CORTAGA MOBILE APP PRIVACY POLICY

This Privacy Policy was last updated December 12, 2016.
Cortaga is committed to protecting your privacy and developing technology that gives you a powerful and safe online experience. This Privacy Policy (the “Policy”) applies to the Cortaga Mobile Application (the “App”). By using the App you consent to the data practices described in this Policy. All capitalized words not defined herein shall have the meanings ascribed to them in the Terms of Use.
COLLECTION OF YOUR PERSONAL INFORMATION

You may provide Cortaga with personally identifiable information that may include, but not be limited to, your e-mail address, name, home or work address and telephone number. Additionally, the App collects driving data from your phone such as driving speed, time of day, GPS-based location data, and camera image data while using the App, and provides that data to entities with who you have agreed to share it. We will retain your personally identifiable information for the period necessary to fulfill the purposes outlined in this Policy unless otherwise required or permitted by law.

The App is intended to collect your driving information, but may inadvertently collect the driving information of third parties with whom you are a passenger. No records will be created that identify any such third parties.

USE OF YOUR PERSONAL INFORMATION

The App uses your personal information to provide you employer or contractee with information about your performance as a driver, as well as to improve our services to you by improving the App’s performance.

Except as set forth in this Policy, we will not use, disclose, or transfer your personally identifiable information or the personally identifiable information of others you have provided us unless (1) you expressly authorize us to do so; (2) it is necessary to allow our service providers or agents to provide services for us, (3) it is necessary in order to provide our products or services to you (and contacting you when necessary), (4) we are sending you other information that may be useful to you, (5) subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements, (6) it is necessary to protect the confidentiality or security of your records, (7) subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all of the assets of Cortaga or the merger of Cortaga into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which Cortaga is not the survivor, (8) it is necessary in connection with other business purposes including, without limitation, customer care, service quality, business management and operation, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends and dispute resolution, (9) it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity; (10) it is necessary for us to provide it to our attorneys, accountants, regulators, auditors or other advisors; or (11) it is otherwise necessary for us to disclose it as required or permitted by law.

We may use various web site analytics tools and technologies regarding activities on our web sites that require storage of web session data. The overall aim of these tools is to aid in making our web sites easy to use and to proactively identify and correct error conditions. These tools and technologies may also be used to assist web site visitors who report problems in the use of our web sites. Stored web session data is used in accordance with this privacy policy.

DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION TO THIRD PARTIES

Cortaga shares your personally-identifiable driving data and other personal information only with your contractee or employer or as otherwise specifically agreed by you, and does not sell, rent, or lease its customer lists or the identity of individual customers to third parties.

Cortaga may share personally identifiable information with trusted partners to help us perform statistical analysis. All such third parties are contractually prohibited from using personally identifiable information provided by the App except to provide these services to the App, and they are required to maintain the confidentiality of your information with equal or greater protections than those provided by the App.

Cortaga will disclose your personally identifiable information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Cortaga; (b) protect and defend the rights or property of Cortaga; and, (c) act under exigent circumstances to protect the personal safety of users of Cortaga or the public.

SECURITY OF YOUR PERSONALLY IDENTIFIABLE INFORMATION
The App secures your personally identifiable information, and the personally identifiable information of others on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. However, no data transmission over the Internet can be guaranteed as 100% secure. As a result, while we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us or receive from us.
COMMUNICATIONS WITH Cortaga
We appreciate your questions and comments about the App and Cortaga and welcome your messages to recipients listed on the App including messages or emails provided to our customer support. We will share your communications with those within our organization who are most capable of addressing the issues contained in your message. We may archive your message for a certain period of time or discard it, but your e-mail address and e-mail will only be used in accordance with this Policy.
USING THE APP FROM OUTSIDE THE UNITED STATES
If you are using the App from outside of the United States, please be aware that your information, including any personally identifiable information to which we may be given access, may be transferred to, stored, or processed in the United States. The data protection and other laws of the United States and other countries may not be as comprehensive as those in your country, but we will take strong measures to protect your personally identifiable information. By using the App, you understand that your personally identifiable information may be transferred to our facilities and to those third parties with whom we share such information as specified in this Policy.
NO INFORMATION COLLECTED FROM CHILDREN
The App will never ask for or knowingly collect information from children. We are strongly committed to preserving online privacy for all of our web site visitors, including children. We do not knowingly collect information about children or sell products to children. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13.
CHANGES TO THIS POLICY
We may change this Policy at any time and from time to time. The most recent version of the Policy is reflected by the version date located at the bottom of this Policy. If we make any material changes to our Policy, those changes will apply to the personally identifiable information collected after the effective date listed on the Policy, and we will notify you by placing a notice on the App’s download page prior to the change becoming effective. We encourage all users to periodically review this Policy for the latest information on our privacy practices.
CALIFORNIA PRIVACY RIGHTS AND DO NOT TRACK DISCLOSURES

Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personally identifiable information, such as name, e-mail, and mailing address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the name and address of all such third parties. To request the above information, please email us at support@cortaga.com with a reference to California Disclosure Information.

We will respond to such requests to information access within 30 days following receipt at the e-mail stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.

We treat the data of everyone who uses the App in accordance with this Policy, whatever their Do-Not-Track setting or use of any other mechanism that provides them with the ability to exercise choice about the collection of their personally identifiable information.

CONTACT INFORMATION
The App welcomes your comments regarding this Policy. If you believe that the App has not adhered to this Policy, please contact Cortaga at support@cortaga.com. We will use commercially reasonable efforts to promptly determine and remedy the problem.

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