sfara Privacy Policy 

Here are a few general principles to keep in mind as you read through this Policy:

• The Services are owned and operated by sfara, Inc. and its corporate affiliates (referred to collectively in this Policy as “we,” “us,” “our” and other similar pronouns).
• Sfara is not covered by, and the Services do not comply with, the federal Health Insurance Portability and Accountability Act (“HIPAA“), which applies to certain health, medical and medical insurance related information.
• The App may use GPS and other locator capabilities to identify, display and share your device’s precise location, as further described in Section 1 below.
• This Policy may change, so check back to this page periodically to make sure you understand how your personal information will be treated.
• This Policy does not apply to information that you may provide to us, or that we may obtain, other than through the Services or the various social networking platforms that we use.
• The App is intended for users who are located in and travel within the United States. The information you provide to us is being transmitted to us and processed in the United States and will be protected subject to this Policy and United States laws.
• This Policy is incorporated into, and part of, the sfara Terms of Service which governs your use of the Services.

1. What information is collected through the Services (as described below, “Information”)?

User-Provided Information

We obtain information you provide to us, for example when you download and register the App, conduct a transaction on the Services, sign up for newsletters, or submit a comment to question to us using a “contact us” or similar feature on the Services. Registration with us is mandatory in order to be able to use the App. “Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information.

When you register with us and use the App, you provide:

• your name, email address, username, password, mobile phone number and, at your option, car make and model, names and contact information of your emergency contacts, and any additional information of your choosing that you may enter into a free-form field (the “Free Form Field Content”); and
• transaction-related information, such as your downloading and registration of the App, your uses of the App, and your responses to our correspondence with you.

We and our Service Partners (as defined in Section 4) disclaim any responsibility for the Free-Form Field Content. You understand and agree that we and our Service Partners (a) have the right but not the obligation to monitor Free-Form Field Content and (b) shall not be liable to you or anyone else for any action or inaction related to any Free-Form Field Content.

Location Information

The App collects information about the precise geographic location of your device. If your device is equipped with GPS or can connect with wireless access points or hot spots, or if your device is also a phone that communicates with cell towers or satellites, then your device is able to use these features to determine its precise geographic location and transmit it to us.

If you have consented using your device’s user interface, the geographic location of your device will be transmitted to our servers in real time (even if you are not actively using the App or it is minimized on your device). Once you set your device to transmit its location information to us, your device will continue to transmit its location information to us (even when the App is minimized on your device or closed) unless you set your device to no longer do so.

You may at any time opt-out from further allowing us to have access to your device’s location information by accessing the App’s location settings on your device and setting your device not to share its location with us; however, if you opt-out of location sharing, the App will not work properly. For more information, please see Section 7.

Mobility Information

The App collects mobility information from your device, relating to the time, date and location of driving events (which include but are not limited to trip start/end, braking, acceleration and phone handling).

Diagnostic, Technical and Usage Logs and Information

In order to provide, test and help us improve our products and services, you acknowledge that we will be collecting diagnostic, technical, and usage logs and information from your device that is running the App. This information may be collected from your device at any time. The information that would be collected includes, but is not limited to:

• general diagnostic and usage data
• various unique device identifiers
• various unique system or hardware identifiers
• details about hardware and operating system specifications
• performance statistics
• data about how you use your device, peripherals and system and application software
• certain location information

You agree that we may share such diagnostic, technical, and usage logs and information with its service providers to improve our products and services. By installing or using the App on your device, you acknowledge and agree that we and our agents have your permission to collect all such information and use it as set forth above.

Automatically Collected Information and Site Usage Information

The App may collect certain information automatically. We may work with analytics companies to help us understand how the App is being used, by how many users, for how long and how frequently. Using analytics, we may receive counts of the screens and features of the App that are used, device language settings, the types of devices, operating systems, software, carriers, IP addresses and wireless connections our users are using, and their settings. In addition, the App assigns a unique numerical identifier to your account that is associated with your other Information.

As is the case with many websites, our servers automatically collect your IP address when you visit the Site, and we may associate that with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your Site usage. Clickstream data includes, for example, information about your computer or device, web browser and operating system and their settings, the referring page that linked you to the Site, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next website you visit when you leave the Site, and any search terms you have entered on the Site or a referral site. Among other things, this information enables us to generate analytics reports on the usage of the Site. To opt-out of your Site usage being included in our Google analytics reports, you may follow these instructions.

In addition, we may deploy various tracking technologies on the Site to collect additional information about your Site visits. For example:

• Cookies are small data files stored on your computer or device at the request of a website. A cookie assigns a unique numerical identifier to your web browser, and may enable us to recognize you as the same user who was at the Site in the past, and relate your use of the Site to other information about you, such as your Site usage information and Personal Information. Cookies may also be used to enhance your experience on the Site (for example, by storing your username so you can log in easily or keeping you logged into the Site after you have provided your password) or to collect general usage and aggregated statistical information and detect and prevent fraud. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of the Site or its features. To learn more about the use of cookies, including how to manage or delete them, click here.
• HTML5 (the language some Web sites are coded in) may be used to store information on your computer or device about your Site usage activities. This information can be retrieved by us to determine how the Site is being used by our visitors, how it can be improved, and to customize it for our users.
• Cache cookies, such as eTags, may be used to identify your computer or device as the same computer or device that visited the Site or another website in the past.
• Browser history sniffing may be used to enable us to detect whether you have visited a web page of ours or of someone else’s in the past by determining whether its URL is located in the list of URLs stored in your web browser’s history file.
• Browser fingerprinting can enable us to recognize your computer or device as the same one that has been used to visit the Site in the past based on various detectable information from your computer or device that, together, can be used as a “fingerprint” of your computer or device.
• A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you have opened one of our emails or seen one of our web pages.

These tracking technologies may be deployed by us and/or by our service providers on our behalf. These technologies enable us to assign a unique number or identifier to you, and relate your Site usage information to other information about you, including your Personal Information. These technologies also enable us to recognize you when you access the Site using different web browsers and different computers or devices. By using the Site, you consent to our use of these tracking technologies as described above.

Third Party Information

We may also obtain information about you from other third parties, such as companies that help us supplement our records with up-to-date and complete information.

2. How is your Information used?

We or our service providers may use the information we collect from and about you to perform the following business functions:

• enabling users to use the Services and their features
• processing and fulfilling your transactions
• administering the Services and your account with us
• remembering information so you will not have to re-enter it during your use or the next time you use the Services
• collecting and sharing with others (pursuant to Section 4) your device’s precise location information if you enable location sharing
• responding to your requests, questions, and concerns
• internal research and improvement and development of the Services and other software and services
• sending you marketing and other communications, including information about our products, product updates and services that we think might interest you
• calling you or sending you emails or other messages, possibly using automated technology or prerecorded messages, in response to service-related triggering events and other issues
• protecting our rights and property
• preventing fraud
• customizing the Services to your interests and history with us
• other purposes disclosed when personal information is submitted to us

To perform the above functions, we may match information collected from you through different means or at different times, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Services, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.

3. Social Networking

We maintain presence on several social networking and blogging platforms, such as Facebook, Twitter and LinkedIn Through these platforms, we receive some Personal Information and some usage Information about you, and this Policy applies to that information as well. In addition, third party social networking platforms and blogging platforms have their own privacy policies which explain how the third parties that provide them will use and protect your information. In accordance with those policies (and your privacy settings within your social networking accounts), information about your activities on the Services (for example, “liking” an article) may be published to your social network.

4. Do we share Information with others?

Yes. We may share the information we collect through the Services and the various social networking platforms that we use with others for a variety of reasons. In addition to the kinds of information sharing you might expect, such as sharing with third parties who need your information in order to provide services to us (or on our behalf), we may share your information:

• With different companies, individuals and government entities to provide you with the personal assistance and safety services facilitated by the App, which include, for example and without limitation: app stores, telecommunications providers, wireless service providers, call center service providers, roadside assistance service providers, public safety operators, emergency response centers, emergency personnel, towing companies, vehicle manufacturers, distributors and dealers, equipment and software manufacturers, distributors, licensors, content providers, and any other person or entity who provides any service, equipment, content, feature or facilities in connection with the App (collectively, “Service Partners”). We share your Information with Service Partners, or they collect it directly from you or your device.
• To cooperate with requests from law enforcement.

• We may disclose Information regarding our users and user behavior as a measure of interest in, and use of, the Services to third parties, including, for example, aggregate data, such as overall patterns or demographic reports.
• When we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law.
• In connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business.

You agree that we or our Service Partners may collect Information from and/or about you. Without limitation of the generality of the foregoing, (i) we or Service Partners may intercept any wire, wireless, oral or electronic communications made or transmitted through the App, at any time and for any reason, (ii) we or Service Partners may retrieve, access and/or use any of the information (including, without limitation, location information) recorded, transmitted or otherwise obtained in connection therewith, at any time and for any reason, and (iii) you hereby consent to the foregoing and hereby expressly release us, sfara and other Service Partners therefor. We or Service Partners may share between and amongst us your Information that we or they have collected or otherwise obtained, and you hereby expressly acknowledge and consent to such sharing.

5. Do Not Track Disclosures

Some web browsers may transmit “do-not-track” (“DNT”) signals to the online services with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not change our tracking practices (which are explained in more detail under “Automatically Collected Information and Site Usage Information” above) in response to DNT settings in your web browser. Our third party partners, such as web analytics companies, collect information about your online activities over time and across the Services and other online properties. We utilize Google Analytics for our web analytics and you can opt out of your Site usage data being included in our Google Analytics reports by visiting this link.

6. Communications with you

We and our Service Partners may communicate with you by calling or messaging you through your device or to the phone number, email address or other contact information for you that we have on file, possibly using automated technology or prerecorded messages. You hereby agree to this. We and our Service Partners may also use your email address to send you emails about products, specials and online promotions, which may be related to the Services or not. From time to time, we may also use your email address to send you information about selected third party products, services or offers relating to our offerings or services that we think may be of interest to you. Each email you receive from us for offers will provide a link to unsubscribe to all future email offers from sfara. Please understand that it may take us a few days to process any opt-out request and that even if you opt-out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.

By submitting your mobile phone number, you agree that you are providing sfara with prior express written consent to call and send text messages to the mobile device associated with that number using automated technology, which may include promotional messages. Message and data rates may apply. Consent is not required to purchase goods or services from sfara. You may not consent on behalf of someone else or provide someone else’s phone number. You will have the ability to opt out of receiving text messages by following the instructions in the text message you receive. Your opt‐out will be effective after we send you a confirmation. Mobile Internet access is required. You agree to enter into, sign and receive this consent to receive calls and text messages electronically. Print this page using your Internet‐connected computer or device and web browser to retain a copy of your consent. You can withdraw your consent to receive this consent electronically. Contact us at [email protected] to request a free copy of your consent. We may obtain the date, time and content of your messages in the course of your use of text messaging.

If the e-mail address you provide to us is a wireless e-mail address, you agree to receive messages from us at such address unless and until you tell us not to send messages to that address. You may change your e-mail preferences at any time, but your wireless carrier’s standard rates will apply as long as you are receiving messages at a wireless e-mail address. If you give us a wireless e-mail address, you represent that you are the owner or authorized user of the device on which messages will be received and that you are authorized to approve the applicable charges.

You acknowledge and agree that we and/or our Service Partners (either ourselves or themselves, or through our or their service providers) may record and/or monitor conversations between you and our (or their, as applicable) customer service representatives, emergency personnel, or the police, as well as your use of any of our (or their) automated services, for various purposes, including (without limitation), in order to assess, maintain or improve the quality of the Services, cooperate with law enforcement, or promote and provide the Services, or for issue resolution or training purposes. Our customer service representatives (as well as those of our Service Partners, if applicable) may also remain on the line while conferencing in a third party to assist in completing a service request.

You (for yourself and anyone else acting or using the Services on your behalf) (a) expressly consent to the monitoring and recording activities described herein, and (b) release us and our Service Partners from claims, liabilities and losses resulting in connection with any such monitored and/or recorded conversations as described herein.

7. Opt In and Opt Out

There are four opt-out options for users of the Services:

• Opt-out of all Information collection by uninstalling the App. You can stop all collection of Information by the App easily by uninstalling the App. You may use the standard uninstall processes available as part of your mobile device or via the mobile application marketplace or network.

• You may opt-out from further allowing us to have access to your device’s location data by accessing the App’s location setting on your device and setting your device not to share its location with us. However, if you opt-out from location sharing, the App will not function properly.
• You may opt out of our promotional emails by clicking on the opt-out link within the email you receive. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions, and communications with us.
• You may opt-out of receiving text messages by following the instructions in the text message you receive. Your opt‐out will be effective after we send you a confirmation.

8. Your Access Rights

You may review, update or modify certain Personal Information that is stored in your user account on the App by logging in to the “My Account” or similar area of the App. We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your right to delete your information is subject to our records retention policies.

9. Data Retention

We may retain information gathered through your use of the Services and the various social networking platforms that we use for so long as is commercially reasonable for a legitimate business purpose.

10. Children

We do not use the Services and the various social networking platforms that we use to knowingly solicit personally identifiable information from or market to children under the age of 13. In the event that we learn we have collected information from a child under the age of 13 without parental consent, we will take the steps to remove such information. Please alert us if you believe that we might have any account information from or about a child under the age of 13.

11. Security

While we endeavor to protect the security and integrity of sensitive Personal Information collected through the Services, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

Because we provide the App through wireless networks, your communications may be intercepted by others. We and our Service Partners cannot and do not guarantee (and we and our Service Partners expressly disclaim) the security and privacy of wireless transmissions, and we and them will not be liable for any lack of security relating to the use of the App by you. You agree that you will not hold us or any of our Service Partners liable for any damages resulting from any loss of privacy or security occurring in connection with any communications over such networks.

If you correspond with us by e-mail, text message, or using Web forms like the “contact us” feature on the Services, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

You are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security.

If we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your e-mail address in your account up to date. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification.If you prefer for us to use your phone number or another contact point to notify you in this situation, please e-mail us at[email protected]. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.

12. Changes to this Privacy Policy

We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page with a new “Effective Date.” In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. In some cases, we may request your consent to the changes.

13. Your Consent

By installing or otherwise using or accessing the Services or our presence on various social networking platforms in any manner, you consent to (a) our processing of Information as set forth in this Privacy Policy now and as amended by us, and (b) the collection, maintenance, processing, and transfer of such Information in and to the United States and other countries and territories, pursuant to the laws of the United States, which may provide lesser privacy protections than the laws of other countries.

14. Contact Us

If you have any questions or comments regarding our privacy practices, you may contact us at:

sfara, Inc.

33-41 Newark St., Suite 5B

Hoboken, NJ 07030

Email: [email protected]

Phone: (201) 942-6929

Effective Date: December 4, 2017