Privacy Policy

Introduction

Smartcar, Inc. (“Smartcar,” “we,” “us,” “our”) has created a connected car API platform to enable application developers (“Developers”) to build applications and use standard APIs to allow end users to use such applications to communicate with such end users’ vehicles manufactured by certain vehicle manufacturers (“OEMs”). Such platform, together with our website located at www.smartcar.com (the “Site”), and any services provided by us in relation to such platform or the Site, are referenced herein as the “Service”. This Privacy Policy sets forth Smartcar’s policy with respect to information including personally identifiable data (“Personal Data”) and certain other information that is collected from visitors to the Site and users of the Service. By using or accessing the Service in any manner, you acknowledge that you accept and agree to the terms, practices and policies outlined in this Privacy Policy, and you hereby consent that we may collect, use, and share your information as set forth below. This Privacy Policy does not apply to any third party website, product or service, including any applications made available by Developers (each of the foregoing, a “Third Party Service”), even if the Third Party Service links to (or from) the Service or is enabled through the Service. Smartcar does not operate those Third Party Services - please always review the privacy practices of those third parties before deciding whether to provide any information to them.

Interacting with the Service

When you interact with us through the Service, we may collect Personal Data and other information from you, as further described below.

Personal Data That You Provide through the Service

We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services, instruct information to be shared with us or use certain components of the Service.

Information from Third Party Services

We collect certain information through trusted third parties, including Developers and OEMs. By using the Service in conjunction with any Third Party Service that uses our platform, you consent to the terms of this Privacy Policy. Some features of the Service allow you to provide or transmit data and content, including regarding your vehicle and the use thereof (“Vehicle Information”), to or through the Service. As an end user of any Third Party Service that utilizes the Service, whether directly via use of our APIs or other services, or through an application built by us directly, you are agreeing to share Vehicle Information and other information with us. You are enabling us to interact with and through Third Party Services or OEMs on your behalf and with your consent. We may also retrieve information pertaining to usage of Developer applications and other general activity that comes through use of the Service.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Service, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Smartcar and the authorized third parties referred to herein located in the United States.

Other Information

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Service, Smartcar may collect information regarding customer demographics, interests, usage and behavior based on the Personal Data and other information provided to us. This information may be compiled and analyzed on an aggregate basis, and Smartcar may share this aggregate data with its affiliates, agents, business partners, Developers, OEMs or other third parties. This aggregate information does not identify you personally. Smartcar may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Location Information: Our Service may collect and use your location information (for example, by using the GPS on your mobile device) to provide certain functionality of our Service. We may also use your location information in an aggregate way, as described above in the “Aggregated Personal Data” section.

Analytics and Tracking Technologies: We may, and we may allow third party service providers to, use cookies (as noted above) or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

You may set a “Do Not Track” (DNT) privacy preference in your web browser. When you turn on DNT in your browser, we will use commercially reasonable efforts to stop collecting the information that allows us to tailor suggestions based on your recent use of the Service and your visits to websites within our advertising partner networks. Specifically, we stop collecting the unique cookie that links your browser to use of the Service and visits to these websites for tailoring suggestions or ads.

How We Use Your Personal Data

Smartcar uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to or use the Service, we will use your Personal Data to provide you with access to the Service, operate and maintain the Service (including providing customer service, fixing malfunctions, testing our security systems, etc.), provide you with the features, functions and benefits of the Service (including displaying Vehicle Information to you), enhance and develop the Service (including creating new features or functions, refining or personalizing the user experience, increasing Service technical performance), help personalize the Service experience for you (including remembering your information so you will not have to enter it each time you use the Service), monitor your use of the Service and otherwise effect the purposes described in the Privacy Policy. Smartcar and its affiliates may use this information to contact you in the future to tell you about products or services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

If Smartcar intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Smartcar Is Not in the Business of Selling Your Information

We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data or other information with certain third parties without further notice to you, as set forth below.

Third Party Services

As described above, if you authorize a Third Party Service to access your Smartcar account or otherwise utilize the Smartcar platform, you acknowledge that we may share your information (including Vehicle Information) with the third party that provides the Third Party Service. The use of your information by such third party will be subject to its applicable privacy policy, which you should carefully review.

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies

We may also share your Personal Data with our corporate affiliates for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties

Smartcar, like many businesses, sometimes engages other companies to perform certain business-related functions. Examples of such functions include mailing information, hosting data and maintaining databases. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements

Smartcar may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Smartcar, (iii) act in urgent circumstances to protect the personal safety of users of the Service or the public, or (iv) protect against legal liability.

Your Choices

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain components of the Service.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by Smartcar other than Personal Data collected through the Service. This Privacy Policy shall not apply to any unsolicited information you provide to Smartcar through the Service or through any other means. This includes, but is not limited to, information posted to any public areas of the Service, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Smartcar shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children

Smartcar does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Smartcar through the Service, please contact us, and we will endeavor to delete that information from our databases.

No Endorsement of Third Party Services

This Privacy Policy applies only to the Service. The policies and procedures we described here do not apply to the Third Party Services. Any links or integrations from or with a Third Party Service do not imply that Smartcar endorses the Third Party Service.

Security

Smartcar takes reasonable steps to protect the Personal Data provided via the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Service may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Smartcar via the Internet.

Other Terms and Conditions

Your access to and use of the Service is subject to the Terms of Service at smartcar.com/terms/.

Changes to Smartcar's Privacy Policy

The Service and our business may change from time to time. As a result, at times it may be necessary for Smartcar to make changes to this Privacy Policy. Smartcar reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Service after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information: Contacting Smartcar

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Service. Please also feel free to contact us if you have any questions about Smartcar’s Privacy Policy or the information practices of the Service. You may contact us at support@smartcar.com.