This Policy applies when you use our services through our website located at www.steadydrive.com (“Site”) and through the SteadyDrive mobile application (“App”). For the purposes of this Policy, unless otherwise noted, the Site, the App, and the services provided by SteadyDrive are collectively referred to herein as the “Services.”
This Policy works in conjunction with our SteadyDrive Terms of Service (“Terms”). Any capitalized term used, but not defined in this Policy, shall have the meaning ascribed to such term in the Terms. If you do not agree with our policies and practices, please do not use our Services. By accessing or using our Services, you agree to this Policy.
When you download the App and grant permission to track, collect and process your Driving Data (as defined below), we, through third-party service providers (“Providers”), collect that data. Your Driving Data will be used to create a driving score (“Score”), that is intended to help users improve driving habits. Your Score may also help you qualify for a discount on auto insurance from an insurance provider (“Insurer”). With your permission, our Providers, in turn, may share your Score, Driving Data and other information you have shared with us with Insurers that have agreed to receive this information from those Providers. The list of Insurers accepting this information may change over time without notice to you, and SteadyDrive cannot assure that any specific Insurer, or any specific percentage of Insurers licensed in your state, accepts this information from our Providers. Once shared, this information will be subject to those Insurers’ privacy policies and terms of service.
Driving Data is stored securely and is not used for any purpose other than performing the Services.
When offering and providing our Services, we need to collect information from and about our users, some of which may constitute personal information. For purposes of this Policy, “Personal Information” is any information that can be used, directly or indirectly, to identify, locate or contact someone. Types of personal information include names, physical addresses, mailing addresses, email addresses, phone numbers, date of birth, login credentials and passwords. Under certain circumstances, personal information may also include other information that can reasonably link to a particular person, such as internet protocol (IP) addresses, App ID, unique device identification numbers, and internet activity.
Personal Information does not include (1) publicly available information; or (2) de-identified or aggregated consumer information.
What Information We Collect
We have collected the following categories of Personal Information from consumers within the last twelve (12) months:
How We Collect Personal Information
SteadyDrive collects a variety of information from and about users of the App to determine their eligibility for preferred insurance rates. We collect this information through your use of our Services, such as signing up, creating an account, and using our App.
By downloading and using the App, we, through our Providers, gather certain telemetric data based on your driving behavior, such as miles driven, speed, direction, acceleration, deceleration, altitude, collision and impact, and location information through the use of your mobile device’s accelerometer, GPS, and gyroscope through our App (collectively, “Driving Data”) until you cease using the App, revoke your permission for us to do so, or we discontinue the Services. This information is stored in an encrypted environment and not used for any other purpose other than to perform the Services.
Additionally, our Site may also collect other information from users such as IP address, browser type and version, hardware type, language and time zone setting, operating system and platform. Some web browsers allow users to send “do-not-track” signals to websites, but our Site does not respond to those signals.
Our Site, like most websites, employs “cookies” and similar technologies. Cookies are small files that are stored on your computer or mobile device when you visit our Site and allow us to recognize your browser and obtain information about your use of our Site. Cookies allow sites to respond to you as an individual. Our Site can also tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.
Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie does not give us access to your computer or any information about you, other than the data you choose to share with us.
You can accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer. However, this setting may prevent you from taking full advantage of the Site.
How We Use Your Information
SteadyDrive uses the information you provide or that we collect from and about you to develop, operate, maintain, enhance, and provide our Services, including the following:
- • We use your email address and mobile phone number to contact you for administrative purposes, for customer service purposes, or regarding your use of the Services.
- • We use the information that you provide or that we collect to provide the Services to you.
- • We use the information that you provide or that we collect to understand and analyze the usage trends and preferences of our users, to improve the way the Services look and work, and to create new features and functionality.
- • We use the data the App gathers from a user’s mobile device to conduct analysis and for providing the Services.
- • We may use “automatically collected” information and “cookies” information to: (a) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you use the Service; (b) provide customized third party advertisements, content, and information; (c) monitor and analyze the effectiveness of the Service and third party marketing activities; (d) monitor aggregate site usage metrics such as total number of visitors and pages viewed.
How We Share Your Personal Information
We may disclose your Personal Information to third parties for various purposes. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:
- • Category A: Identifiers
- • Category B: Customer Records Information
- • Category D: Commercial Information
- • Category E: Internet or Other Similar Electronic Network Activity.
- • Category F: Driving Data and Geolocation Data
We, directly or through our Providers, may also disclose Personal Information we collect from you for one or more of the following legitimate business purposes:
- • to contractors, service providers, and other third parties we use to support our business;
- • to business partners, Insurers and others to provide you with information about promotions or offers upon your authorization or at your request;
- • to fulfill the purpose for which you provided it;
- • to a buyer or other successor of our business in the event of a sale or transfer of some or all of our business or assets or in the event that all or a portion of SteadyDrive or its assets are acquired by or merged with a third party entity, in which case we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from users, including Personal Information and user data in connection with such merger, acquisition, sale, or other change of control.
- • for any other purpose disclosed by us when you provide the information;
- • to comply with any court order, law or legal process, including responding to any government or regulatory request;
- • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
- • if we believe disclosure is necessary or appropriate to protect the rights, property or safety of ourselves, of our customers, or others; or
- • with your consent.
In addition to the above, SteadyDrive may share automatically collected and other aggregate non-personal information (that is, information that does not identify or connect with any particular individual) with third parties, to assist us in understanding the usage, viewing, and demographic patterns for certain programs, content, services, advertisements, promotions, and/or functionality on the Services. We may also provide your de-identified and anonymized data for research studies.
How is Your Information Protected?
SteadyDrive is committed to protecting your information from unauthorized access and disclosure. We have implemented reasonable technical and organizational measures designed to enhance the security of our Services. Unfortunately, the transmission of information via the Internet, cellular and WiFi networks, and mobile platforms is not completely secure. Although we take reasonable safeguards to protect your personal information, we cannot guarantee the security of your personal information. Any transmission of personal information via the Internet or over cellular and WiFi networks is at your own risk. We are not responsible for any third party circumvention of any privacy settings or security measures we provide. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. You should not share your password with anyone.
You may update your preferences relating to your receipt of marketing communications from us by contacting us at email@example.com. You may also opt out of receiving email marketing communications by following the “unsubscribe” instructions provided in promotional emails you receive from us. However, you may not opt out of Services-related communications, such as account verification and administrative messages, so long as you are registered to use our Services.
Your Privacy Rights
Exercising Your Rights
You can exercise the rights specified above by contacting us at:
Email: firstname.lastname@example.org. Only you, or someone legally authorized to act on your behalf, may exercise your privacy rights. You may only exercise the Right to Access twice within a twelve (12) month period.
To exercise the Right to Access or Right to Delete (a “Request”), you must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative, which may include:
- • Your name, user account ID, password, address, or email address on file.
- • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
A Request satisfying the above criteria shall be considered a “Verifiable User Request.” We cannot respond to your Request or provide you with Personal Information if we cannot verify your identity or authority to make the Request and confirm the Personal Information relates to you.
You do not need to create an account with us to exercise your rights.
We will only use Personal Information provided in the Request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your Request within ten (10) business days of our receipt thereof. If you do not receive confirmation within the ten (10) day timeframe, please contact us at email@example.com.
We will endeavor to provide a substantive response to a Verifiable User Request within thirty (30) days of receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of your Request. The response we provide, if applicable, will also explain the reasons we cannot comply with a Request.
We do not charge a fee to process or respond to your Request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the Request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your Request.
Links to Third Party Websites
Our Services, email updates, and other communications may, from time to time, contain links to and from the websites of others. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
This Policy does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual.
Not Directed to Children
Our Services are intended for use by users over the age of 18. We do not direct our Site or Services nor offer services to children under the age of 18. Should we become aware of a child under 18 who provides their Personal Information to us, we will, depending on the context of how such information was provided, use that information to respond to that child to inform him or her that they cannot use our Services, and then promptly delete that information.
Our Site and Services are intended solely for users in the United States. If you access our Site or Services in another country, you do so at your own risk and understand and agree that we and our Providers may collect, store, maintain and process your information on servers located in the United States.
We may update this Policy from time to time. When we update the Policy, we will notify you by updating the “Last updated” date at the bottom of this Policy, posting the new Policy, and providing any other notice required by applicable law. We recommend that you review the Policy each time you visit the Site or use the App to stay informed of our privacy practices. If you do not agree or consent to these updates or changes, do not continue to use the Services.
If you have any questions about this Policy, please contact us at:
Auto Enablers LLC
712 Fifth Avenue
New York, NY 10019
Last Updated: April 20, 2023