Consumer Portal Privacy Notice
This Privacy Notice explains the data collection, use, and data sharing practices of Auto Titles of America, LLC, a Verra Mobility company, d/b/a Peasy (“Peasy”) on the websites and mobile applications that link to, or include, this Privacy Notice (“Websites” and “Applications”). Peasy is committed to protecting your privacy. We have prepared this Privacy Notice to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our Websites, our Applications, and our online services (“Services”). It does not apply to websites, applications or services of Peasy or its subsidiaries that are offered under a different Privacy Notice.
Peasy provides Services to individuals as well as to business customers (collectively, “Users”). The Terms of Use Agreement posted on each Website sets forth the terms that apply to the use of the Website and Services associated with that website, unless Peasy has entered into a separate agreement with its business customer that governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Business Data”). The organization that entered into the Customer Agreement (“Business Customer”) controls any associated Business Data, including any Personal Data that they submit to us, or receive from us, during providing the Services to such Business Customer.
- Changes to This Privacy Notice. This Privacy Notice may be updated from time to time for any reason. We will notify you of any changes to our Privacy Notice by posting the new Privacy Notice at www.drivepeasy.com. You should consult this Privacy Notice regularly for any changes.
- Questions; Contacting Peasy; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Notice or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:
Verra Mobility
Attn: Privacy Office
1150 N. Alma School Rd, Mesa AZ 85201
Telephone: +1 (480) 596-4566
Email:
privacy@verramobility.com
- If you are a California resident, please be sure to review the section “Additional Information for California Residents” below for important information, as required by California privacy laws, about the categories of personal information we collect and disclose, as well as your rights under California privacy laws.
- User Consent. By submitting Personal Data through our Websites, Application(s) or Services, you agree to the terms of this Privacy Notice and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Notice.
- A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Peasy and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible.
- Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, cell phone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Business Data, Personal Data, payment method data and Anonymous Data, as described below.
- Business Data. Business customers may submit Business Data to Peasy when using the Services.
- Information You Provide to Us.
- We may collect Personal Data from you, such as your first and last name, gender, e-mail and mailing addresses, professional title, company name, the last 4-digits of your drivers’ license, license plate number, telephone number and password when you create an account to log in to our network (“Account”).
- If you use our Services on your mobile device, including through our Application(s), we may collect your phone number and the unique device id number.
- If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can either uninstall the Application(s) or deactivate location services for the Application(s) on your mobile device.
- When you order Services on our Websites or our Application(s), we will collect all information necessary to complete the transaction, including your name, payment method information, billing information and shipping information. We do not store this information directly on our servers, but this information may be shared with third parties who will help process and fulfill your purchase. If our Website requires that you submit credit card numbers, we encrypt that information using industry standard technology.
- Our Websites may collect and process information about you to (i) process online payments for tolls or traffic citations; (ii) provide access to citation images, invoices and credit card statements; (iii) respond to an inquiry request; or (iv) provide access to rental car agency-specific FAQs and other information.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, to send you a reply.
- When you participate in one of our surveys, we may collect additional profile information.
- We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
- We may also collect Personal Data at other points in our Websites that state that Personal Data is being collected.
- Information Collected via Technology.
- Information Collected by Our Servers. To make our Websites, Application(s) and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.\n
- Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Websites, track users’ movements around the Websites, gather demographic information about our user base, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Websites or use the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Notice, we do not link this automatically-collected data to Personal Data.
- Integrated Service Providers and Linked Networks. You can elect to sign in or sign up to Peasy through a linked network (e.g., Facebook, Google), and you can connect your existing account with certain third-party networks like Facebook, Twitter and LinkedIn (each a “Linked Network”). If you elect to sign up through or connect a Linked Network, we receive certain profile and account information about you from the Linked Network. The specific information provided to us by these Linked Networks is determined by these third-parties and may vary by network. In all cases, the permissions page for the Linked Network will describe the information being shared. You should consult their respective privacy policies for information about their privacy practices. You may also elect to connect through third party networks (“Integrated Service Provider”). If you do so, you will be allowing us to pass to and receive from the Integrated Service Provider your login information and other user data.
- Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Websites. This type of information is collected to make the Websites more useful to you and to tailor the experience with us to meet your special interests and needs. For more information on Cookies, including how to manage or delete Cookies, please see our Cookies Policy.
- Pixel Tags. In addition, we may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format that users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
- How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our Websites.
- Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded our Application(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Application(s), and information about the type of device you use. In addition, in the event our Application(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
- Analytics Services and Interest-Based Advertising. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Websites. This includes third party analytics services, including but not limited to Google Analytics (“Analytics Services”), that we engage to help analyze how users use the Website, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Websites and Services. The information generated by the Cookies or other technologies about your use of our Websites and Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Notice. By using our Websites and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at 1-833-99-PEASY (1-833-997-3279). We may also partner with ad companies to support our marketing efforts, including by serving you ads better tailored to your likely interests. If you don’t want to take advantage of these services, you may be able to opt-out by visiting
http://www.aboutads.info or
http://networkadvertising.org/choices/.
- Location Information. If you have enabled location services on your phone, we collect your location information to make a map available to the recipients of your messages showing your location. If you do not want this information collected by us, you can disable location services on your phone.
- Use of Your Personal Data
- Business Data. Business Data will be used by us in accordance with our Business Customer’s instructions, including any applicable terms in the Customer Agreement and our Business Customer’s use of Services functionality, and as required by applicable law. Peasy is a processor of Business Data and our Business Customer is the controller.
- General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
- identify you as a user in our system;
- provide improved administration of our Websites, Application(s) and Services;
- provide the Services you request;
- improve the quality of experience when you interact with our Websites, Application(s) and Services;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as security or support and maintenance advisories;
- send you administrative communications about the Services;
- respond to your inquiries related to employment opportunities or other requests;
- make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback; and
- send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Peasy.
- Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Website navigation. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
- Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Notice.
- Business Customer’s Instructions. Peasy will solely share and disclose Business Data in accordance with our Business Customer’s instructions, including any applicable terms in the Customer Agreement and our Business Customer’s use of Services functionality, and in compliance with applicable law and legal process.
- Third Parties Designated by You. We may share your Personal Data with third parties, such as toll authorities, municipalities, or other persons or entities to which you have authorized us, via our Terms of Use Agreement(s) or otherwise, to disclose such data.
- Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Websites or Application(s); to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to Peasy.
- Affiliates. We may share some or all your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Notice.
- Corporate Restructuring. We may share some or all your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Notice.
- Disclosure to Third Party Companies. We may enter into agreements with companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website (“Third Party Companies”). A Third Party Peasy Company may want access to Personal Data that we collect from its customers. As a result, we may disclose your Personal Data to a Third Party Peasy Company; however, we will not disclose your Personal Data to any Third-Party Company for the Third-Party Company’s own direct marketing purposes, unless you have “opted-in” by following the instructions we provide to allow such disclosure. If you have opted-in to receive e-mail communications from a Third-Party Company and later wish to discontinue receipt of these e-mails, please contact the Third-Party Company directly to update your preferences. The privacy policies of these Third-Party Companies may apply to the use and disclosure of your Personal Data that we collect and disclose to such Third-Party Companies. Because we do not control the privacy practices of Third-Party Companies, you should read and understand their privacy policies.
- Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Peasy may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Peasy; (c) to protect or defend the rights or property of Peasy or users of the Website or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Notice, or our Terms of Use.
- Third Party Websites. Our Websites may contain links to third party websites, including the websites of our Business Customers. When you click on a link to any other website or location, you will leave our Website and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Notice do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
- Your Choices Regarding Information. You have several choices regarding the use of information on our Services:
- Email Communications. We may periodically send you free newsletters and e-mails that directly promote the use of our Websites, Application(s) or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use Agreement or Privacy Notice.
- Changing or Deleting Your Personal Data You may review, update, correct or delete the Personal Data in your user account (including any imported contacts) by making your desired modifications within the profile page on our Applications or by contacting us at 1-833-99-PEASY (1-833-997-3279). If you completely delete all your Personal Data, then your Account may become deactivated. We will use commercially reasonable efforts to honor your request. We will retain billing and payment method information associated with our Peasy Application for a period of 120 days following any cancellation of your account to process payment for any tolls that were incurred before the date of cancellation. We may retain an archived copy of your records as required by law or for legitimate business purposes.
- Applications. You can stop all collection of information by the Application(s) by uninstalling the Application(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You may at any time opt-out from further allowing us to have access to your location data by deactivating location services for the Application on your mobile device.
- Security of Credit Card and Bank Account Information. For online payments and/or Automated Clearing House (ACH) payouts, we use the payment services of one or more payment processors listed on the applicable Website. We do not process, record or maintain your credit card or bank account information. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to the applicable Website.
- Your California Privacy Rights
Certain California privacy laws, including the California Consumer Privacy Act (“CCPA”) require that we provide California residents specific information about how we use their personal information.
Categories of Personal Information that We Collect, Disclose, and Sell
Below please find the categories of personal information about California residents that we collect, sell, and/or disclose to third parties or service providers for a business purpose.
Categories of personal information
|
Do we collect?
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Do we disclose for business purposes?
|
Do we sell?
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NAME, CONTACT INFORMATION AND IDENTIFIERS: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
|
YES
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NO
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NO
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CUSTOMER RECORDS: Paper and electronic customer records containing personal information, such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
|
YES
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NO
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NO
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PROTECTED CLASSIFICATIONS: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
|
NO
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NO
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NO
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purchase history and tendencies: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|
YES
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NO
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NO
|
Biometric information: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
|
NO
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NO
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NO
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USAGE DATA: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.
|
YES
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NO
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NO
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GEOLOCATION DATA: Geographic location information about a particular individual or device
|
YES
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NO
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NO
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AUDIO/VISUAL: Audio, electronic, visual, thermal, olfactory, or similar information.
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YES
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NO
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NO
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EMPLOYMENT HISTORY: Professional or employment-related information.
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NO
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NO
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NO
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EDUCATION INFORMATION: Information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
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NO
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NO
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NO
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PROFILES AND INFERENCES: Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|
NO
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NO
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NO
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California Consumer Rights
California law gives consumers the right to make the following requests, up to twice every 12 months:
- The right to request a copy of the personal information that we have collected about you in the prior 12 months.
- The right to request details about the categories of personal information we collect, the categories of sources, the business or commercial purposes for collecting information, and the categories of third parties with which we share information.
- The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.
- The right to opt-out of sale of your personal information. To exercise your opt-out rights, please visit our
Do-Not-Sell My Personal Information form.
You can submit a copy, deletion and right-to-know request by:
The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data. We do not discriminate against consumers when they exercise their CCPA rights.
California Privacy Rights under California’s Shine-the-Light Law
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. California residents who would like to make such a request may submit a request in writing to privacy@verramobility.com. The request should attest to the fact that the requester is a California resident, and provide a current California address.
CONTACT US WITH ANY QUESTIONS ABOUT THIS PRIVACY NOTICE:
Verra Mobility
Attn: Privacy Office
1150 N. Alma School Rd, Mesa AZ 85201
Telephone: +1 (480) 596-4566
Email:
privacy@verramobility.com