Regarding personal information
Thank you for your recent request to know about your personal information — your privacy is very important to us. Provided with this document is a file containing your personal information. If you requested access to your data categories, the file will contain the categories of personal information (PI) we have collected about you. If you requested access to your data, the file will contain your specific pieces of PI with the category of each piece of PI identified.
The personal information was sought from the records of Avail.
Your personal information file:
Per your verified request, we are providing you a file containing the personal information about you that is subject to the California Consumer Privacy Act (CCPA).
Please also note the following about your personal information file:
- The amount and type of personal information included in the attached file will vary based on your relationship with Avail. Based on the personal information about you that we located, it appears that you are an individual with whom Avail's car sharing service has interacted for marketing purposes. It is likely that this interaction occurred via focus group or social media.
- If you requested access to your specific pieces of data:
- the way the personal information is presented will vary based on how the information is kept in our system. Some of your information has been redacted or not returned due to risk of fraud as required by CCPA, such as social security numbers, drivers' license numbers, financial account numbers or account passwords. We will let you know that we have collected it but will not provide you with the actual personal information in the response; and
- for each piece of personal information returned, we have indicated the category in which that piece of personal information belongs. The categories are listed below with examples of the types of personal information that fall into each category. Those categories allow you to better understand the personal information that is shared and with whom it is shared.
- To protect consumer's privacy, we only return personal information that we are confident belongs to you. That would mean some data that might belong to an individual with a similar name or address may not be returned to you if we aren't certain it is yours. We will also not return data that belongs to multiple parties on an account.
To view your personal information, please refer to the attached document titled with your name.
For additional information on how to read the personal information file, please see the attached "Frequently Asked Question" document.
Categories of personal information, sources of personal information, business purposes and third parties:
As required by the CCPA, the following response, together with the information contained in the personal information file, explains the following for the personal information collected in at least the past 12 months:
- The categories of personal information collected;
- the categories of sources from which personal information was collected;
- the business or commercial purposes for collecting personal information; and
- the categories of third parties with whom we share personal information and the personal information shared with those categories of third parties.
1. The categories of personal information collected:
The file of your personal information shows the category of personal information for each piece of information. These are the categories:
| Personal information categories | Examples |
|---|---|
| Personal identifiers | Name, alias, signature, postal address, phone number, date of birth, unique personal identifier, online identifier, email address, internet protocol (IP) address, state identification card number, account name, driver's license number, or other similar identifiers. |
| Personal characteristics | Age, race, and sex (including gender, gender identity, or gender expression). |
| Biometrics and multimedia information | Faceprint, audio, electronic, visual, or similar information |
| Internet or other electronic network activity information | Browsing history, search history, information regarding your interaction with our websites, mobile application or advertisements, links you use or web pages you visit while visiting our websites or mobile applications, browser type, internet service provider (ISP) or mobile service provider, cookies, and mobile device information including device identifier or other information. |
2. The categories of sources from which personal information was collected
We collect personal information about you in several ways and from several sources based on your relationship with us, including:
- Directly from you: We and service providers working on our behalf may collect information directly from you when you use our mobile applications or websites including AvailCarSharing.com, AvailCommunities.com, and www.AvailAssist.com, respond to our emails, or subscribe to our mailing list.
- Automatically: We and service providers working on our behalf may collect personal information from you automatically when you use one of our websites, mobile apps, view our emails or otherwise engage with us through a computer or mobile device ("Sites") such as IP address, browsing history and other internet activity information.
- From third parties: We also may collect personal information about you from third parties such as insurance companies, consumer reporting agencies, service providers, marketing companies and data providers.
- From other Avail customers: We may also collect information about you from other Avail customers to carry out necessary services and/or requests, including when a customer adds additional drivers. If other Avail customers give us your personal information or if you provide us personal information about others, we will only use the information for the specific reason for which it was provided to us.
3. The business or commercial purposes for collecting personal information
We use your personal and other information for business purposes including to:
- Improve, develop, and analyze our Sites and services. We use your personal information and other information to:
- analyze, improve, develop, and offer new and existing services, products, features and models, analytics software, and other similar methods,
- analyze how visitors use our Sites, improve, develop, or deliver our Sites and enhance and personalize your experience on our Sites. Some of the information used for these purposes is collected using analytics software, cookies, and other tracking technologies, and
- conduct research studies to maintain, develop or protect our services, customers, and networks.
- Provide marketing communications. We may use your personal information to send you promotional communications about services, features, and options we believe may interest you. We may send communications via e-mail, regular mail or may send push notifications via a mobile device. We may also use your information to serve you ads or customized content online.
- Comply with legal requirements and protect the safety and security of our business, services, and Sites. We may use your personal information to comply with laws, regulations, or other legal obligations, to assist in an investigation, to protect and defend our rights and property or the rights of third parties or enforce terms and conditions. We may also use your personal information to prevent suspected fraud, threats to our network or other illegal activities, prevent misuse of our products or services, or for any other reason permitted by law. We may use your personal information to protect our company, our affiliates, our customers, our network, and our Sites.
- Update or correct our records. We may receive personal information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine that personal information with other personal information we have about you to update our records. For example, we may obtain change of address information from public sources and use that personal information to update or correct your address.
4. The categories of third parties with whom we share personal information and the personal information shared with those categories of third parties
We do not sell your personal information. We may share your personal information with our affiliates for business purposes consistent with the uses described in our Privacy Policy. We strive to work with companies that share our commitment to privacy. We may also share information with others in an aggregated or de-identified form that does not reasonably identify you.
We may also share your personal or other information with service providers and other third parties for business purposes or as required or permitted by law including with:
- Service providers: Personal information may be shared with service providers who perform services on our behalf for a business purpose including service providers that:
- provide marketing and advertising, email, or other communication services,
- provide services that support our online activities including providing tracking technologies, web hosting and analytics,
- provide tax and accounting, legal services, delivery, and data enhancement services,
- provide technology services and enhance security, privacy, and fraud protections,
- provide data analytics services or conduct research, and
- provide support to our operations.
- Marketing and advertising partners: We may share personal and other information with third party online and other marketing and advertising partners or permit these partners to collect personal information from you directly on our Sites to personalize online advertising. The Cookies and Other Tracking Technologies section of our Privacy Policy has more details about these activities.
- Third parties in connection with a business transaction: Personal information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of any or all our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy or similar proceedings.
- Law enforcement, regulators, and other parties for legal reasons: Personal information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe such action is necessary to:
- comply with the law and the reasonable requests of regulators, law enforcement or other public authorities,
- protect our or others safety, rights, or property, and
- investigate fraud or to protect the security or integrity of our Sites or any services.
The following table lists the categories of personal information that we may have collected from you and the categories of service providers or third parties to whom we may have disclosed those categories of personal information for a business purpose. Please refer to your personal information file for the categories of information for the personal information we have collected from you specifically.
| Categories of personal information | Categories of third parties |
|---|---|
| Personal identifiers | Service providers; marketing and advertising partners; third parties involved in a business transaction; law enforcement or regulators |
| Personal characteristics | Service providers; marketing and advertising partners; third parties involved in a business transaction; law enforcement or regulators |
| Internet or other electronic network activity information | Service providers; marketing and advertising partners; law enforcement or regulators |
For more information about our privacy practices, please review our Privacy Statement at https://www.availcarsharing.com/privacy-policy.
Sincerely,
The Avail Team