Effective Date: December 15, 2020
This Policy describes: (1) the types of Personal Information we may collect; (2) the purposes for which we collect Personal Information; (3) the parties with whom we may share this information; (4) your rights and choices; (5) how to contact us with your questions or concerns; (6) and the measures we take to protect Personal Information.
This Policy applies to the processing of Personal Information by CarLabs in the context of its publicly available websites, including www.carlabs.com and www.carlabs.ai (collectively, our “Website”) and in connection with its customer, partner, and vendor relationships (“Business Data”).
CarLabs is the data “controller” for purposes of the European General Data Protection Regulation (“GDPR”) (or for California residents, a “business” as such term is defined under the California Consumer Privacy Act of 2018 (“CCPA”)) for the processing of Personal Information on our Website and for the processing of Business Data.
For the purpose of this Policy, “Personal Information” means “any information relating to an identified or identifiable natural person.” This Policy does not apply to information collected by us from our employees, which are governed by other policies. By accessing and continuing to use the Website or the Software Services you consent to the terms and conditions of our Policy. If you do not agree with any part of this Policy, please do not access or continue to use any of our services or otherwise submit your Personal Information.
- Personal Information We May Collect or Receive
Depending on the context in which you interact with us, we may collect or receive the following types of information, including Personal Information, from and about you:
- When you submit requests or inquiries on our Website (including when requesting additional information, services, or support from us), we may collect your name, title, company name, address, phone number, and email address, and certain company information.
- We may collect information about the devices accessing our Website and Software Services. Some examples are: type of device, operating system used, application information, unique device identifiers and crash data. The type of information we collect depends on the type of device used and its settings.
- When you correspond with us via email, we may collect the Personal Information included in your email.
- We may obtain Personal Information from third-party business partners such as the contact details of prospects and sale leads from our resellers.
- Like many websites, we use “cookies” to collect visitor information. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser. If you have provided your name or other contact information to us via a web form, we are able to link that information back to the cookie. Using cookies makes it possible for us to recognize your browser when you visit and to tell us whether Customers and visitors have visited the Website previously. This information may also be used to provide you with information that we believe to be relevant to you based on your actions on our Website.
We may collect Personal Information from our existing and prospective Customers, vendors, and partners:
- When Customers register to use the Software Services (and related services, such as customer support), we may require them to provide us with contact information (such as name, company name, phone number, and email address). They may voluntary decide to communicate additional Personal Information (such as title, department name, fax number, and additional company information, such as mailing address, annual revenues, number of employees, or industry). We may use the email address provided during the registration process to generate a username and temporary password for Customers.
- We collect information about Customers’ use of the Software Services and our Customers’ own customers and users.
- We collect Customers’ contact details to send them information about our products or services.
- We collect Personal Information of vendors’ and partners’ employees as provided by vendors or partners for purposes of the obtaining and using the vendor’s services or in furtherance of the relevant partner relationship.
- How We May Use Personal Information
We may use the information that we collect about you or that you provide to us, including any Personal Information, in the following ways:
- We use data we collect to provide the Website and Software Services that we offer. This includes operating, maintaining and providing you with all the content and features of the Website and Software Services.
- To inform you about CarLabs and our products, services and partners, including to send you marketing promotions.
- To diagnose and resolve issues with and otherwise improve our Website or Software Services.
- To protect the security of our services, employees and users, detect and prevent fraud, and to resolve disputes.
- To send administrative information to you, for example, information regarding the services and changes to our terms, conditions, and policies of our Website and Software Services.
- To carry out our obligations and enforce our rights arising from any agreements between you and us.
- To understand usage patterns on the Website and Software Services.
- To set up the Software Services for individuals and their organizations.
- In connection with prospective service engagements, partnerships or vendor relationships.
- How We May Share Personal Information
We may disclose your Personal Information as follows:
- To our affiliates or subsidiaries as necessary to provide our products and services.
- To our service providers in support of our business. We do not authorize these service providers to use or disclose your Personal Information except as necessary to perform certain services on our behalf or comply with legal requirements. We require these service providers to safeguard the privacy and security of personal information they process on our behalf.
- To an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
- We may disclose your Personal Information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
- We do not share your Personal Information with third parties or unaffiliated companies for their marketing purposes unless you opt-in to that sharing.
- Your Rights and Choices
We seek to provide you with choices regarding the Personal Information you provide to us.
- Marketing communications from CarLabs. If you do not wish to receive email marketing communication from us, you can opt-out by sending an email to email@example.com. You can also unsubscribe from email marketing communications by following the instructions contained in the marketing messages you receive. Even if you opt-out or unsubscribe, we can send you certain communications relating to our services, such as administrative messages related to Customer accounts. You cannot opt-out of receiving those messages. Where required under applicable law, we will only send you marketing communications with your consent.
- Right of access, deletion, correction of your Personal Information. Subject to applicable law, you may have the rights to request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, and have the information blocked or deleted, as appropriate. These rights may be limited in some circumstances by local law. To exercise these rights, please contact us as set forth below in Contact Us (Section 14) below.
- Customers’ account information. You can update, edit or remove your account information at any time by logging into the Customer portal.
- If you are a California Resident, see Your California Privacy Rights (Section 7) below.
- If you are in the EU, see the GDPR (Section 6) below.
You can choose not to provide us with your Personal Information, but if you do not provide us with your Personal Information when we request it, we may not be able to provide you with our full range of products and services, or provide a service appropriately tailored to you.
If you are a resident of the European Economic Area (EEA), we collect and process Personal Information about you only where we have a legal basis for doing so under applicable data protection law, including under the GDPR. The legal bases will depend on the purpose for which we process your Personal Information. This means that when we collect and use your Personal Information, we are obligated to:
- Ensure that personnel accessing Personal Information are subject to confidentiality duties;
- Process Personal Information based on Customer instructions or applicable laws;
- Apply technical and administrative measures to protect Personal Information;
- Assist Customers in responding to requests from individuals about their Personal Information;
- Assist Customers in fulfilling their legal duties including regarding notification of data breach;
- Delete Personal Information at the conclusion of the contracted services except where retention is required or permitted by law;
- Provide Customers with information required to fulfill regulatory and audit obligations; and
- Obtain Customer consent when engaging a subprocessor to process Personal Information in connection with the CarLabs-branded products.
EU or Swiss residents with inquiries or complaints regarding this Policy should contact CarLabs as set out in Contact Us (Section 14) below.
- Your California Privacy Rights
This section provides additional details about the Personal Information we may collect about California consumers and the rights afforded to them under the CCPA.
For more details about the Personal Information we have collected over the last 12 months, including the categories of sources, please see the Personal Information We May Collect or Receive (Section 2) above. These categories include identifiers, commercial information, financial data, internet activity information and professional or employment-related information as described in Section 1798.140(o) of the CCPA.
We collect this information for the business and commercial purposes described in this Policy including How We May Use Personal Information (Section 3) above.
We share this information with the categories of third parties described in the How We May Share Personal Information (Section 4) above.
Subject to certain limitations, the CCPA provides California consumers a number of rights, specifically:
- the right to request to know more details about the categories or specific pieces of Personal Information we collect, including the sources of the Personal Information, commercial purposes for which it is used (including details on how used and disclosed Personal Information) and request a copy of the Personal Information that we have collected about you during the past 12 months;
- to delete their Personal Information;
- to opt out of any “sales” of Personal Information that may be occurring; and
- to not be discriminated against you for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us as set out in Contact Us (Section 14) below.
We will verify your request using the information we currently hold about you, including email address. Further information may be required in order to identify you. Consumers can also designate an authorized agent to exercise these rights on their behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases, we may be required or permitted by law to deny your request.
- Data Security
We take reasonable steps given the context of the engagement in which data is provided to protect your Personal Information from loss, misuse, interference, unauthorized access, disclosure, alteration, and destruction. However, the security of information transmitted through the Internet can never be guaranteed and is not entirely within our control. Where you receive a password for access to certain parts of our Website or the Software Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
- Cross-Border Data Transfers
We may transfer your Personal Information to countries other than the country in which the data was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided that information. When we transfer your Personal Information to other countries, we will protect it as described in this Policy.
To offer our services, we may need to transfer your Personal Information among several countries where we have service providers, including the United Sates, where we are headquartered. By using the Software Services or otherwise providing Personal Information to us, you consent to the transfer of Personal Information to countries outside of your country of residence, including the United States.
- Links to Other Websites
Our Website or the Software Services may contain links to websites of third parties who: (1) are not affiliated with us; (2) are outside our control; or (3) are not covered by this Policy (“Third-Party Websites”). Links provided to Third-Party Websites on our Website or the Software Services are provided only as a convenience to you. The inclusion of any link does not imply its reliability or an endorsement by us of the content or security. We are not responsible for the privacy practices of Third-Party Websites, which may collect and use information from you in a manner different than how we do so. Accordingly, the use of such Third-Party Websites is entirely at your own risk. For relevant information, you should review the privacy statements or policies of any Third-Party Websites before using them. Other parties may collect information about your online activities over time and across different websites when you use our Website or the Software Services.
- Changes to This Policy
We reserve the right to modify this Policy at any time, so please review it frequently to see when the Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on our Website or via the Software Services. Your continued use of the Website or Software Services is deemed to be acceptance of such changes, to the extent permitted under applicable law.
- Age Limitations
CarLabs does not allow the use of our Software Services and Website by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with Personal Information, please contact us and we will take steps to delete such information.
- Required cookies. Some cookies are strictly necessary to enable core site functionality. For example, we may use required cookies to authenticate your access to various secure areas of our Website that may contain content for registered users.
- Performance cookies. These cookies allow us to enhance your browsing experience, tailor content to your preferences, and make your interactions with our Website more meaningful. For example, performance cookies may be used to determine whether you have visited our Website before and inform us about site features in which you have interest, thereby permitting us to better tailor the site to our users.
- Advertising cookies. In addition to required and performance cookies, some third parties issue cookies through our Website to serve advertising that is relevant to your interests based on your browsing activities. These ad targeting cookies also allow us to analyze Website traffic so we can measure and improve performance. These third parties may also collect your browser history or other information to determine how you reached our Website and the pages you visit when you leave our Website. Information gathered through these automated means may be associated with the personal information you previously submitted on our Website.
Web beacons (also known as internet tags, pixel tags, and clear GIFs) are clear electronic images that can recognize certain types of information on your computer, such as the type of browser used to view a website page, when you viewed a particular site linked to the web beacon, and a description of a site tied to the web beacon. Certain pages on our Website may contain such web beacons, which CarLabs uses to operate and improve the Website.
How to Control Cookies?
However, be aware that any preference you have set will be lost if you delete all cookies, including your preference to opt-out from cookies as this itself requires an opt-out cookie to have been set. Also bear in mind that removing or blocking cookies can affect your user experience and without cookies, you may not be able to take full advantage of our Website features.
- Contact Us
If you have questions about this Policy, the Website or the Software Services, would like to opt out from certain services, or to exercise your rights, contact us:
- via email at firstname.lastname@example.org; or
- via mail at CarLabs Inc., 1920 Hillhurst Avenue, Suite V946, Los Angeles, CA 90027
- via telephone on the contact numbers set out on our Website