Flexcar Privacy Policy
Last updated: February, 2024
This Flexcar Privacy Policy describes how Flexcar™, LLC, and our subsidiaries and affiliated companies (collectively, “Flexcar”, “we”, “us”) collect, use, and disclose information about you. This Privacy Policy applies to information we collect from you as a consumer when you access or use our websites, mobile applications, and other online products and services, or when you otherwise interact with us where we provide this Privacy Policy (collectively, “Services”). In some circumstances, we may provide different or additional notices of our privacy practices to the extent they apply to you because of the product or services you obtain from us, the capacity in which you engage with us, or different laws that may apply. If you are a resident of California, then the Additional California Privacy Rights applies to you.
Any terms not defined in this Privacy Policy have the meanings provided in the Flexcar
Terms of Use. or
Membership Agreement. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. We may also provide you with additional notice (such as by adding a statement to the Services or sending you a notification), such as in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
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We collect and use your information in a variety of ways. We collect information you provide directly to us. For example, we collect information directly from you when you create an account, fill out a form, request Services or customer support, or otherwise communicate with us. We also collect certain information from you or your device automatically when you interact with our Services such as activity or usage information. We use this information to provide you Services and for other business purposes. The types of information about you that you provide and that we collect automatically from you are listed below along with our uses of that information. In addition, if you add an Additional Driver or Authorized Driver, we collect the information you provide about them, which can include the information listed below and which we may use as described below. By providing their information, you represent that you have the right to provide that information to us and have provided all legally required notices and obtained all necessary consents in order to do so.
Types of Information We Collect and Usage
Identifiers, including name, user name, email address, postal address, online identifier, IP address, payment card information, Social Security Number, driver’s license number, Passport number.
Customer records, including name, user name, email address, postal address, telephone number, photo, Social Security Number, driver’s license number, passport number.
Commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories
- Providing services, including maintaining and servicing accounts, improving, and developing new products and services, debugging and repairing errors in our Services
- Providing customer service
- Processing or fulfilling transactions
- Verifying customer information, including your driving record, and checking your credit history
- Processing payments
- Communicating with you
- Direct marketing
- Targeted Advertising
- Analytics
- Security
Characteristics of protected classifications, including age and gender.
- Providing services, including maintaining and servicing accounts, improving, and developing new products and services, debugging and repairing errors in our Services
- Verifying customer information, including your driving record, and checking your credit history
- Processing or fulfilling transactions
- Analytics
Internet or other electronic network activity information, including browsing history, search history, information regarding your interaction with the Services or ads, usage information, internet service provider, device ID, cookie or other tracking information and technologies
- Providing services, including maintaining and servicing accounts, improving, and developing new products and services, debugging and repairing errors in our Services
- Customizing and improving our services, including recording information about your browsing session on the Services, including which pages you visited and any forms on the website that you filled in
- Providing customer service
- Verifying customer information
- Direct marketing
- Targeted Advertising
- Analytics
- Security
Geolocation data, including precise geolocation and approximate location based on IP address
- Providing services, including maintaining and servicing accounts, improving, and developing new products and services, debugging and repairing errors in our Services
- Verifying customer information, including your driving record, and checking your credit history
- Direct marketing
- Targeted Advertising
- Analytics
Audio, such as call recording.
- Providing services, including maintaining and servicing accounts, improving, and developing new products and services, debugging and repairing errors in our Services
- Providing customer service
- Verifying customer information, including your driving record, and checking your credit history
- Security
Inferences drawn from personal information to create a profile about consumer’s preferences, characteristics, behavior
- Providing services, including maintaining and administering our website and applications
- Direct marketing
- Analytics
Sensitive personal information, including account log in and password, Social Security Number, driver’s license number, passport number, precise geolocation, biometric data
- Providing services, including maintaining and servicing accounts
- Providing customer service
- Verifying customer information, including your driving record, and checking your credit history
- Processing or fulfilling transactions
- Analytics
- Security
- We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
- In addition, we may use the personal information we collect or that is collected on our behalf to create de-identified, anonymized, or aggregated information that no longer identifies or relates to a specific person. We use such de-identified, anonymized, or aggregated information in accordance with applicable law.
- We may also use the personal information we collect or that is collected on our behalf to comply with legal and financial obligations and/or to carry out any other purpose described to you at the time the information was collected.
Third-Parties That Collect Information On Our Behalf
- Payment Processors. If you make a payment through our Services, we work with a third-party payment processor that collects and processes your payment information, and we do not directly handle your payment card information.
- Biometric Identity Verification Providers. If you use our Services to obtain a vehicle, in order to pick up your vehicle, we work with a third-party biometric identity verification provider that collects your government ID and selfie and compares them to each other using machine learning, biometric information tools, and/or other technologies to verify your identity. See the Biometric ID Verification Provider Privacy Policy to learn about their privacy practices [https://www.onefootprint.com/privacy-policy]. The Biometric ID Verification Provider allows Flexcar to access the government ID, selfie, and information generated from the selfie for as long as necessary for Flexcar’s identity verification, fraud prevention, and security purposes, but deletes this information no later than 3 years after your last interaction with us.
Information Our Vehicles Collect
Flexcar, through its vehicles, collect certain information to, among other things, manage its vehicles and provide our Services. More specifically, the vehicles you rent from us are equipped to collect certain information regardless of whether it is being rented or driven and is not necessarily associated with a particular individual or driver but in some cases can be. Our vehicles collect the following information:
- GPS. Our vehicles provide their precise geolocation through the use of their Global Positioning Systems. We use this information to provide our Services, including to help you locate your vehicle, provide roadside assistance, locate lost or stolen vehicles, improve our products and services
- On-board vehicle movement monitoring and detection. Our vehicles are equipped with systems that may monitor the state of the vehicle, regardless of whether they are being used, and collect information such as crash detection factors or rate of braking or acceleration.
- Connected Car Data. Some of our vehicles are connected cars, which means that they are equipped with features such as telematics systems, on-board devices, or built-in services and technologies that are capable of collecting data about the vehicle and its use, including, for example, the vehicle’s condition, damage and accident events and records, performance, operation and diagnostic data, information on mileage, acceleration, braking, speed, fuel consumption, fuel level, tire pressure, odometer, location and direction, and other vehicle-related information (collectively, “Connected Car Data” or “Vehicle Data”). Typically, this information is associated with the vehicle only and maintained as non-personal information. If we link this information to you, we will treat it as personal information. In some cases, third parties offer technologies in your vehicle and collect Connected Car Data pursuant to their privacy policies, which apply to your use of those technologies.
Information We Collect from Other Sources
In addition to collecting information from you, we obtain information from other sources. For example, we may collect and process information from identity verification services, credit bureaus, motor vehicle record providers, advertising networks, data analytics providers, mailing list providers, company’s internal services, insurance providers, financial services providers, and data brokers or marketplaces. This information includes your name, driving record, driver’s license number, information from your government issued ID, selfie, credit information, address, and email address. If you refer a friend to Flexcar, you provide your friend a code that is activated when your friend signs up with Flexcar, which then informs us that you referred that friend. Additionally, if you create or log into your Flexcar account through a third- party platform (such as Facebook or Google), we will have access to certain information from that platform, such as your name, birthday, and profile picture, in accordance with the authorization procedures determined by such platform.
Financial [loan] Information
At your direction, we provide your information to a third-party Method Financial (“Method”) in order for us to obtain from Method information about loans or liabilities you might have. We use this information to help inform our decision to offer services to you. Method will collect, use, disclose, and retain your information in accordance with its Privacy Policy and Terms of Use, to which you acknowledge and agree: Method's
Privacy Policy and
Terms of Service.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.
Retention of Personal Information
We will retain your Personal Information for as long as reasonably necessary to carry out the purposes disclosed in this policy.
We disclose the following categories of personal information to the recipients described below for the following business purposes or as otherwise described in this policy:
Identifiers, Customer Records, Commercial Information
- Service providers and contractors that perform services on our behalf or that assist us with our business purposes described above, including Internet service providers, data analytics providers, operating systems and platforms, payment processors, identity verification providers, payment risk vendors, credit bureaus, fulfilment partners, customer support partners, marketing service partners, and fraud prevention partners
- Third parties, including Advertising networks, those to whom you consent to or direct we provide your information
- If you provide a testimonial for use on our Services or comment on a public forum, we disclose and post your name, user name, and/or photo along with your comments on our public website
Characteristics of protected classifications
- Service providers and contractors that perform services on our behalf or that assist us with our business purposes described above, including Internet service providers, data analytics providers, operating systems and platforms, payment processors, identity verification providers, payment risk vendors, credit bureaus, fulfilment partners, customer support partners, marketing service partners, and fraud prevention partners
Internet or other electronic network activity information
- Service providers and contractors that perform services on our behalf or that assist us with our business purposes described above, including Internet service providers, data analytics providers, operating systems and platforms, payment processors, identity verification providers, payment risk vendors, credit bureaus, fulfilment partners, customer support partners, marketing service partners, and fraud prevention partners
- Third parties, including Advertising networks, those to whom you consent to or direct we provide your information
Identifiers, Customer Records, Commercial Information
- Service providers and contractors that perform services on our behalf or that assist us with our business purposes described above, including Internet service providers, data analytics providers, operating systems and platforms, payment processors, identity verification providers, payment risk vendors, credit bureaus, fulfilment partners, customer support partners, marketing service partners, and fraud prevention partners
- Third parties, including Advertising networks, those to whom you consent to or direct we provide your information
- If you provide a testimonial for use on our Services or comment on a public forum, we disclose and post your name, user name, and/or photo along with your comments on our public website
Geolocation data
- Service providers and contractors that perform services on our behalf or that assist us with our business purposes described above, including Internet service providers, data analytics providers, operating systems and platforms, payment processors, identity verification providers, payment risk vendors, credit bureaus, fulfilment partners, customer support partners, marketing service partners, and fraud prevention partners
Inferences drawn from personal information
- Service providers and contractors that perform services on our behalf or that assist us with our business purposes described above, data analytics providers, marketing service partners
Sensitive Personal Information
- Service providers and contractors that perform services on our behalf or that assist us with our business purposes described above, including Internet service providers, data analytics providers, operating systems and platforms, payment processors, identity verification providers, payment risk vendors, credit bureaus, fulfilment partners, customer support partners, marketing service partners, and fraud prevention partners
In addition, we may disclose any of the categories of personal information listed above for the following purposes:
- We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
- We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Flexcar, our users, the public, or others.
- We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
- We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
- Personal information is disclosed between and among Flexcar and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
- We disclose personal information with your consent or at your direction.
We also use and disclose aggregated or de-identified information that cannot reasonably be used to identify you.
Advertising and Analytics
We engage others to provide analytics services and serve advertisements across the web and in mobile apps subject to certain written agreements where required by law. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. Flexcar and others may use this information to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. In some cases, we may record information about your browsing session to help us identify technical issues or to improve our products and Services. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit
www.aboutads.info/choices. Go to
Facebook Ads Opt-Out to opt out of Facebooks ads. Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.
Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our Sites or services on your browser or mobile device, log in to your account on our services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our service and to tailor our advertisements and content to you. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimize, and display ads based on your past visits to the services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, go to
Google Analytics Privacy Policy or to
Google Opt-Outs to learn about Google Analytics' currently available opt- outs. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the
Google Ads Preferences Manager or
NAI's online resources.
Social Sharing and Links. Our website may include social media features, such as the Facebook Like button and widgets, such as the Share This button or interactive mini-programs that run on our Sites. These features may collect your IP address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. Social media features and widgets may be either hosted by a third party or hosted directly on our Sites. Your interactions with these features are governed by the privacy notice of the company providing it.
Social Media Advertising. We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.
Do Not Track. Some browsers support a "Do Not Track" feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Sites operated by Flexcar do not currently respond to those signals. If you block or reject cookies, not all of the tracking described here will stop.
Flexcar is headquartered in and offers Services to those in the United States, and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law.
Your Choices
Account Information
You may update and correct certain account information at any time by logging into your account and editing your information. If you have questions about your account, please contact us at
[email protected].
Location Information
When you first launch any of our mobile apps that collect precise location information, you will be asked to consent to the app’s collection of this information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of this location information by following the standard uninstall process to remove all of our mobile apps from your device.
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
California Notice and Privacy Rights
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.), as amended by the California Privacy Rights Act (“CPRA”), affords consumers residing in California certain rights with respect to their personal information. So, in addition to the notices provided above, if you are a California, this section applies to you as indicated.
California Sales and Sharing of Personal Information
California law requires that we provide transparency about personal information we “sell” or “share.” “Sale,” for the purposes of the CCPA, broadly means scenarios in which we have disclosed personal information with partners in exchange for valuable consideration, while “sharing” means we have disclosed information to a third party for cross-context behavioral advertising. In addition, the CCPA has been interpreted to deem this “sharing” to also be a form of “sale.” Accordingly, in the preceding twelve (12) months, Flexcar has “sold” or “shared” your personal information to or with third parties for cross- context behavioral advertising, such as targeting of advertising to you based on your personal information obtained from your activity across businesses, websites, apps, and services other than our Services. See the Targeted Advertising and Analytics section above for more information about behavioral advertising. See Privacy Rights below to learn how to opt out of these activities.
We do not knowingly sell or share personal information about consumers under the age of 16.
California Shine the Light
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to
[email protected] or Flexcar Privacy, 200 Pier 4 Blvd., Boston Massachusetts 02210 USA.
Privacy Rights
Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request correction of your personal information, (3) request deletion of your personal information, and (4) not be discriminated against for exercising these rights. You may make these requests by sending an email to
[email protected]. You can opt out of targeted advertising
here. If we need to further verify your request, we may do so by asking you to provide information related to your interactions with us.
If we deny your request, you may appeal our decision by contacting us at
[email protected]. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.
If you have any questions about this Privacy Policy, please contact us at
[email protected] or Flexcar Privacy, 200 Pier 4 Blvd., Boston Massachusetts 02210 USA.