Privacy Policy

Last updated March 14, 2023

1. Introduction
This privacy policy (the “Policy”) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This notice applies to users of Streeto’s services anywhere in the world, including users of Streeto’s apps, websites, features, or other services.

This notice describes how Streeto and its affiliates collect and use data. This notice applies to all Streeto users globally, unless they use a service covered by a separate privacy notice.

2. Information we may collect from you
We may collect and process the following data about you:
• Information you provide to us. You may give us information about you by filling in forms on the mobile app or by corresponding with us (for example, by email). This includes information you provide when you register to use the mobile app, create a Streeto Agreement, describe an occupied parking space, add and/or modify your vehicles, make Streeto Agreement Offers, participate in app transactions/processes, send feedback, chat with users /drivers, participate in discussion boards or other social media functions on the mobile app, send comments or requests, and when you report a problem with the mobile app. The information you give us may include your name, address, location, email address, phone number, vehicle data and personal description.
• Information we collect about you. With regard to each of your visits to the mobile app, we may automatically collect the following information:
location of the device (we collect precise or approximate location data from drivers’ mobile devices when the Streeto app is running in the foreground (app open and on-screen) or background (app open but not on-screen; we try to minimize the use of this option if possible to help you optimize your mobile battery use); app usage; technical information, including the type of device you are using; a unique device identifier; mobile network information; your mobile operating system; the type of mobile browser you are using, and time zone setting;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the mobile app (including date and time); sections you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
• Information we receive from other sources. We may receive information about you from other sources, including from third parties who have obtained your permission to share your information with us, or from publicly available sources.

3. Cookies
We use cookies on the mobile app. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device’s hard drive.
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of the mobile app. They include, for example, cookies that enable you to log into secure areas of the mobile app.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the mobile app when they are using it. This helps us to improve the way the mobile app works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognize you when you return to the mobile app. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to the mobile app, the pages you have visited, and the links you have followed. We will use this information to make the mobile app and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name Purpose
__utma Google Analytics cookie used to distinguish users and sessions. The cookie is created when the javascript library executes and no existing __utma cookies exist. The cookie is updated every time data is sent to Google Analytics.
__utmb Google Analytics cookie used to determine new sessions/visits. The cookie is created when the javascript library executes and no existing __utmb cookies exist. The cookie is updated every time data is sent to Google Analytics.
__utmc Google Analytics cookie used to determine whether the user was in a new session/visit.
__utmz Google Analytics cookie used to store the traffic source or campaign that explains how the user reached your site. The cookie is created when the javascript library executes and is updated every time data is sent to Google Analytics.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the mobile app.

4. Use of your information
We use the information we collect from you in the following ways:
• to ensure that the mobile app is presented in the most effective manner for you and for your device;
• to provide you with information, products, or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
• to carry out our obligations arising from any contracts entered into between you and us;
• to allow you to participate in interactive features of the mobile app, when you choose to do so;
• to notify you about changes to the mobile app;
• to provide customer support;
• to administer the mobile app and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
• to improve the mobile app and to ensure that content is presented in the most effective manner for you and for your device;
• to allow you to participate in interactive features of the mobile app, when you choose to do so;
• as part of our efforts to keep the mobile app safe and secure; and
• to measure or understand the effectiveness of advertising we serve to you and others, and
• to make suggestions and recommendations to you and other users of the mobile app about goods or services that may interest you or them.

We will not sell, distribute, or lease your personal information to third parties unless we have your permission or are required by law to do so.
We may share your personal information with third parties in the following circumstances:
• with service providers who provide services to us, such as hosting and maintenance, customer relationship management, payment processing, and analytics. These service providers are required to keep your personal information confidential and use it only for the purpose of providing the services we have retained them to perform;
• with law enforcement or other governmental authorities, if required by law or if we believe that such action is necessary to protect and defend the rights, property, or personal safety of the mobile app, our users, or others;
• in connection with a sale, merger, acquisition, reorganization, or other transfer of all or part of our business; and
• with your consent or at your direction.

5. Data storage and transfer
Streeto operates and processes personal data globally, so we can offer you a seamless experience. We also respect your data protection rights whether you are in your home country or elsewhere.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our service providers. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details, and the provision of support services. By submitting your personal data, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

Streeto only discloses personal data to law enforcement agencies in a manner that is consistent with the regulatory requirements of applicable laws, such as the GDPR.

This means that we may transfer personal data to countries other than your home country in order to provide our services in a different country at your request. We may also transfer personal data to another country if that is necessary to respond to a customer support request that you submitted outside your region. And streeto agreement data history may be accessed by users in another country after they have left the country where services were rendered. Because our services involve multiple users at the same time, limited personal data may be accessible to the other user in another country.

We do so in order to fulfill our agreements with all of our users, or based on users’ instructions or prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses.

6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we are required to retain certain types of information for specific periods of time.

8. Your rights
You have the following rights in relation to your personal data:

• the right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully;
• the right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected;
• the right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
• the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes;
• the right to request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
• the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; and
• the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can exercise any of your rights by submitting your request in writing to us using the contact information provided below.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

9. Integrating Social Networking Services
The Service allows you to enable or log in to the Services via various social networking services such as Facebook (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Service or log into the Service using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of such third parties, and Streeto shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Service.
You may also have the option of posting your Streeto activities to Social Networking Services when you access content through Streeto (for example, you may post to Facebook that you performed an activity on Streeto); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.

10. California Privacy Rights
California Civil Code Section 1798.83, permits our users who are California residents to request and obtain from Streeto, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Streeto, you have the right to request removal of unwanted data that you publicly post on Streeto. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the App, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

11. Children:
Streeto 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 Services. 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 Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Streeto through the Services, please contact us, and we will endeavor to delete that information from our databases.

12. Complaints
If you have any complaints regarding the processing of your personal data, please submit your request in writing to us using the contact information provided below.
You also have the right to make a complaint at any time to the data protection authority in the country where you live or work, or where you believe a breach of data protection laws has occurred.
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit your request in writing to us using the contact information provided below.

13. Changes to the Policy
We may update this Policy from time to time by publishing a new version on the mobile app. You should check this page occasionally to ensure you are happy with any changes to this Policy. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

We may also notify you of changes to this Policy by email or through the mobile app.
This Policy was last updated on March 14, 2023.

14. Contact Information
If you have any questions about this Policy, please contact us by email at hello@streeto.io.