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Privacy Policy

This Privacy Policy, effective May 25, 2018, applies to all of the products, services and websites offered by Unleashed, LLC or our subsidiaries or affiliated companies.

On May 25, 2018, the General Data Protection Regulation (“GDPR”), a data protection and privacy regulation concerning the collection, use and processing of personal information of individuals in the European Union (“EU”), will go into effect.  The GDPR replaced the 1995 Data Protection Directive (Directive 95/46/EC).  It applies to all companies which collect and process data of EU residents.  This Privacy Policy has been updated to reflect the changes and improvements Unleashed, LLC has made in response to the mandates of the GDPR. 

Information Collection and Use

According to the European Commission, "personal data is any information relating to an individual, whether it relates to his or her private, professional or public life. It can be anything from a name, a home address, a photo, an email address, bank details, posts on social networking websites, medical information, or a computer’s IP address."[1]  Personal Information includes but is not limited to identifiers such as an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a person.  We do not consider information that has been anonymized, aggregated or encrypted so that it can no longer be used to identify a specific person or non-personal or device-level information to be personal information.  To the extent Unleashed, LLC collects personal information, we require your explicit consent in order to process the data and provide Unleashed, LLC’s services, which you may withdraw at any time by sending a request to Unleashed, LLC, Attn:  Legal Department (Privacy Policy), 15 Walden St Concord MA 01741.  Absent explicit consent, Unleashed, LLC is authorized to collect and process personal information about you when the processing is necessary to perform a contract with you, like the Terms of Service or in furtherance of Unleashed, LLC’s legitimate business interests, such as in improving, personalizing, and developing the services, marketing new features or products that may be of interest, and promoting safety and security as described herein.

Unleashed, LLC may collect the following types of information:

Some of the information collected is personal information under the GDPR.  This personal information may be necessary in order to use Unleashed, LLC’s services.  You may also provide other personal information through your use of Unleashed, LLC’s services, dispute resolution, or when you otherwise communicate with Unleashed, LLC regarding our services.

You may purposely or inadvertently provide personal information about someone else, for example someone’s home address.  Any personal information provided by you about someone else is presumed to be provided with that other person’s consent. 

In addition to the above, Unleashed, LLC may use the information we collect to:

Unleashed, LLC processes personal information on our servers in the United States of America and in other countries. In some cases, we process personal information outside your own country. We may transfer your personal information to service providers and other partners for processing, based on our instructions, and in compliance with this policy and all applicable laws. For example, Unleashed, LLC uses third-party providers to provide our services, such as web hosting, and to help us understand and improve the use of our services, such as Google Analytics.  We may share your personal information with such third-party providers consistent with this Privacy Policy and any other applicable confidentiality and security measures.  

Personal Information of Children

Unleashed, LLC’s services are intended for an adult audience or for use by minors who have permission from a parent or legal guardian.  It is not possible for us to determine if personal information is being provided by or on behalf of a minor.  To the extent Unleashed, LLC receives personal information regarding a minor, it is understood that such personal information was supplied with the consent of said minor’s parent or legal guardian.  A parent or legal guardian may contact us at any time to request access, correction, restriction or deletion of the personal information of a minor. 

Information Sharing and Disclosure

Ride-share Service Providers – Unleashed, LLC may share personal information, such as your geographic location, intended destination, or telephone number, with a third-party ride-share provider for the purposes of facilitating your travel plans for which you accessed Unleashed, LLC’s services.  In certain situations, for example when you opt to hail a ride-share provider through Unleashed, LLC’s webpage or application, the personal information you enter on the webpage or application will be forwarded to the selected ride-share provider.  If you disclose personal information to a third party, such as a ride-share provider, or visit a third party website via a link from our website or app, the third party’s privacy policies and practices will apply to that information.  Unleashed, LLC cannot guarantee the security of your personal information once it is provided to a third party.  Additionally, you may receive personal information about the ride-share provider’s driver, such as name or mobile number.  You are the controller of any such personal information you receive from the ride-share provider and you must comply with the applicable privacy laws. 

Unleashed, LLC reserves the right to share the personal information collected when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, this Privacy Policy, or other policies, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues or other potentially prohibited or illegal activities, or (d) protect against harm to the rights, property or safety of Unleashed, LLC, our users or the public as required or permitted by law.  We may share anonymized location data with other institutions for research purposes.  We do not sell, rent, or otherwise disclose your personal information to third parties for their marketing and advertising purposes without your consent.

Unleashed, LLC takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to Unleashed, LLC employees, contractors and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Cookies

When you visit our sites or use our services or applications, we may use cookies and other similar technologies to collect additional website usage data to help provide you with a better, faster, and safer experience, and for advertising and marketing purposes.  Most web browsers automatically accept cookies, but some browsers allow you to decline cookies or alert you when a website it attempting to place a cookie on your computer. 

Accessing and Modifying Your Personal Information

You have the right to access your personal information and to request that Unleashed, LLC correct, delete or restrict usage of your personal information as required by applicable law.  You have the right to know what personal information we collect and maintain about you and to object to our processing and use of your personal information.  You can ask us to update incorrect or incomplete personal information or to delete or restrict how we use your personal information.  However, these rights are subject to applicable law and a request to stop processing your personal information or a withdrawal of consent to use or process your personal information may impact your ability to use Unleashed, LLC’s services. 

Unleashed, LLC will abide by any law which governs your right to access, modify or delete your personal information, but reserves the right to deny access, modification or deletion of such personal information in certain circumstances under applicable laws.  We may also retain personal information when necessary for legal reasons or to prevent harm.

Information Retention

Unleashed, LLC keeps information about you and your use of Unleashed, LLC’s services for as long as necessary for our legitimate business interests, to provide you with the requested services,  to resolve disputes, to enforce our policies, to prevent harm and for other legal reasons. 

Change of Ownership

In the event Unleashed, LLC is reorganized, acquired by or otherwise merged with or becomes associated with another company, your personal information may be shared or transferred in accordance with this Privacy Policy.  In such an event, Unleashed, LLC will require the other entity or the new, combined entity to follow this Privacy Policy or its own policy so long as its policy does not diminish the protection provided by this Privacy Policy. 

Data Controllers and Data Protection Officers

You are contracting with Unleashed, LLC.  Unleashed, LLC is your data controller and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with this Privacy Policy and any applicable laws.  If you have any questions about this Privacy Policy or the way Unleashed, LLC collects, uses, discloses, retains or protects your personal information, you may contact us at:  Unleashed, LLC, Attn:  Legal Department (Privacy Policy), 14 Old Weston Road, Wayland, MA  01778.  Unleashed, LLC may process and retain your personal information on our servers in the US or elsewhere in the world where our data centers are located.  If required, Unleashed, LLC has appointed a data protection officer to be responsible for enforcing this Privacy Policy. 

Please note that this Privacy Policy may change from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).  Use of Unleashed, LLC’s services after those changes become effective signals your agreement to be bound by the revised Privacy Policy. 

 

[1] European Commission’s press release announcing the proposed comprehensive reform of data protection rules. 25 January 2012.