Good Driver Mutuality
Privacy Policy

Last Updated: April 23, 2024

 

This Privacy Policy is designed to help you understand how Good Driver Mutuality, Inc. (“Good Driver,” “we,” “us,” or “our”) we collect, use, process, and share your personal information, and to help you understand and exercise your privacy rights.

About Our Services

Our Services (as defined below) may facilitate your access to the website located at www.gooddriver.ai and interaction with Good Driver Mutuality App,  (a “Platform”). Our Services may also facilitate the creation of a digital bank account through third party services that we do not own or control that enable you to take self-custody and manage  assets (like US dollar), and enable you to interact with third party services and supported protocols that support the distribution of assets the internet.

Please make sure to review our Terms of Service for more information, including specific terms and obligations for the use of our Services that may include dispute resolutions.

 

Privacy Policy Table of Contents

1……… SCOPE TO THIS PRIVACY POLICY

2……… PERSONAL INFORMATION WE COLLECT

3……… HOW WE USE YOUR PERSONAL INFORMATION

4……… HOW WE DISCLOSE YOUR PERSONAL INFORMATION

5……… YOUR PRIVACY CHOICES AND RIGHTS

6……… INTERNATIONAL DATA TRANSFERS

7……… RETENTION OF PERSONAL INFORMATION

8……… SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

9……… CHILDREN’S INFORMATION

10……. OTHER PROVISIONS, INCLUDING FOR EU/UK CITIZENS

11……. CONTACT US

1. SCOPE TO THIS PRIVACY POLICY

This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called the “Services.”

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

• Account Creation. We may collect personal information when you create an account, such as email address.

• Mutuality Program Enrollment: We may collect personal information when you join Mutuality Program, such as name, phone number, tax ID, driver license number, date of birth. Please note that this information is stored encrypted on your local mobile device and on our server and we can access it only upon your authorization. This information is used internally by the mobile application to determine applicable pledged amount according to standards established by the Mutuality Program (www.gooddriver.ai). If you delete the mobile application, the data stored locally will also be deleted.

• Financial and Online Transactional Information. We may collect financial information such as your bank account numbers, bank statements, transaction history, trading data, credit/debit card numbers. We may collect personal information and details associated with your transactions including, but not limited to, information about the transactions you make using the Services, the purpose of the transactions, information on sources of your funds, sender and receiver of funds, and ultimate beneficiary information. Any fiat payments or transactions made via our Services are processed by third-party processors.

• Your Transactions/Know Your Customer (“KYC”) information. If you enroll in the Mutuality Program, or conduct other digital financial transactions using our Services, we will record the details of each transaction (such as any contributions made, etc.). In addition, in connection with use of our Services, we or our service providers may also collect information to facilitate the transaction, verify your identity, and comply with our regulatory obligations (sometimes referred to as “Know Your Customer” checks). Such information may include, without limitation: date of birth, your passport or national ID card, a bank card statement, or other information linking you to an address.

• Third-Party Administrator (“TPA”) Required Information. We facilitate the collection of information needed by TPAs to process any automotive repair claim. 

• Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.

• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (for example, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.

• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners. 

• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use our Services.

• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
• Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties.
  See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics partners may include:
  • Google Analytics. For more information about how Google uses your personal information (including for its own purposes, for example, for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

C. Personal Information Collected from Other Sources 

Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations.  For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect personal information about you from that third-party application that you have made available via your privacy settings.

Credit Bureaus and ID Verification Partners. We may obtain personal information about you from credit bureaus and identity verification partners.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide personal information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (for example, relative, friend, neighbor, or co-worker).

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

• Managing your information and accounts;
• Verify your identity in accordance with applicable know-your-customer, money-laundering and other financial sector legislation or regulations;
• Facilitating transactions you enter into;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing your financial information and other payment methods for products or Services purchased; and
• Allowing you to register for events.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Improving, upgrading, or enhancing our Services;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include word-of-mouth networking, direct email campaigns and custom audiences advertising.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

D. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

• With Your Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
• Automated Decision Making. We designed a mobile application that you can choose to use that tracks your driving behavior to improve pricing and promote the incentivization mechanism for the Mutuality Program. While we do not collect personal information from this application, our mobile application will process your personal information, which may include information derived by the sensors of your mobile devices that detect drastic turning, speeding, hard breaking, and other unique driving skill inferences to generate a relative score based on a statistical analysis compared against the historical information of other drivers’ skills using similar sensors. We do not collect this information or have access to this information collected on your mobile device that is used to generate your score. This information is kept entirely local to your mobile application. This score will be used to classify your driving behavior, which may be used as one of the factors in determining the amount of your pricing and the amount of incentivization you received.  The mobile application is constantly evaluated for accuracy, fairness, and bias by using a system to label the driving behavior of other designated drivers, collecting that labeled data, such as drastic turning, speeding, hard braking, and other unique driving skill inferences, and using the aforementioned data to train the algorithm to promote the accuracy and fairness.
  Some jurisdictions may consider this to be automated decision making or profiling. You must first opt-in to this offering through the mobile application prior to commencement of driving activity to take advantage of the benefits offered, including obtaining more rewards under the Mutuality Program.
  You may opt-out of your mobile application collecting this information at any time by turning off the Driving Behavior Recording button. When you opt-out after using the mobile application, then your scoring will not be taken into consideration for pricing and will not be used for incentivization mechanisms.   If you have questions about our mobile application and its use regarding potential automated decision making or profiling, you may contact us as set forth in “Contact Us” below.
• De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you access our Services, or other analyses we create.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

• Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, third party administrators (“TPAs”), actuarial researcher or auditor, auto repair body shops and related services. Note: you may need to provide certain information only you know (like Driver’s License and/or VIN number) to our Service Providers to facilitate processing of a Mutuality Program claim.
• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
• Affiliates. We may share your personal information with our company affiliates.
• Other Users or Third Parties You Share or Interact With. As described above in “Personal Information We Collect,” our Services may allow you to share personal information or interact with other users and third parties (including individuals and third parties who do not use our Services and the general public).
• APIs/SDKs. We may use third-party application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. SDKs typically collect your mobile device identifier and information related to your use of the Services. SDKs may allow third parties including analytics and advertising partners to collect your information for various purposes including to provide analytics services and personalized advertising. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS 

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (for example, communications regarding our Services or updates to our Terms or this Privacy Policy).
• Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
• Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
• Phone Calls. If you receive an unwanted phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in “Contact Us” below.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Confirm Whether We Are Processing Your Personal Information (the right to know);
• Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion of your personal information;
• Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for “targeted advertising” (as “targeted advertising” is defined by applicable privacy laws), if we “sell” your personal information (as “sell” is defined by applicable privacy laws), or if we engage in “profiling” in furtherance of certain “decisions that produce legal or similarly significant effects” concerning you (as such terms are defined by applicable privacy laws);
• Request Restriction of or Object to our processing of your personal information;
• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal; and
• Appeal our Decision to decline to process your request.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

If applicable laws grant you an appeal right and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

6. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.   In most cases, we immediately delete any personal information collected on our servers once its purpose to collect has been fulfilled. You may have personal information that remains stored on your local device that is encrypted when using the app. You are responsible for keeping it secure.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

8. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

9. CHILDREN’S INFORMATION

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children.

10. OTHER PROVISIONS, INCLUDING FOR EU/UK CITIZENS

 Third-Party Websites/Applications/Services. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services or the Services may allow you to interact with Third-Party Services, such as financial institutions and repair body shops. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for the third party’s actions or omissions, including but not limited to their privacy practices, content of such other websites or applications, and errors or bugs in their software. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.

• EEA Data Protection Authorities (DPAs)
• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• UK Information Commissioner’s Office (ICO)

11. CONTACT US

Good Driver Mutuality Inc. is the controller of the personal information we process under this Privacy Policy.

If you have any questions about our privacy practices or this Privacy Policy, need to access this Policy in an alternative format due to having a disability, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Good Driver Mutuality, Inc.
contact@gooddriver.ai