Last Updated 12.28.20
• access, use, or download our mobile application (“Mobile App”),
• visit or use our website at www.thewhyroad.com (the “Site”),
• access or request any content or information from us, or
1. How We Collect, Use, and Share Your Information
We collect certain information about you when you visit or use our Services. This information may personally identify you or have the potential to personally identify you (“Personal Information”). In this section, we describe the Personal Information we may collect about you and the sources of that information.
Information We May Collect
• Identifiers: We may collect your full name, email address, phone number, physical address, IP Address, device ID, or other similar identifiers. We may also collect any other Personal Information that you provide to us, such as social media identifiers or language preference.
• Internet or Other Electronic Network Activity Information: We may collect information regarding your interaction with the Services, including time of visit and geolocation data, pages visited, links clicked, emails opened, language preferences, and the pages that led or referred you to our Services. We may also collect information automatically from your device, such as device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, and add-ons.
• Geolocation Data: We may collect your physical location or infer your physical location based on your IP address, mailing address, or other network or voluntarily-provided information.
• Commercial Information: We may collect information about the products or services you have purchased, obtained, or considered from us; and information about how you progress through or engage with a course, including survey results or your contributions.
• Payment Information: In order to process your subscription fees, we collect credit card information, bank account number, or other payment information.
You may refuse to provide, or request that we delete, certain categories of Personal Information we have about you. However, if our collection of the Personal Information is required by law or contract or is necessary for you to access or use the Services, we may be unable to provide the Services to you. Please note that if you request that we delete all of the Personal Information we have about you, we may need to delete your user account.
Sources of Your Personal Information
• We may automatically collect certain information about the computer or other devices that you use to access the Services, including mobile devices, through commonly used information-gathering tools, such as cookies, pixels, and web beacons (more information is in our Cookies section below).
• You provide some Personal Information to us directly. For example, you provide Identifiers (such as name, email address, and billing address) and Payment Information (such as credit card information or bank account information) when you make a purchase from us.
• We may generate information about you based on our relationship with you or your use of the Services, such as transaction history or visit history. Such information may be aggregated or anonymized before we process it.
• Third parties or public sources may provide us with certain Personal Information. For example, we may collect Personal Information from publicly accessible social media profiles and posts, public databases, private third parties, law enforcement, or other public sources. In some cases, we may link the information provided by third parties to other Personal Information we already have about you.
2. How We Use Your Personal Information
This section describes the purposes for which we process your Personal Information. We process your Personal Information:
• For legitimate business interests which outweigh the general privacy rights of individual data subjects. This includes but is not limited to analyzing and improving our Services and business operations; enhancing the performance of the Mobile App or the Site; web analytics; direct marketing; ensuring the security and availability of the Services; and monitoring use of the Mobile App or the Site to prevent fraud or abuse.
• To comply with a legal obligation or requirement. We use and process your Personal Information when we believe doing so is necessary to comply with laws and regulations, pursuant to a judicial authorization, or to exercise or defend our legal rights or those of a third party.
• With your consent. We process your Personal Information if we obtained your affirmative consent to such processing, such as to send you communications that you requested, or to respond to inquiries and questions that you initiated.
• If we need to process your Personal Information for a purpose other than that for which the information was initially collected, we will provide you with information about that other purpose before we further process your Personal Information.
3. How We Share and Disclose Your Personal Information
We understand that you entrust us with your Personal Information, which is why we try to be transparent about if and when we share your Personal Information with third parties, other users, or our business partners. Below, we explain the reasons why we may share your Personal Information with third parties:
• With your consent. We share your Personal Information if you affirmatively consent to it. If we are legally obligated to obtain your consent prior to sharing your Personal Information, we notify you of the specific purpose for which we are obtaining your consent, and we do not share beyond that purpose without notifying you of and obtaining additional consent for further disclosure.
• For legal disclosure. We may share your information with third parties when we reasonably believe disclosure is required or permitted in order to comply with a subpoena, court order or other applicable law, regulation or legal process.
• To protect us or others. We may share your information with third parties, law enforcement, other governmental agencies, or legal counsel to the extent we believe that sharing such information is necessary to protect the rights, property, or safety of us, our products or services, our customers, or others.
• As aggregate information. We may share certain aggregated, non-personally identifying information internally or with others for purposes of research, reporting, and benchmarking.
• As a result of merger or sale of our business. We may share your Personal Information if we are involved in a merger, sale, financing, liquidation, bankruptcy or acquisition of corporate entities or business units.
We do not sell any Personal Information for any reason.
4. Your Access to and Control Over Information
You can review and change your Personal Information by logging into your account and visiting your account settings page.
You may also send us an email at firstname.lastname@example.org to request access to, correct, or delete any Personal Information that you have provided to us. We may need to delete your user account in order to delete all of your Personal Information. Please note that we may be unable to respond to a request if we cannot verify that you are the owner of the Personal Information that is the subject of the request, if deletion of your Personal Information is technically infeasible, or if we need to retain your Personal Information to comply with our legal obligations.
California residents may have additional rights. Please refer to the California Privacy Notice below.
While no online service is 100% secure, and we make no guarantee about the security of your Personal Information, we implement reasonable security measures to protect information about you against unauthorized access, use, alteration, or destruction. We monitor our Services for potential vulnerabilities and attacks, and we use a variety of security technologies and organizational procedures to help protect your Personal Information from unauthorized access, use, or disclosure. However, any transmission of Personal Information via the Services is at your own risk. We are not responsible for 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 this password with anyone.
6. How We Retain Your Personal Information
7. Children’s Privacy
8. Do Not Track Disclosure
9. Third Party Data Practices
10. Cookies Policy
Your web browser may allow you to control the cookies we and other websites set on your computer. Please consult the help section of your web browser for more information on how to delete cookies. However, note that if you choose to delete or disable cookies, we may be unable to provide the Services to you.
11. Notification of Changes
12. Contact Information
13. California Privacy Notice
This California Privacy Rights Notice (“Notice”) applies only to individuals residing in the State of California who are considered “consumers” and from whom we collect “personal information” as those terms are defined in the California Consumer Privacy Act of 2018 (“CCPA”). We will update this Notice at least once every twelve (12) months to reflect changes in our business, legal or regulatory obligations, so please check this Notice periodically for changes.
How We Collect, Use, and Disclose Your Data
In the last 12 months, we have collected the categories of Personal Information from the categories of sources listed in Section 1 above. We have used those categories of Personal Information for the business or commercial purposes specified in Section 2 above. We may have disclosed or shared, to the categories of third parties listed in Section 3 above, the following categories of Personal Information:
• Internet or Other Electronic Network Activity Information
• Geolocation Information
• Commercial Information
• Payment Information
Your CCPA Rights and Choices
California consumers have the following rights regarding our use and disclosure of your personal information, subject to certain limitations in the CCPA:
• The right to know. You may request, up to twice in a 12-month period, the following information about the Personal Information we have collected about you during the past 12 months:
o the categories of Personal Information we have collected about you;
o the categories of sources from which we collected the Personal Information;
o the business or commercial purpose(s) for collecting the Personal Information;
o the categories of third parties with whom we shared the Personal Information;
o the categories of Personal Information we have sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information.
• The right to delete. You may request that we delete the Personal Information we have collected about you, subject to certain limitations under applicable law. We may be unable to delete all of your Personal Information if we need to retain your Personal Information:
o To complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you;
o To detect data security incidents;
o To debug or repair any errors;
o To protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
o To use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e., to improve our services).
• The right to opt-out from a sale. The Why Road does not sell any Personal Information for any reason.
• The right to non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.
You may exercise any of the rights above by submitting a request using the Contact Information provided above. We may need to verify your identity before responding to your request, such as by requesting government-issued identification or confirming your full name, email address or account access.
You may authorize someone to act as your agent and submit a CCPA request on your behalf. Before we will respond to any such request: (1) we require your agent to provide us with written evidence of permission to act on your behalf, and (2) you must verify your identity directly with us, unless your authorized agent is acting pursuant to a power of attorney under the California Probate Code.