This Privacy Policy (this “Policy”) applies to all Users (including Driver applicants) and to the Co-op Apps and Services, websites, features, and other services (collectively, the “Platform”). Capitalized terms not defined herein shall have the meaning set forth in the Terms of Service Agreement.
Article I. THE INFORMATION TDC-CO COLLECTS
When you use the Platform, TDC-CO collects the information you provide, such as usage
information and information about your device. We also collect information about you from other
sources like third-party services and optional programs in which you participate, which we may
combine with other information. The type of information we collect is detailed below.
Section 1.01 Information You Provide to Us.
(a) Account Registration. When you create an account with TDC-CO, we collect the information you provide us, such as your name, email address, phone number, birth date, and payment information. You may choose to share additional information with us for your account, like your photo or saved addresses (e.g., home or work) and other enabled preferences (such as your preferred pronouns).
(b) Driver Information. If you apply to be a Driver, we will collect the information you provide in your application, including your name, email address, phone number, birth date, profile photo, physical address, government identification number (such as social security number), driver’s license information, vehicle information, and car insurance information. Additionally, we collect the payment information you provide us, including your bank routing numbers and tax information. Depending on the requirements of applicable law, we may also ask for additional business license or permit information. We may also request additional information from you after you become a Driver, including information to confirm your identity.
(c) Ratings; Feedback. When you rate and provide feedback about Riders or Drivers, we collect the information you provide in your feedback.
(d) Communications. When you contact us, or we contact you, we collect any information that you provide, including the contents of the messages or attachments.
Section 1.02 Information We Collect When You Use the Platform.
(a) Location Information. Great rides start with an easy and accurate pickup. The Platform collects location information (including GPS and Wi-Fi data) differently depending on your selected settings and device permissions and whether you are using the Platform as a Rider or
Driver. We collect the following location information from Drivers and Riders:
(i) Riders. We collect your device’s precise location when you open and use the Rider App, including while it is running in the background from the time you request a Service until the Service ends.
(ii) Drivers. We collect your device’s precise location when you open and use the Driver App, including when it is running in the background and when it is in driver mode. We also collect precise locations for a limited time after you exit driver mode to detect ride incidents, and we continue collecting such locations until a reported or detected incident is no longer active.
(b) Usage Information. We collect information about your use of the Platform, including Service information like the date, time, destination, distance, route, payment, and whether you used a promotional or referral code. We also collect information about your interactions with the Platform, including the pages and content you view and the dates and times of your use.
(c) Device Information. We collect information about the devices you use to access the Platform, including device model, IP address, type of browser, version of operating system, identity of carrier and manufacturer, radio type (such as 4G), preferences and settings (such as preferred language), application installations, device identifiers, advertising identifiers, and push notification tokens. If you are a Driver, we also collect mobile sensor data from your device (such as speed, direction, altitude, acceleration, deceleration, and other technical data).
(d) Communications Between Riders and Drivers. We work with a third party to facilitate phone calls and text messages between Users without sharing either party’s actual phone number with the other User. While we use a third party to provide the communication service, we collect information about these communications, including the User’s phone number, the date and time, and the contents of messages. For security purposes, TDC-CO may also monitor or record the contents of communications made on the Platform.
(e) Address Book Contacts. You may set your device permissions to grant TDC-CO access to your contact lists, which may be helpful to you when referring friends to TDC-CO. If a contact list is shared, TDC-CO will access and store the names and contact information of the people in your address book.
(f) Cookies; Analytics; Third-Party Technologies. We collect information through the use of “cookies,” tracking pixels, data analytics tools (such as Google Analytics), SDKs, and other third-party technologies to understand how you navigate through the Platform and interact with TDC-CO advertisements, to make your experience safer, to learn what content is popular, to improve your site experience, to serve you better ads on other sites, and to save your preferences. Cookies are small text files that web servers place on your device. Cookies are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Platform. You should consult your web browser(s) to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, it disables certain features of the Platform.
Article II. INFORMATION WE COLLECT FROM THIRD PARTIES
Section 2.01 Third-Party Services. Third-party services provide us with the information needed for core aspects of the Platform, as well as for additional services, programs, loyalty benefits, and promotions that can enhance your experience. These third-party services include background check providers, insurance partners, financial service providers, marketing providers, and other businesses. Third-party services may share information to make the Platform safer, such as background check information for Drivers; about your participation in third-party programs that provide things such as insurance coverage and financial instruments, such as insurance, payment, transaction, and fraud detection information; to operationalize loyalty and promotional programs, such as information about your use of such programs; and about you provided by specific services, such as demographic and market segment information.
Section 2.02 Enterprise Programs. If you use the Platform through your employer or another organization that participates in one of our programs, we will collect information about you from those parties, such as your name and contact information.
Section 2.03 Concierge Service. Businesses or other entities may order you Services (a “Concierge Service”). If an organization has ordered you a Concierge Service, it will provide us with your contact information and the pickup and drop-off location for Services.
Section 2.04 Referral Programs. If a User refers you to the Platform, we will collect information about you from that referral, including your name and contact information.
Section 2.05 Other Users and Sources. Other Users and/or public or third-party sources, such as law enforcement, insurers, media, or pedestrians, may provide us with information about you, for example, as part of an investigation into an incident or to provide you with support.
Article III. HOW WE USE YOUR INFORMATION
Section 3.01 TDC-CO’s Usage. We use your personal information to (i) provide Services on the Platform; (ii) maintain the security and safety of the Platform and its Users; (iii) build and maintain a robust community-led experience; (iv) provide customer support; (v) improve the Platform; and (vi) respond to legal proceedings and obligations.
Section 3.02 TDC-CO’s Platform. We use your personal information to provide an intuitive,useful, efficient, and worthwhile experience on the Platform. To do this, we use your personal information to (i) verify your identity and maintain your account, settings, and preferences; (ii) connect you to Services and track the Services’ progress; (iii) calculate prices and process payments; (iv) allow Users to connect regarding Services and to choose to share their location with others; (v) communicate with you about your Services and experience; (vi) collect feedback regarding your experience; (vii) facilitate additional Services and programs with third parties; and (viii) operate contests, sweepstakes, and other promotions.
Section 3.03 Maintaining the Security and Safety of the Platform and Its Users. Providing you with a secure and safe experience drives the Platform, both on the road and on the Co-op Apps. To do this, we use your personal information to (i) authenticate Users; (ii) verify that Drivers and their vehicles meet safety requirements; (iii) investigate and resolve incidents, accidents, and insurance claims; (iv) encourage safe driving behavior and avoiding unsafe activities; (v) find and
prevent fraud; and (vi) block and remove unsafe or fraudulent Users from the Platform.
Section 3.04 Building and Maintaining TDC-CO Community. TDC-CO strives to be a positive part of the community. We use your personal information to (i) communicate with you about events and promotions; (ii) facilitate your participation in the democratic process of the TDC- CO;(iii) personalize and provide content, experiences, communications, and advertising to promote and grow the Platform; and (iv) help facilitate donations you choose to make through the Platform.
Section 3.05 Providing Customer Support. We work hard to provide the best experience possible, including providing you with support. To do this, we use your personal information to investigate and assist you in resolving questions or issues you have regarding the Platform and provide you support or respond to such issues and inquiries.
Section 3.06 Platform Improvements. We are always working to improve your experience and provide you with new and helpful features. To do this, we use your personal information to perform research, testing, and analysis; develop new products, features, partnerships, and Services; prevent, find, and resolve software or hardware bugs and issues; and monitor and improve our operations and processes, including security practices, algorithms, and other modelling.
Section 3.07 Responding to Legal Proceedings and Requirements. Sometimes, applicable law, government entities, or other regulatory bodies impose demands and obligations on us regarding the Services we provide. In such circumstances, we may use your personal information to respond
to those demands or obligations.
Article IV. HOW WE SHARE YOUR INFORMATION
We do not and will not sell your personal information. However, to make the Platform work, we may need to share it with other Users, third parties, and service providers, as detailed below.
Section 4.01 Sharing Between TDC-CO and Users.
(a) Rider Information Shared with Driver. Upon Rider’s request for Services, we share with the Driver the Rider’s pickup location, name, profile photo, rating, rider statistics (e.g., approximate number of rides and years as a Rider), and information the Rider includes in their Rider Account (e.g., preferred pronouns). Upon pickup and during your Services, we share with the Driver the Rider’s destination and any additional stops the Rider inputs into the Rider App. Once Services are complete, we also share the Rider’s rating and feedback with the Driver. We remove the Rider’s identity associated with ratings and feedback when we share it with Drivers, but a Driver may be able to identify the Rider who provided the rating or feedback.
(b) Driver Information Shared with Rider. Upon a Driver accepting a requested Service, we will share with Rider the Driver’s name, profile photo, preferred pronouns, rating, real-time location, and the vehicle make, model, color, and license plate, as well as other information, such as information Drivers choose to add (e.g., country flag and why you drive) and Driver statistics (e.g., approximate number of rides and years as a Driver).
Section 4.02 Sharing For Necessity. Although we help Users communicate with one another to arrange Services, we do not share your phone number or other contact information with other Users. If you report a lost or found item to us, we will seek to connect you with the relevant User including sharing direct contact information with your consent.
Section 4.03 Shared Services. When Riders use a shared Service, we share each Rider’s name and profile picture to ensure safety. Riders may also see each other’s pickup and drop-off locations while sharing Services.
Section 4.04 Services Requested or Paid for by Others. Some Services may be requested or paid for by others. If you utilize such Services, your TDC-CO business profile account, a code or coupon, a corporate credit card linked to another account, or another User otherwise requests Services for you, we may share some or all of your Service details with that other party, including the date, time, Charge, rating given to Driver, region of the Services, and pick up and drop off location.
Section 4.05 Referral Programs. If you refer someone to the Platform, we will let them know that you generated the referral. If another User referred you, we may share information about your use of the Platform with that User. For example, a referral source may receive a bonus when you join the Platform or utilize a certain number of Services, and the referring User would receive such information.
Section 4.06 Sharing with Third-Party Service Providers for Business Purposes. Depending on the applicable User, TDC-CO may share the following categories of your personal information for business purposes to provide you with a variety of the Platform’s features: (i) personal identifiers, such as your name, address, email address, date of birth, government identification number (such as social security number), driver’s license information, vehicle information, and car insurance information; (ii) financial information, such as bank routing numbers, tax information, and any other payment information you provide us; (iii) commercial information, such as ride information, User statistics and feedback, and User transaction history; and (iv) internet or other electronic network activity information, such as your IP address, type of browser, version of the operating system, carrier and/or manufacturer, device identifiers, mobile advertising identifiers, and location data.
Section 4.07 Sharing with Service Providers. We disclose certain categories of personal information to service providers to fulfill the following business purposes: maintaining and servicing the Platform account; processing or fulfilling Services; providing you customer service; processing Rider transactions; processing Driver applications and payments; verifying the identity of Users; detecting and preventing fraud; processing insurance claims; providing Driver loyalty and promotional programs; providing marketing and advertising services; providing financing; providing requested emergency services; providing analytics services; and undertaking internal research to develop the Platform.
Section 4.08 Sharing For Legal Reasons and To Protect the Platform. We may share your personal information in response to legal obligations, or if we have determined that sharing your personal information is reasonably necessary or appropriate to comply with applicable federal, state, or local law or regulation, civil, criminal, or regulatory inquiry, investigation or legal process, an insurance claim, or enforceable governmental request; respond to legal process (e.g., a search warrant, subpoena, summons, or court order); enforce our Terms of Service Agreement; cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law; or exercise or defend legal claims, protect against harm to our rights, property, interests, safety, or the rights, property, interests, or safety of you, third parties, or the public, as required or permitted by applicable law.
Section 4.09 Upon Your Further Direction. With your permission or upon your direction, we may disclose your personal information to interact with a third party or for other purposes.
Section 4.10 How We Store and Protect Your Information. We retain your information for as long as necessary to provide you and other Users of the Platform a quality experience. This means we keep your profile information for as long as you maintain an account. We retain transactional information such as rides and payments for at least seven (7) years to ensure we can perform legitimate business functions, such as accounting for tax obligations. If you request your Rider or Driver Account be deleted, we will delete your information as set forth in Section 5.01(h). Additionally, we take reasonable and appropriate measures designed to protect your personal information. We will use commercially reasonable efforts to secure your account, however, no security measures are always effective against all unauthorized access, and we cannot guarantee the security of your information, including against unauthorized intrusions or acts by third parties.
Article V. YOUR RIGHTS AND CHOICES REGARDING YOUR DATA
As detailed below and on our Privacy Homepage, TDC-CO provides ways for you to access and delete
your personal information as well as exercise other data rights that give you certain controls over your
personal information.
Section 5.01 All Users.
(a) Email Subscriptions. You can always unsubscribe from our commercial or promotional
emails by clicking unsubscribe in those messages. However, we will still send you transactional
and relational emails about your use of the Platform.
(b) Text Messages. You can opt out of receiving commercial or promotional text messages
by texting the word “STOP” to the sending number from the mobile device receiving the
messages.
(c) Push Notifications. You can opt out of receiving push notifications through your device
settings. Please note that opting out of receiving push notifications may impact your use of the
Platform (such as receiving a notification that your ride has arrived).
(d) Profile Information. You can review and edit certain account information you have
chosen to add to your profile within your account settings.
(e) Location Information. You can prevent your device from sharing location information
through your device’s system settings. However, limiting location sharing may impact TDC-
CO’s ability to provide you with our full range of features and Services.58726031.2
(f) Cookie Tracking. You can modify your cookie settings on your browser, but if you delete
or choose not to accept our cookies, you may be missing certain features, Services, and other
aspects of the Platform.
(g) Do Not Track. Your browser may offer a “Do Not Track” option, which allows you to
signal to website operators, web applications, and service providers that you do not want them
to track your online activities. The Platform does not currently support Do Not Track requests.
(h) Deleting Your Account. If you would like to delete your applicable User account, please
visit our Privacy Homepage. In some cases, we will be unable to delete your account, such as
if there is an issue with your account related to trust, safety, or fraud. When we delete your
account, we may retain certain information for legitimate business purposes or to comply with
legal or regulatory obligations. For example, we may retain your information to resolve an
ongoing insurance claim, or we may be obligated to retain your information as part of an
ongoing legal claim. When we retain such data, we do so in ways designed to prevent its use
for other purposes.
Section 5.02 Verification of User. To respond to Users' exercise of their rights, we will need to
verify your request either by asking you to log in and authenticate your account or otherwise verify
your identity by providing information about yourself or your account. Authorized agents can
make a request on your behalf if you have given them legal power of attorney or you provide
signed permission, verification of your identity, and confirmation that you provided the authorized
agent permission to submit the request.
Section 5.03 Response Timing and Format. We aim to respond to a User’s request for access or
deletion within forty-five (45) days of receiving that request. If we require more time, we will
inform you of the reason and extension period in writing.
Article VI. MISCELLANEOUS
Section 6.01 Minor’s Data. TDC-CO is not designed to provide minors with Services, and we do
not knowingly collect personal information from minors under the age of thirteen (13). If we
discover a minor under the age of thirteen has given us personal information, we will take steps to
delete that information. If you believe that a minor under the age of thirteen has given us personal
information, please contact us at our Help Center.
Section 6.02 Links to Third-Party Websites. The Platform may contain links to third-party
websites. Those websites may have privacy policies that differ from ours. We are not responsible
for those websites, and we recommend that you review their policies. Please contact those websites
directly if you have any questions about their privacy policies.
Section 6.03 Changes to This Privacy Policy. We may update this Policy from time to time as
the Platform changes and applicable privacy laws evolve. If we update this Policy, we will do so
online, and if we make material changes to this Policy, we will let you know through the Platform
or by some other method of communication (e.g., email). When you use the Platform, you are
agreeing to the most recent terms of this Policy.
Section 6.04 Contact Us. We encourage you to contact us if you have any questions or concerns
about your privacy or anything in this Policy, including if you need to access this Policy in an
alternative format.
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