Privacy Policy

At Dav El | BostonCoach, we care deeply about privacy. We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. This policy explains our privacy practices for DavElBostonCoach.com (the “Site”), and Dav El | BostonCoach’s mobile application (the “App”).  The Site and App are operated by Harrison Global LLC and its corporate affiliates (referred to collectively in this policy as “Dav El | BostonCoach,” together with “we,” “us,” “our”, and other similar pronouns). We’ll refer to the Site, the App, and our other services as the “Services.”

Last Updated: December 31, 2019

It will take effect on January 1, 2020.

The previous version of this policy can be viewed here https://davelbostoncoach.com/privacy-policy/5-24-18/.

We need to process  personal information in order to provide the Services and run our business. By using the Services you are confirming that you have read and understand this policy, accept and agree to this policy, including how and why we use your information.

1.Accepting the Privacy Policy

By using the Services, you acknowledge that Dav El | BostonCoach will use your information in the United States, and any other country where Dav El | BostonCoach operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside.

2.Information Collected or Received

In the course of providing our Services, we collect or receive your personal information in a few different ways.

Registration, Account Setup, Service Usage: In order to set up an account, you need to provide a valid email address, full name, phone number and password. In order to book a ride on the Site or the App, you need to set up an account, provide pick-up/drop-off information and provide credit card information. In order to book a ride by phone through our call center, you need to provide a valid email address, full name, phone number, credit card information, and pick-up/drop-off information. We may need to store encrypted credit card information and use it for both billing and payment purposes.

Automated Information: Dav El | BostonCoach automatically receives and collects information from your browser or your mobile device when you visit the Site or use the App (e.g., your IP address, or cookies). This information is stored in log files. We may combine this information from your browser or your mobile device with other information that we collect about you. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for users, to provide more personalized experience for users and advertising.

We may also automatically collect device-specific information when you install, access, or use our Services. This information may include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, and device identifiers.

Cookies: We use the following types of cookies (you may adjust the cookie settings in your browser at any time):

Required Cookies – These cookies are required to enable core site functionality.

  • Remember log-in details and provide secure log-in
  • Provide secure log-in
  • Remember your task or transaction progress

Functional Cookies – These cookies enable additional functionality like saving preferences, allowing social interactions, and analyzing usage for site optimization.

  • Analyze site usage to provide custom content
  • Remember your log-in details
  • Conduct analytics to optimize site functionality
  • Allow third parties to provide social sharing tools
  • Make sure the website looks consistent

Advertising and 3rd Party Cookies – These cookies, along with email addresses, are used by us and third parties to serve ads that are relevant to your interests.

  • Provide you with interest-based offers or ads
  • Allow you to share pages with social networks
  • Allow you to post comments
  • Serve ads relevant to your interests

Location Information: When you use the App, you may consent to share your geo-location details with Dav El | BostonCoach in order to automatically set your pick-up location. Also when you take a ride in a Dav El | BostonCoach vehicle, the geo-location details of the vehicle are automatically tracked.  We may use and store information about your location to provide features and to improve and customize the Services. We will only share your geo-location details with vendors in order to provide you with the Services.

Images Stored on Device: When using the App and with your consent, Dav El | BostonCoach may collect images that you choose to upload from your device in order for you to provide feedback about your experience with the App and the Services.

Analytics Information: We use data analytics to ensure site functionality and improve the Services. We use a mobile analytics software to allow us to understand the functionality of the App on your phone. This software may record information such as how often you use the App, what happens within the App, aggregated usage, performance data, app errors and debugging information, and where the App was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.

Non-Member Information: Dav El | BostonCoach may receive or obtain information (for example, an email address) about a person who is not a registered Dav El | BostonCoach member (a “non-member”) in connection with certain Dav El | BostonCoach features (e.g., when a member adds a non-member guest to the ride s/he is booking). Non-member information is used only for the purposes of providing Services when it was submitted to Dav El | BostonCoach.

Summary of Information Practices
The following table summarizes our personal information collection, use, and sharing practices in the preceding 12 months since we last updated this Policy.  As reflected in this table, we may share your personal information with a variety of outside entities.

 

Category of Personal Information Collected Examples Categories of Sources Commercial/Business Purpose for Collection Categories of Vendors (including third parties and service providers) with Whom Personal Information is Shared
Identifiers Full name, email address, phone number, account login You Maintaining and servicing accounts; providing customer service; processing or fulfilling orders and transactions; marketing and advertising; analytics regarding use of Offerings; communications with you at your request IT vendors, cloud computing providers, database providers, customer service vendors and other service providers that need access to such information to perform services for us, data analytics providers, ad networks, ad tech vendors, social networks, and other marketing and advertising vendors
Unique identifiers or personal identifiers IP address, online identifiers, device ID Your device used to access our Sites, and our and third-party cookies and other tracking technologies on our Sites Protect against malicious, deceptive, fraudulent or illegal activity; analytics regarding use of Services; marketing and advertising IT vendors, cloud computing providers, database providers, customer service vendors and other service providers that need access to such information to perform services for us, data analytics providers, ad networks, ad tech vendors, social networks, and other marketing and advertising vendors
Internet and other network activity Browser information, operating system information, app version, app usage and debugging information, and other technical information Your device used to install, access or use our Services Analytics regarding use of our Sites; marketing and advertising; providing, maintaining our Services; internal research IT vendors, cloud computing providers, database providers, customer service vendors and other service providers that need access to such information to perform services for us, data analytics providers, ad networks, ad tech vendors, social networks, and other marketing and advertising vendors
Geolocation data Location of device Your device used to access and use our Services Processing or fulfilling orders and transactions; providing, maintaining and improving our Services; marketing and advertising; analytics regarding use of our Sites; internal research Customer service vendors and other service providers that need access to such information to perform services for us, data analytics providers, ad networks, ad tech vendors, social networks, and other marketing and advertising vendors
Audio, electronic, visual, thermal, olfactory, or similar information Photos You Maintaining and servicing accounts; providing customer service; processing or fulfilling orders and transactions
Payment information (Information under California Civil Code 1798.80) Credit card information You Process payments; processing or fulfilling orders and transactions Service providers such as payment processors and others as necessary to provide Services to us
Commercial information Purchase history You Processing or fulfilling orders and transactions; customer service Service providers such as payment processors and others as necessary to provide Services to us
Professional or employment-related information Job history You Process and evaluate employment applications and administrative purposes Service providers such as HR vendors and others as necessary to provide services to us

 

3.Choice & Control

We know that members of our community value having control over their own information, so Dav El | BostonCoach gives you the choice of providing,editing, accessing, and deleting certain information, as well as choices about how we contact you. You may change or correct your Dav El | BostonCoach account information through your Dav El | BostonCoach profile and download your ride information from your Dav El | BostonCoach account. You may also request that your account be deactivated. If your account is deactivated, your information will no longer be visible but Dav El | BostonCoach will only maintain your information if needed to comply with legal obligations. Guest passengers wishing to review their personal data should contact the Dav El | BostonCoach account holder that booked on their behalf.

You also have the following additional rights with respect to your information:

Data access and portability: Access to and portability of your data are available by downloading your ride history and personal data by logging into your Dav El | BostonCoach account.

Data correction and/or editing: Personal, ride, password and payment information can be easily changed by logging into your Dav El | BostonCoach account.

Account deactivation: You may request that your account be deactivated and no longer be visible. However, Dav El | BostonCoach must maintain certain information in order to comply with legal obligations.

Withdrawal of consent or objection to processing: You can object to data processing in certain limited circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

Where we use your data for direct marketing purposes, you can always object by withdrawing your consent, using the “unsubscribe” link in such communications or changing your communication preference settings.

Personal, payment and ride information are required to provide your rides, receipts, cancellation notices, etc. Dav El | BostonCoach cannot offer or fulfill the Services without processing this information.

Dav El | BostonCoach strives to meet its customers’ inquiries. If you have a concern about your service or the processing of your information, please contact customer service [email protected]  {note:  there is an underscore “_” between Customer and care}.

Right not to be subject to a decision based only on automated processing: Much of Dav El | BostonCoach’s processing (booking, billing, fulfilling your ride) is automated in order to protect the security of your information and bring you high quality services. If you would like to speak to a Dav El | BostonCoach agent please contact customer support 866-712-8655.

Decisions based on automated processing cannot be avoided when they are necessary to perform the Services or authorized by EU law.

Complaint filing: If you have used our Services while physically in the EU (i.e., you have taken a ride in the EU, and/or booked a ride while in the EU), you have the right to file a complaint against Dav El | BostonCoach with the European Data Protection Supervisor (“EDPS”), regarding personal data processed specifically for those events. The EDPS’s contact details are: Office of the European Data Protection Supervisor, Rue Wiertz 60, B-1047 Brussels, Belgium, email: [email protected]

If you live in the EU, you may also file a complaint with your local data protection authority.

If you are a California resident, you have the right to know what personal information we collect, use, disclose or sell about you under the CCPA. Additionally, you have the right to access and delete your personal information.

To exercise these California privacy rights and choices, please follow the instructions below:

  • How to request access to your personal information: You may request access to your personal information twice in a 12-month period. To do so, please complete the webform in the Dav El | BostonCoach Privacy Rights Portal https://davelbostoncoach.com/personal-information-request/ email us at [email protected] with the subject heading “California Privacy Rights,” or call 1-866-712-8655. Account holders can request access to their personal information at any time by logging into their accounts on the Site. In response, we will produce an Access Report detailing the personal information we have collected, disclosed, and/or sold about you. This Access Report will be delivered by mail or electronically at your request.  Note, we may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.

 

  • How to request deletion of your personal information: You may request that we delete the personal information it has collected and/or maintained about you. To do so, please complete the webform in Dav El | BostonCoach Privacy Rights Portal https://davelbostoncoach.com/personal-information-request/ , email us at [email protected], or call 1-866-712-8655. Note, we may need to retain certain personal information as permitted by law, such as to complete the transaction for which the personal information was collected, provide a requested good or service, detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities, comply with legal obligations or to enable solely internal uses that are reasonably aligned with your expectations or lawful within the context in which you provided the information.

We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Verification: Please note, we will take steps to verify your identity before fulfilling any of the above requests. If you maintain an account with us, we will verify your identity through existing authentication practices for the account (e.g., username and password). If you are not a registered member, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g., browser or device ID).

Authorized Agents: Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your or your minor child’s personal information.  In order to designate an authorized agent to make a request on your behalf, you must provide written proof that you have consented to this designation unless the agent has power of attorney pursuant to California Probate Code sections 4000-4465. You must also verify your identity directly with us by providing a copy of your government issued identification.

Response Timing and Format: If you are Dav El | BostonCoach customer with an online account, we will deliver our written response to that account online. If you are not a Dav El | BostonCoach customer or do not have an online account, we will deliver our written response by mail or electronically, at your preference. The response will also explain the reasons we cannot comply with a request, if applicable.

Anti-Discrimination Right: We will not discriminate against you for exercising any of your CCPA rights. But note that some of the functionality and features available to you may change or no longer be available to you upon deletion of your personal information or opt-out of sale of your personal information.

We do not sell your personal information for money, but we use cookies and similar technologies. Please see our section above regarding our cookie usage.

We do not and will not sell the personal information of minors under 16 years of age without affirmative authorization.

4.Messages from Dav El | BostonCoach

On occasion, Dav El | BostonCoach may need to contact you. These communications are service-related and necessary for users. You agree that Dav El | BostonCoach can send you service-related communications, such as those related to rides, transactions, your account, or security. Examples of service-related communications include an email address confirmation/welcome email when you register your account, notification of a booked ride, modification of key features or functions, and correspondence with Dav El | BostonCoach’s support team.

When you register for an account, you can agree to receive marketing communications from us. You can unsubscribe at any time from marketing communications through the opt-out link included in the marketing communications or through your account settings.

5.Information Uses, Sharing & Disclosure

We respect your privacy. Dav El | BostonCoach will not process or share your personal information without your consent, except based on the following legal grounds:

  • it is necessary to perform the contractual obligations in our Terms & Conditions and in order to provide the Services to you;
  • it is necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims;
  • it is necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners;
  • it is available in government records
  • it is necessary in the public interest;
  • it is necessary to protect your vital interests, or those of others.

Where we process your information without your consent, we do as follows.

Providing and improving our Services: We may use customer information as it is necessary to pursue our legitimate interests of improving our Services for our users, understanding how our Services are being used, and exploring and unlocking ways to develop and grow our business.

Keeping our Services safe and secure: We may also use customer information for safety purposes, in order to ensure the security of our Services.

Legal and Safety: Dav El | BostonCoach may also retain, preserve, or release your personal information to a third party in the following limited circumstances: in response to lawful requests by public authorities; to protect, establish, or exercise our legal rights or defend against legal claims; to comply with a subpoena, court order, legal process, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of Dav El | BostonCoach’s Terms & Conditions.

Service Providers: It is also necessary for Dav El | BostonCoach to engage service providers in order to operate and provide the Services. These service providers have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated to Dav El | BostonCoach not to disclose or use your information for other purposes.

Business Reorganization: In some cases, Dav El | BostonCoach may choose to buy or sell assets. In these types of transactions (such as a sale, merger, liquidation, receivership, or transfer of all or substantially all of Dav El | BostonCoach’s assets), member information is typically one of the business assets that is transferred. If Dav El | BostonCoach intends to transfer information about you, Dav El | BostonCoach will notify you by email or by putting a prominent notice on the Site and the App, and you will be afforded an opportunity to opt out before information about you becomes subject to a different privacy policy.

6.Security

The security of your personal information is important to us. Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services.

Dav El | BostonCoach follows the industry best practices to protect the personal information submitted to us, both during transmission and after it is received. Some of these standards are:

  • Encryption of certain information (such as credit card numbers) using secure socket layer technology (SSL);
  • Protection of the confidentiality, integrity, and availability of all customer information systems;
  • Definition and monitoring of IT security standards aligned with industry regulations;
  • Implementation of vulnerability management techniques according to which we scan and map our network, prioritize areas of importance and apply fixes and safeguards;
  • Application of safeguard firewalls and anti-virus tools to detect/prevent attacks;
  • Continuous monitoring for security risks and maintenance of patch updated infrastructure;
  • Over 85 policies encompassing data security;
  • Security awareness trainings to our personnel.

With specific regard to credit card information, we comply with the Payment Card Industry Data Security Standard (“PCI DSS”) by (but not limited to) designing, implementing, and maintaining a coherent set of standards and procedures to manage risks to cardholder data – in an effort to ensure an acceptable level of Information Security risk – and by conducting yearly PCI DSS audits.

We regularly review, test and update our security policies and systems in order to meet the highest standards of data security. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

7.Retention

Dav El | BostonCoach will retain your information only for as long as it is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Dav El | BostonCoach member account), as described in this policy, or as needed to provide the Services to you. If you no longer want Dav El | BostonCoach to use your information to provide the Services to you, you may close your account. Dav El | BostonCoach will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, Dav El | BostonCoach’s service providers may also be required to retain and use your information in order to comply with their legal obligations.

8.Privacy Policy Changes

We may amend or update this policy from time to time. The revised privacy policy will be published on the Site. If we believe that the changes are material, we’ll do one of (or both) the following: (i) post notice of the changes on the Site before the changes become effective, (ii) send you an email about the changes before the changes become effective. We encourage you to check back regularly and review any updates.

9.Contact

If you have any questions, you can contact Dav El | BostonCoach’s Support Team via our Customer Support Center https://davelbostoncoach.com/help/, and/or write to us at the following address:

Dav El | BostonCoach

69 Norman Street

Everett, MA 02149

USA