In order to use the App you need to be authorized by the Client and you need to authorize us to use and collect information that identifies you personally (“Personal Information”).
Information We Use and Collect
Profile Information: In order to utilize a Client leased vehicle you have already provided Client with certain information about you and authorized Client to provide that information to us for purposes related to the use of the vehicle and our providing of Services. This includes Personal Information, such as your personal and business address, phone number, email address and other contact information, as well as information relating to your vehicle and the use of the vehicle (which can be connected with you). Once you become a user of the App, you may provide us with additional Personal Information and other information, including your mobile telephone number. This information will be combined and/or associated with the other profile information we have received from the Client.
Device Identifiers and Tracking Technologies: When you use the App we may access, collect, monitor and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device or transmission technologies such as near field communication or low energy Bluetooth or iBeacon, which uniquely identify your mobile device and are used to support and improve the App and use of the App. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent by us to the device. Though a device identifier does not collect or share any Personal Information about you, it may be used in conjunction with Personal Information obtained from other sources to deliver content and analyze use of the App. A device identifier may remain persistently on your device. We may access, collect and/or store device identifiers and maintain them in your profile.
Vehicle Use Information: Through your use of the App, you permit the collection of, or otherwise input information regarding the use of your vehicle and those services that support the use of your vehicle. Additional information, such as other contacts, favorite locations or limited information about vehicle care transactions (e.g., maintenance and recall service; registration documents; and, business mileage or odometer readings) may be provided by you through the App. Such information will be available to you through the App as well as through our web site, and may be available to the Client as part of the Services. Other vehicle information and vehicle transaction information managed by us for the Client in connection with the Services will be visible to you in the App. The App also interfaces with databases related to the use of vehicles through use of motor vehicle registration data. Therefore, public records related to the motor vehicle registration number (e.g. traffic incidents) may be collected and associated with your Personal Information.
If your company has authorized the “AutoLog” GPS-assisted business mileage logging feature, you have the ability to opt in to use the feature to automatically record business mileage using location services built into your phone. Wheels does not store precise GPS route history, only the approximate stop locations and summary distances that are calculated by the application. The Wheels Mobile Assistant may show you a map of your driven routes, but that route information is local to the phone and is not sent to Wheels or your employer. You as a driver can choose to use the tallied business mileage to complete your mileage submission requirements or if on Wheels’ Reimbursement product, submit these trip summaries for reimbursement. You as a driver have the ability to export the data or delete the trip details stored on your phone. Other than geo-location data collected when the business mileage logging feature is activated, the App does not collect sensitive information.
How We Use and Disclose Information
We may use your Personal information to send you communications such as service notifications, security alerts, and other operational notices related to the App and/or the Services.
We use information we collect to operate, maintain and provide you the features and functionality of the App, to analyze how the App is used, diagnose service or technical problems, maintain security, personalize content, remember information to help you efficiently access your account, aggregate, monitor relevant metrics and otherwise provide the Services. We also use information collected through use of the App for research and analytical purposes and such information may be disclosed (in non-personally identifiable form) to the Client and/or other fleet Clients.
Client Access: The Client has the right to access and review the information related to your use of the vehicle that is collected when submitted via data forms in the App in support of and to provide the Services (e.g., maintenance and recall service; registration documents; and, business mileage or odometer readings). We are not responsible for the Client’s use of the information.
Service Providers: Your information may be disclosed to certain third-party providers who participate in the delivery of the Services related to managing your vehicle. These service providers may include towing services, maintenance shops, vehicle dealership or similar providers.
Application Service Providers: Additionally, your information may be disclosed to certain third-party service providers who assist us in providing you with the App. These application service providers may include hosting services, diagnostic troubleshooting services, email, SMS gateways or mobile device communication companies. We have agreements with application service providers which limit use of the information for the purposes of providing services for us in connection with providing you the App.
Business Transfers: As we develop our business, we may buy or sell assets or business offerings. Information relating to users is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution or discussions regarding such transactions.
Compliance with Laws and Law Enforcement: We may disclose Personal Information if required to do so by law or subpoena or if we believe that it is reasonably necessary to comply with a law, regulation or legal process; to protect the safety of any business, person or member; to address fraud, security or technical issues; or to protect our rights or property or the rights of others. We may in our sole discretion elect in good faith to cooperate with any law enforcement agency requesting assistance with an official investigation by disclosing and/or sharing with such agency any and all information, data and/or content connected with use of the App. We may also, but need not, in our sole discretion, initiate a report to any law enforcement agency where it is reasonably suspected that unlawful activity may occur, or may have occurred, including but not limited to disclosing and/or sharing information, data and/or content connected with use of the App.
Information received by us through the App is stored and processed on secured servers and computers we control in the United States. We use (and our service providers are required to use) reasonable technical and administrative security measures designed to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to data centers, and information access authorization controls.
While we have implemented reasonable security measures please keep in mind that “perfect security” does not exist, and no transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us and utilizing the App. Please remember that you are responsible for maintaining the confidentiality and security of any user name and password you use in connection with the App. If you believe that your account or account information is being used in an unauthorized fashion, you must contact us immediately. You are also responsible for all use of the App resulting from your account.
Access to Information
You may review and edit certain information that you provide and/or we collect. The App provides you with the ability to create and edit aggregate trip data and personal/business use information. You may also change the mobile phone number associated with the App. You may be limited in ability to edit Profile Information. Profile Information is received from Client and you must contact Client to change that information. Information connected with Profile that is specific to the App, such as mobile phone number, contacts and favorite locations may be edited by you.
Deletion of Information
The App permits you to delete certain information from the App, including “AutoLog” recorded business mileage, mobile phone number, contacts and favorite locations. If you elect to delete the information, any information may remain in aggregate form within our databases, but we will not be able to access the data on an individual basis and we will not be able to restore that information. In addition, locally stored data will be deleted if you uninstall the app, and some locally stored data may be purged by the app on a rolling basis to manage storage size.
Limitation of Liability
By providing us with any Personal Information you expressly and unconditionally release and hold us harmless from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of the information. In addition, while we take efforts to ensure the proper and appropriate use of data by anyone that may receive your information from us, we cannot be liable for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your information caused by those service providers and third parties.
Last Updated: October 31, 2017