Effective 6/9/2019

This privacy notice is provided on behalf of ANIHI Newco, LLC (also referred to in this notice as “Drift”, “we” or “us”) to explain how we collect, use and share the information we obtain about you in the course of facilitating your peer-to-peer car sharing experience. This notice also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

Our Privacy Principles

We do not share your information with non-affiliate companies that would use it to contact you about their own products and services.

We require persons or organizations that represent or assist us in supporting you to keep your information confidential.

We require our personnel to protect your personal information and keep it confidential.

In addition to the practices described above, we use a variety of physical, technical, and administrative security measures that help to safeguard your information.

Drift collects personal and non-personal information through its mobile phone applications, through its websites including www.driftforapartments.com, and www.drivedrift.com, and through your use of our products and services. We design our products and services with privacy and data protection as key principles and have created this Privacy Notice to explain our information collection practices and your data protection rights. We urge you to read this Privacy Notice in its entirety.

Contents:

  • About Drift
  • Personal Information We Collect About You
  • Use of Cookies and Similar Tracking Technologies
  • How We Use the Information We Collect
  • How We Share the Information We Collect
  • How We Secure the Information We Collect
  • How We Retain the Information We Collect
  • Children’s Privacy
  • Specific Information Related to Users in California
  • Contact Us
  • Changes to this Privacy Notice

About Drift

Drift is a peer-to-peer car sharing platform that connects owners looking to share their car with individuals seeking to use a car for their individual transportation needs. To facilitate peer-to-peer car sharing, we collect personal information about you, your vehicle(s), and driving needs.

We work with many different companies to facilitate peer-to-peer car sharing including mobile application providers, insurance companies, payment processors, telecommunications providers, wireless service providers, emergency personnel, towing companies, vehicle manufacturers, distributors and dealers, equipment and software manufacturers, licensors, content providers, and any other providers of products, services, equipment, content, features or facilities in connection with our products and services.

Personal Information We Collect About You

“Personal information” means any information relating to a person that directly or indirectly allows us to identify such person. If we combine personal information with the other information we collect, the combined information will be treated as personal information for as long as it remains combined.

Information that you share with Drift or Drift’s service providers: Drift may collect information that you provide directly to Drift or authorize us or our service providers to obtain, such as:

Contact and identification information including your name, home and emailaddresses, telephone numbers, driver’s license, Social Security number (if needed for tax purposes), biometric (including facial recognition data) and date of birth

  • Other information provided when you register for the Drift platform
  • Information about your motor vehicle(s) – We may inspect your vehicle(s) from time to time for safety and fitness for sharing
  • Payment information, including credit card and/or other financial account numbers that you provide for payment purposes

We may also obtain personal information related to driving risk including:

  • Insurance policy information
  • Insurance claims data
  • Motor vehicle records (driver’s license information, violations, convictions, and license status) and other consumer reporting data, including credit score

Drift Community Public Information: If you are permitted to join the platform, you may create a personal owner and/or borrower profile accessible by Drift and other Drift members. Your public listing page includes personal information, such as your user ID/name associated with your account, your public profile photo, and for owners, where your car is located for pick up, your listing description, vehicle availability, and transaction related information to allow our community to evaluate your reliability and responsiveness, and reviews and feedback. Your public profile and public listing pages may be indexed by search engines and may be published as search results.

Transaction Information: If you agree to a booking, we may provide your information to the other party in that transaction as reasonably necessary to facilitate the transaction. For example, we may provide information to facilitate communication or your photograph to facilitate identification. We will provide the address of the vehicle and/or the proposed delivery location. Drift Members involved in a booking with you may send you messages through the platform, for example, to confirm pickup or delivery location.

Information automatically collected from the Drift Mobile application and telematics devices installed in vehicles: Drift may collect information from the mobile application or telematics device, such as:

  • Geolocation and geospatial data: such as the latitude, longitude, and altitude of your vehicle; direction of travel; and the time the information was recorded.
  • Other mobile device information: such as IP address, unique device identifier, browser type, mobile service provider, time zone, zip code, area code, and other operating system data available to the mobile application.
  • Mobile application analytics information and other information about how you use the application: such as how often you use the application, referral URL and exit page, clickstream data, the events that occur within the application, direction/guidance requests and usage, aggregated usage, performance data, and the application marketplace from where you downloaded the application.
  • Trip information: such as trip start and end time, miles, acceleration, deceleration, braking behavior, cornering, speed, and trip routing.
  • Vehicle related information: such as your vehicle identification number, diagnostic information, odometer, oil life remaining, tire pressure, information about collisions involving your vehicle, and location information, such as GPS, Wi-Fi access points, or cell towers.

Please note that the owner of the vehicle may also have the capability to track the location and use of the vehicle through means the owner controls and that Drift does not facilitate.

Use of Cookies and Similar Tracking Technologies

We and our third-party marketing service providers (such as Google Analytics and Adobe Analytics) use cookies, analytics, remarketing, and other technology to help us provide users with a better service and a more customized web experience.Additionally, we and our service providers use tracking services, analytics, and other technologies to monitor visits to our websites and mobile applications, including www.driftforairports.com, www.driftforapartments.com, and www.drivedrift.com. These websites may also use web beacons (also called “clear GIFs” or “pixel tags”) in conjunction with cookies. We may track your behavior across time and across third-party sites, as well permit other third parties to do so on our site. Our site and applications do not respond to browser Do Not Track signals.

Cookies allow us to provide you with a more customized service and are used to track and measure web site usage. This information may be used to manage and customize our web site’s content, layout, and services in order to improve our site, enhance customer service, and provide tailored messages.

You may opt out of accepting cookies by changing the settings on your browser. However, rejecting cookies may prevent you from using certain functions and you may have to repeatedly enter information to take advantage of services or promotions.

How We Use Information We Collect

To provide services to you: We use, store, and process your information to provide and improve our services. We use your information to process sharing transactions and to send you notices about your transactions. We also may send you service and support messages including reminders, updates, and alerts and may contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging, as authorized by the Drift Terms and Conditions.

We may use personal information for service-related communications. We may also use the information provided by you to investigate, respond to, and resolve issues or complaints.

To enhance our services: Drift may use your information for product development, model development, and statistical analysis to improve our services. For use of personal information for model development and analytics, we make every reasonable effort to use anonymized or de-identified information where possible and have implemented measures to help limit the use of personal information for analytic purposes.

For fraud and misuse prevention: We may use your information to prevent and deter fraud or misuse of our products and services as required by law.

Additional Uses of Information for U.S. Users: For those users of Drift products and services inside the United States only, we may process personal information for the following additional purposes:

  • As a component of our services Drift may provide you with certain insurance benefits sourced through third-party insurers, including Drift’s corporate affiliate Allstate Insurance Company. If so, the insurer may use your information to facilitate their operational and service performance, including enhancing customer data quality processes and updating their pricing and underwriting models in accordance with their privacy policies. Allstate’s privacy policy can be found at https://www.allstate.com/about/privacy-statement-aic.aspx.
  • We may use your information to market Drift and Drift corporate affiliate products to you in such a way that does not disclose your personal information to unaffiliated third parties.
  • We perform various profiling activities using personal information. When we refer to profiling, we mean using personal information to make predictions about people, or to categorize them into particular groups (e.g., risk categories). We may use profiling to offer insurance services to you and for our internal market research.
  • How We Share the Information We Collect

To provide additional features or services to you: Examples of when we may work with other parties to provide additional features or services include:

  • Providing features or functionality in a mobile application, such as providing you with navigation services or information on how to improve the safety of your driving
  • Providing you with towing and repair options
  • Contacting emergency personnel
  • Understanding driving behavior data to understand the level of risk a driver may pose

With our corporate-affiliate companies: We may share your personal information and the other information we collect with our corporate affiliates.

As required by law: We may disclose information to third parties pursuant to legal process, and all information collected may be deemed discoverable by third parties and used in accident investigations and litigation. We may be legally required to provide the information to third parties and their legal counsel. We may also share personal information to protect our rights, property, or legal interests, including to enforce our terms and conditions, or as part of a merger, acquisition, divestiture, or other corporate reorganization.

Other than as otherwise described in this privacy policy, we do not share your personal information with unaffiliated third parties without aggregating and anonymizing (or de-identifying) it.

How We Secure the Information We Collect

We safeguard your information: We use a variety of physical, technical, and administrative security measures that help to safeguard your information from loss, misuse, unauthorized access, disclosure, alteration, destruction or theft, including the use of encryption and other technology safeguards. We also require third parties to protect your information in accordance with our strict information security policies that align with generally accepted information security standards. It is important to keep in mind, however, that no security measures are absolutely effective.

We review our internal security policies and guidelines periodically to review new technology, methods, risks of processing the data, and the nature of the data being protected. We limit access to our databases containing personal information to authorized persons having a justified need to access such information.

All personal information you provide to us is stored on secure servers provided by us or our third-party service providers. Unfortunately, the transmission of information via the internet is not completely secure. Although we will use all reasonable measures to protect your personal information, we cannot guarantee the security of your personal information transmitted to our site, therefore, any transmission is at your own risk. Once we have received your information, we will use security procedures and features to try to prevent any unauthorized access.

How We Retain the Information We Collect

We store personal information for as long as necessary for us, our affiliates, and our service providers to provide products and services to you and others, to comply with legal obligations, or to administer any product or service. Because of the nature of developing and refining statistical models, we store information that is automatically collected from your devices until it is no longer needed to provide products or services to you and to develop and refine our models. We review our data retention policies annually and comply with applicable legal requirements.

Children’s Privacy

Our services are not intended for use by anyone under the age of 18. We do not intentionally gather personal information about children. If we become aware that we have collected personal information from a child without parental consent as required by local law, we will make reasonable efforts to delete such data from our records.

Specific Information Related to Users in California

California Residents: California law permits its residents to request and receive information about a business’ disclosure of certain categories of personal information to other companies for their use in direct marketing. If you are a California resident and user of our website, products, or services, you can request a copy of this information from Drift. See the “Contact Us” section for contact information. Please include your name and email address in email requests, and your name and postal address in mail requests.

Contact Us

For general inquiries, complaints, or to exercise your rights under applicable law, contact us at:

Email:
privacy@drivedrift.com

Mail:

Drift
Attn: Operational Risk Manager
222 W Merchandise Mart Plaza
Suite 875
Chicago, IL 60654

To request that you no longer receive promotional e-mails from Drift, please email us at info@drivedrift.com.

Changes to this Privacy Notice

We may modify our Privacy Notice from time to time. We will provide you with notice of material changes to our Privacy Notice as appropriate under the circumstances. For example, we may post a notice of changes on our websites or mobile applications. Please see the revised date at the top of this page to see when this Privacy Notice was last revised.