Effective Date: 10/5/2022
1. Information Collection
When using any of the Platforms, you may voluntarily provide information about yourself. We collect this information when you create an account, provide information via email or the 1stMILE Online Chat, complete surveys and forms through the 1stMILE Platforms, enroll in our programs, or interact with us for any other purpose. We may also automatically collect information relating to your interactions with us and our Platforms.
For example, we may collect or access the following information:
Personal and online identifiers (such as name, email address, IP address, or other unique online identifiers)
Certain customer record information (such as address, telephone number, financial account numbers, or any other financial information)
Characteristics of protected classifications under California or federal law (such as gender)
Commercial or transactions information (such as records of transactions with 1stMILE)
Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)
Biometric information (such as call recordings)
Inferences drawn from the above information about your predicted characteristics and preferences
Other information about you that is linked to the personal information above (such as Vehicle Identification Number (“VIN”), make and model of your vehicle, and any other information you associate with your 1stMILE account).
2. Information Use
We may use your information for any lawful purpose, including the following:
To respond to your inquiries;
To operate and improve our services, including to provide better services, products, and opportunities to our customers and visitors to our Platforms;
To enroll you in, and administer our programs, including the 1stMILE Loyalty Program and the 1stMILE Buy Program, including to deliver services related to the programs;
To operate, personalize, and improve the Platforms, including for advertising and analytics purposes;
To send surveys, promotions, and marketing materials that may be of interest to you, and for other marketing activities;
To prevent and detect fraud;
To comply with the law and to maintain the security of our Platforms; or
With your consent, or as otherwise disclosed at the time information is collected.
3. Information Sharing
We may share the information we collect with other parties, including the following:
To Fulfill Your Requests. We may share information with third-party service providers or vendors who process data on our behalf to help our business operations, such as payment processors and email service providers.
Corporate Changes. We may share information as part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding.
As Required by Law and Similar Disclosures. We may share information pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of third parties.
Affiliates. We may share information with corporate affiliates, including those not under the 1stMILE brand.
Other Third Parties. We may share information with third-party companies, vendors, business partners, and other organizations whose products or services we think may interest you.
De–identified or Anonymized Information. We may share information that has been de-identified or aggregated without limitation.
Consent. We may share information with your consent or as otherwise disclosed at the time of data collection or sharing.
To prevent unauthorized access, use or disclosure of information we collect, we have put in place commercially reasonable physical, electronic and managerial procedures to safeguard and secure the information.
We may work with third parties that collect data about your use of the Platforms and other sites or apps over time for non-advertising purposes. We use Google Analytics and other third-party services to improve the performance of the Platforms and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Platforms, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.
6. Third-Party Links and Tools
We may provide links on the Platforms to third-party websites or apps, including plug-ins that link to social media sites such as Facebook, Twitter, YouTube, LinkedIn, and Instagram. These websites and apps are independent from 1stMILE and have their own separate privacy policies. 1stMILE is not responsible for the privacy practices or content of such third-party websites or apps. We recommend that you review the third-parties’ privacy polices before you visit these websites or apps to learn about their data practices.
The Platforms may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Platforms, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy notices of the companies that provide those features. We encourage you to carefully read the privacy notices of any accounts you create and use.
7. Opting Out of Promotional Emails and Text Messages
If you decide for any reason that you no longer wish to receive promotional emails from us, you can unsubscribe from our email distribution list by clicking the “unsubscribe” link located at the bottom of each promotional email. You can also opt out of receiving emails by sending a request to [email protected]. Please note that if you opt-out of receiving promotional emails from us, we may still contact you by email for transactional purposes related to your account or business relationship with us.
To opt-out of promotional text messages, please reply STOP to any message you receive.
8. California Privacy Rights
This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.
Categories of Sources. We collect this personal information from the following categories of sources:
Data analytics providers;
Data brokers and third party data providers;
Social networks; and
Our commercial purposes, including marketing, advertising, and enabling commercial transactions.
Our business purposes as identified in the CCPA, which can include:
Auditing related to our interactions with you;
Detecting and protecting against security incidents, fraud, and illegal activity;
Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
Internal research for technological improvement;
Activities to maintain and improve our services; and
Other one-time uses.
Recipients of California Personal Information. We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes:
Internet service providers;
Data analytics providers;
Operating systems and platforms; and
Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
The right to know the categories and specific pieces of personal information we collect, use, and disclose about you; the categories of sources from which we collected personal information about you; our purposes for collecting personal information about you; the categories of personal information about you that we have disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
The right to request that we delete the personal information we have collected from you.
The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
To exercise any of the rights described above, please contact us using the following information and submit the required verifying information, as further described below:
By phone at (877) 726-7932
By email at [email protected]
Online through https://1stMILE.com/california-consumer-request-form
Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your full name, email address or other contact information, and information about your relationship with 1stMILE.
Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf. You will need to provide your identification, the identification of the agent, and your written consent for them to act on your behalf.
Minors’ Right to Opt In. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
10. How to Contact Us