# PRIVACY NOTICE
#### Last updated January 01, 2021
Thank you for choosing to be part of our community at Geo Data Intelligence
Corporation, doing business as EZRouting ("**EZRouting**," "**we**," "**us**," or "**our**"). We
are committed to protecting your personal information and your right to privacy. If you
have any questions or concerns about this privacy notice or our practices with regard
to your personal information, please contact us at email@example.com.
This privacy notice describes how we might use your information if you:
* Visit our website at [http://www.ezrouting.com](http://www.ezrouting.com)
* Download and use our mobile application — BusQuest
* Engage with us in other related ways ― including any sales, marketing, or events
In this privacy notice, if we refer to:
* "**Website**," we are referring to any website of ours that references or links to this policy
* "**App**," we are referring to any application of ours that references or links to this policy, including any listed above
* "**Services**," we are referring to our Website, App, and other related services, including any sales, marketing, or events
The purpose of this privacy notice is to explain to you in the clearest way possible
what information we collect, how we use it, and what rights you have in relation to it.
If there are any terms in this privacy notice that you do not agree with, please
discontinue use of our Services immediately.
**Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect.**
## TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE USE YOUR INFORMATION?
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
## 1. WHAT INFORMATION DO WE COLLECT?
### Personal information you disclose to us
**In Short**: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register
on the Services, express an interest in obtaining information about us or our products
and Services, when you participate in activities on the Services (such as by posting
messages in our online forums or entering competitions, contests or giveaways) or
otherwise when you contact us.
The personal information that we collect depends on the context of your interactions
with us and the Services, the choices you make and the products and features you
use. The personal information we collect may include the following:
**Personal Information Provided by You**. We collect email
addresses; usernames; passwords; and other similar information.
All personal information that you provide to us must be true, complete and accurate,
and you must notify us of any changes to such personal information.
### Information collected through our App
**1In Short**: We collect information regarding your geolocation, push notifications,
when you use our App.
If you use our App, we also collect the following information:
* Geolocation Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our App, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
* Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.
## 2. HOW DO WE USE YOUR INFORMATION?
**In Short**: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business
purposes described below. We process your personal information for these purposes
in reliance on our legitimate business interests, in order to enter into or perform a
contract with you, with your consent, and/or for compliance with our legal obligations.
We indicate the specific processing grounds we rely on next to each purpose listed
We use the information we collect or receive:
* **To facilitate account creation and logon process**. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
* **To post testimonials**. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at firstname.lastname@example.org and be sure to include your name, testimonial location, and contact information.
* **Request feedback** . We may use your information to request feedback and to contact you about your use of our Services.
* **To enable user-to-user communications**. We may use your information in order to enable user-to-user communications with each user's consent.
* **To manage user accounts**. We may use your information for the purposes of managing our account and keeping it in working order.
* **To send administrative information to you**. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
* **To protect our Services**. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
* **To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.**
* **To respond to legal requests and prevent harm.** If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
* **Fulfill and manage your orders.** We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
* **Administer prize draws and competitions.** We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
* **To deliver and facilitate delivery of services to the user.** We may use your information to provide you with the requested service.
* **To respond to user inquiries/offer support to users.** We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
## 3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
**In Short:** We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
* **Consent:** We may process your data if you have given us specific consent to use your personal information for a specific purpose.
* **Legitimate Interests:** We may process your data when it is reasonably necessary to achieve our legitimate business interests.
* **Performance of a Contract:** Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
* **Legal Obligations:** We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
* **Vital Interests:** We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
* **Business Transfers.** We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
to access or store information. Specific information about how we use such
technologies and how you can refuse certain cookies is set out in our Cookie Notice:
## 5. HOW LONG DO WE KEEP YOUR INFORMATION?
**In Short:** We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the
purposes set out in this privacy notice, unless a longer retention period is required or
permitted by law (such as tax, accounting or other legal requirements). No purpose in
this notice will require us keeping your personal information for longer than three (3)
months past the termination of the user's account.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if this is not
possible (for example, because your personal information has been stored in backup
archives), then we will securely store your personal information and isolate it from
any further processing until deletion is possible.
## 6. HOW DO WE KEEP YOUR INFORMATION SAFE?
**In Short:** We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures
designed to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic
transmission over the Internet or information storage technology can be guaranteed
to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals,
or other unauthorized third parties will not be able to defeat our security, and
improperly collect, access, steal, or modify your information. Although we will do our
best to protect your personal information, transmission of personal information to and
from our Services is at your own risk. You should only access the Services within a
## 7. DO WE COLLECT INFORMATION FROM MINORS?
**In Short:** We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By
using the Services, you represent that you are at least 18 or that you are the parent
or guardian of such a minor and consent to such minor dependent’s use of the
Services. If we learn that personal information from users less than 18 years of age
has been collected, we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of any data we
may have collected from children under age 18, please contact us at
## 8. WHAT ARE YOUR PRIVACY RIGHTS?
**In Short:** You may review, change, or terminate your account at any time.
If you are a resident in the EEA or UK and you believe we are unlawfully processing
your personal information, you also have the right to complain to your local data
protection supervisory authority. You can find their contact details [here](https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm).
If you are a resident in Switzerland, the contact details for the data protection
authorities are available [here](https://www.edoeb.admin.ch/edoeb/en/home.html).
### Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:
* Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete your
account and information from our active databases. However, we may retain some
information in our files to prevent fraud, troubleshoot problems, assist with any
**Cookies and similar technologies:** Most Web browsers are set to accept cookies
by default. If you prefer, you can usually choose to set your browser to remove
cookies and to reject cookies. If you choose to remove cookies or reject cookies, this
could affect certain features or services of our Services. To opt-out of interest-based
advertising by advertisers on our Services visit [http://www.aboutads.info/choices/](http://www.aboutads.info/choices/). For
further information, please see our Cookie Notice: [http://www.ezrouting.com](http://www.ezrouting.com).
**Opting out of email marketing:** You can unsubscribe from our marketing email list
at any time by clicking on the unsubscribe link in the emails that we send or by
contacting us using the details provided below. You will then be removed from the
marketing email list — however, we may still communicate with you, for example to
send you service-related emails that are necessary for the administration and use of
your account, to respond to service requests, or for other non-marketing purposes.
To otherwise opt-out, you may:
* Access your account settings and update your preferences.
## 9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track ("DNT") feature or setting you can activate to signal your
privacy preference not to have data about your online browsing activities monitored
and collected. At this stage no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do not currently respond
to DNT browser signals or any other mechanism that automatically communicates
your choice not to be tracked online. If a standard for online tracking is adopted that
we must follow in the future, we will inform you about that practice in a revised
version of this privacy notice.
## 10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
**In Short:** Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law,
permits our users who are California residents to request and obtain from us, 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 a Service, you have the right to request removal of unwanted data that you
publicly post on the Services. 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 Services, but please be aware
that the data may not be completely or comprehensively removed from all our
systems (e.g. backups, etc.).
### CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
1. every individual who is in the State of California for other than a temporary or
transitory purpose and
2. every individual who is domiciled in the State of California who is outside the
State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and
obligations regarding your personal information.
**What categories of personal information do we collect?**
We have collected the following categories of personal information in the past twelve (12) months:
|Category | Examples | Collected |
|A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name | YES |
|B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history and financial information | YES |
|C. Protected classification characteristics under California or federal law | Gender and date of birth | NO |
|D. Commercial information | Transaction information, purchase history, financial details and payment information | NO |
|E. Biometric information | Fingerprints and voiceprints | NO |
|F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements | NO |
|G. Geolocation data | Device location | YES |
|H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
|I. Professional or employment-related information | Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us | NO |
|J. Education Information | Student records and directory information | NO |
|K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | NO |
We may also collect other personal information outside of these categories instances
where you interact with us in-person, online, or by phone or mail in the context of:
* Receiving help through our customer support channels;
* Participation in customer surveys or contests; and
* Facilitation in the delivery of our Services and to respond to your inquiries.
**How do we use and share your personal information?**
More information about our data collection and sharing practices can be found in this
privacy notice and our Cookie Notice: [http://www.ezrouting.com](http://www.ezrouting.com).
You may contact us by email at Hello@ezrouting.com, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
**Will your information be shared with anyone else?**
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.
Geo Data Intelligence Corporasation has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. Geo Data Intelligence Corporasation will not sell personal information in the future belonging to website visitors, users and other consumers.
**Your rights with respect to your personal data**
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your
personal information, we will respect your request and delete your personal
information, subject to certain exceptions provided by law, such as (but not limited to)
the exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation or any processing that may be required
to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
* whether we collect and use your personal information;
* the categories of personal information that we collect;
* the purposes for which the collected personal information is used;
* whether we sell your personal information to third parties;
* the categories of personal information that we sold or disclosed for a business purpose;
* the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
* the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete
consumer information that is de-identified in response to a consumer request or to reidentify
individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify your identity to determine you are
the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we can match it
with information you have previously provided us. For instance, depending on the
type of request you submit, we may ask you to provide certain information so that we
can match the information you provide with the information we already have on file,
or we may contact you through a communication method (e.g. phone or email) that
you have previously provided to us. We may also use other verification methods as
the circumstances dictate.
We will only use personal information provided in your request to verify your identity
or authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. If, however, we
cannot verify your identity from the information already maintained by us, we may
request that you provide additional information for the purposes of verifying your
identity, and for security or fraud-prevention purposes. We will delete such
additionally provided information as soon as we finish verifying you.
Other privacy rights
* you may object to the processing of your personal data.
* you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.
* you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
* you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at Hello@ezrouting.com, or by
referring to the contact details at the bottom of this document. If you have a complaint
about how we handle your data, we would like to hear from you.
## 11. DO WE MAKE UPDATES TO THIS NOTICE?
**In Short:** Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be
indicated by an updated "Revised" date and the updated version will be effective as
soon as it is accessible. If we make material changes to this privacy notice, we may
notify you either by prominently posting a notice of such changes or by directly
sending you a notification. We encourage you to review this privacy notice frequently
to be informed of how we are protecting your information.
## 12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data
Protection Officer (DPO), Jason Wang, by email at email@example.com, by phone
at 518-330-2784, or by post to:
Geo Data Intelligence Corporation
30 Cavalier Way
Latham, NY 12110
If you have any further questions or comments, you may also contact us by post at
the following corporate address:
Geo Data Intelligence Corporation
247 Cayuga Road
Cheektowaga, NY 12110
## 13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
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 a request form to firstname.lastname@example.org