group administrator.
Community Forum: If you submit feedback or ideas through our 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. Your name will be included in any posts that you make to the Community Forum.
Other Parties When Required by Law or as Necessary to Protect Our Services: There may be instances when we disclose your information to other parties in order to: (i) protect and defend legal rights of Voyo, its affiliates, and users of our Services; (ii) protect the safety and security of users of our Services; (iii) prevent fraud (or other risk management purposes); or (iv) comply with or respond to law or legal process or a request for cooperation by a government entity.
Other Parties in Connection with Certain Business Transfers: If we make a sale, donation, or transfer of assets, or are otherwise involved in a corporate merger, transfer, reorganization, dissolution or similar event, we may transfer your information to one or more third parties as part of that transaction.
Payment Processors: Our payment processing partners collect your voluntarily provided payment card information necessary to process your payment.
Security and Fraud Prevention Consultants: We may share your information with these consultants for the purpose of detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Hosting, Technology and Communications Providers; Fulfillment Providers; Manufacturing Partners; Data Storage Providers; User Testing Service Providers; Analytics Providers; Staff Augmentation Personnel: We may provide personal information to these parties in order to perform:
- operational services (such as hosting, billing, fulfillment, data storage, security, web service analytics) and/or to make certain services, features or functionality available to our users;
- debugging to identify and repair errors that impair existing intended functionality;
- services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services (including the recording, reproduction and sharing of your communications with us in order to enhance these services or our analytics that support such enhancements), or providing similar services on behalf of the business or service provider;
- internal research and user testing for technological development and demonstration of our Services; or
- activities to verify or maintain the quality or safety of our services.
Phone-Based Location Data: If you are a consumer, 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. If you are a business customer, GPS data may not be disabled on a cellular Device.
Car Location Data: You can disable the collection of car location data by unplugging the Voyo device from the car. Expectedly, this disables all car-related capabilities within the service but can be resumed when you choose to reconnect the device.
Your Voyo Account Information: Where applicable, you may amend your preferences by updating your account information or settings within your Voyo authenticated account. You may unsubscribe from marketing-oriented emails by clicking on the “unsubscribe” link in emails you receive from Voyo.
Interest-Based Advertising: Data about your use of Services may be collected by the Company for use in providing advertising, including by third parties, tailored to your individual interests.
A Note About Email Marketing: By creating an account or purchasing our products, you may be agreeing to receive email messages. These messages could include changes to features of our service and additional email messages about our products, services and promotions that we feel may be of interest to you. If you no longer wish to receive these types of promotional communications from us, you may (i) select the unsubscribe link which is present in each email, (ii) contact customer service at any time, or (iii) email firstname.lastname@example.org. Opting out may prevent you from receiving email messages regarding special offers, improvements, or other updates from Voyo.
Voyo does not knowingly collect or store Personal Information about children under the age of 13. We encourage parents and legal guardians to monitor their children’s Internet usage and to instruct their children not to provide Personal Information on the Internet without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information through our Services, please contact us and we will endeavor to delete that information from our databases.
Voyo is based in the United States, and, regardless of where you use our Services, the information collected as part of that use will be transferred to and maintained on servers located in the United States. Please note that any information we obtain about you will be stored in accordance with U.S. privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using our Services, you consent to this collection, transfer, storage, and processing of information to and in the United States.
If you are a resident of the European Union (“EU”), United Kingdom, Liechtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR. Voyo will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this section and any other provision of this Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at email@example.com.
What Personal Data We Collect From You
For information on what Personal Data we collect from you, please see the Collection of Information section above. For information on how we use that Personal Data, see the Use of Information section above.
Lawful Bases for Processing Personal Data
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to provide you with the Service, for example to create your account, complete your order, ship your product, and provide customer support. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Service that require such data. For example:
- User account data (your email, username and password)
- Sign-up contact information (your name and email)
- Transaction data (details of your order, phone number, billing and shipping addresses)
- Credit card information (to process refunds)
- Customer support data (so that we can provide you with support)
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
- User account data
- Your contact information email address for marketing purposes
- Analytics and usage data
Our legitimate interests include:
- Marketing of our products and services
- Order processing
- Account creation
- Provision of customer support
- Web analytics
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest. You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email firstname.lastname@example.org or write to us at 1058 N. Tamiami Trail, suite 108-137, Sarasota, FL 34236; Attention: Privacy. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by reviewing the “my account” section of our website.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly through our “my account” feature.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about Voyo’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
NOTICE TO CALIFORNIA RESIDENTS
Subject to certain limitations under California Civil Code § 1798.83, if you are a California resident, you may ask us to provide you with (i) a list of certain categories of Personal Information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year and (ii) the identity of certain third parties that received Personal Information from us for their direct marketing purposes during that calendar year. To make such a request, please contact us as indicated in the “Contact Us” section below. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information on covered sharing will be included in our response.
Beginning January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with additional rights, which will be augmented by the California Privacy Rights Act of 2020 (“CPRA”) beginning on January 1, 2023. Your privacy rights are important to us as described in this Policy, but as a small company we are exempt from many of the provisions of the CCPA and the CPRA because we have not, in the prior calendar year:
- had $25,000,000 in revenue;
- derived 50% or more of our revenue from selling consumers’ personal information; or
- bought, sold, or shared for commercial purposes the personal information of 50,000 or more consumers, households, or devices.
NOTICE TO NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name, or by using the following web form. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
DO NOT TRACK NOTICE
Do Not Track (“DNT”) is a preference available in many web browsers which allows you to inform websites you visit that you do not want them collecting information about you. Voyo does not currently respond to DNT signals, which means that we may collect information about your online activity both while you are using the Service and after you leave our Service. For further details regarding DNT, visit donottrack.us.
A cookie is a small data file that your computer downloads from the Site, containing information about you to facilitate interaction with the Site and our Services. Cookies make it possible for us to store contents of your shopping cart until you are ready to check out, and to recognize your browser when you visit. By doing this, we can personalize your visits and save you time during checkout. Cookies can also enable us to track and target the interests of our users to enhance the experience on the Site. If you reject a cookie, you may still use the Site. However, in order to enjoy the benefits of being a registered user of the Site, your browser must be set to accept cookies. Currently, we do not alter our data collection and use practices in response to Do Not Track signals.
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We retain personal data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain personal data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation.
THIRD-PARTY FUNCTIONALITY AND LINKS TO THIRD-PARTY SITES
INTEGRATION WITH SOCIAL NETWORKING AND OTHER SERVICES
One of the special features of our Services is that they allow you to enable or log in to our Services via various online services, including social networking services. Our Services also may enable you to access these third-party services directly or indirectly through our Services. By directly integrating these third-party services, we aim to make your online experiences richer and more personalized. When you add a third-party service account to our Services or log into our Services using your third-party service account, we may collect relevant information necessary to enable our Services to access that third-party service and your data contained within that third-party service. We also may share your information with the operator of that Third-Party Service to facilitate or enhance delivery of that third-party service or other services to you.
You may also have the option of posting your activities on our Services and other content to third-party services when you access content through our Services. We also may publish user contributions through third-party services, such as by posting a user story on our Facebook Page. If either you or we choose to make any of your contributions available through a third-party service or engage in other activities in connection with a third-party service, your friends, followers, and subscribers on those third-party services that you have enabled will be able to view those contributions and activities.
By accessing Voyo via a third-party service, you grant Voyo permission to contact you at the email address associated with your account associated with the third-party service. Members of Voyo’s marketing lists will occasionally receive information on our products, services, special sales, and our newsletter. You may opt out from receiving these types of information, and you may unsubscribe at any time by changing the settings in your app account profile or by sending a request to firstname.lastname@example.org.
We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your information from loss, misuse, unauthorized access, and alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using our Services, but we cannot ensure or warrant the security of any information you transmit to us. Please refer to the U.S. Federal Trade Commission’s web site https://www.ftc.gov/ for information on how to protect yourself from identity theft.
OTHER TERMS AND CONDITIONS