Privacy Policy

This Privacy Notice describes how Lula Technologies, Inc. (“we”, “us”, or “our”) collects, uses, and discloses personal information in connection with our various insurance-related services and offerings (“services”) and when you access or use our website and online platform, the services provided through our online platform (including through APIs we make available to access the platform), or any other website or services that link to this Privacy Notice, or when you otherwise communicate with us.  This Privacy Notice also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.
‍
When we receive or process information for our own purposes, such as contact or billing information of parties directly using our services (“customers”), this Privacy Notice applies. When we receive or process information on behalf of our customers, such as contact or background information of renters or drivers of our customers and individuals applying to become renters or drivers (“clients”), the privacy practices that apply to the processing of that information are governed by our customer’s Privacy Notice.  

Our online platform often involves the collection of personal information from clients of our customers’ vehicles. The clients of our customers (as well as individuals applying to become renters and drivers) are not our customers.  We refer to information received by our customers from their renters and drivers as “driver information.”
‍

1. What Personal Information We Collect & How We Use It‍
2. The types of personal information we obtain about you depends on how you interact with us. The following provides examples of the types of information that we may collect from you for our purposes and how we use that information.

• In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. 
  
  Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.  As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our general interest in conducting our business.
  

1. Types of Information We Collect About Drivers on Behalf of Our Customers
   

• We limit the collection of personal and public information of drivers of our customers to what is required to accomplish our services. As a service provider and data processor serving at the instruction of our customers, we process the following types of personal information about the drivers of our customers through our online platform, including but not limited to:
  

1. Basic identifying information, such as name, address, telephone number, current employer, email address, and other personal information.
   

1. Information relating to:
   

1. Identity checks consisting of address, name, phone, and email
   

1. Background checks consisting of criminal and credit violations
   

1. Consistent monitoring of motor vehicle records, US DOT CSA scores, and backgrounds checks
   

1. Overall compliance with state and federal Motor Carrier regulations, such as Hours of Service, Driving Logs, and Driver Fitness consisting of Medical History
   

1. Historical financial checks consisting of fraud check and violations
   

1. Vehicle and/or asset information for insurance performance history
   

1. Driver geolocation data for insurance claim resolution
   

1. We may collect information about clients’ interaction with our online platform such as computer browser type, pages visited, Internet and network activity, average time spent on our website and platform, IP address, unique identifier of the device, and operating system version.
   

1. We may request or receive other personal information such as feedback, questions, comments, suggestions, or ideas from clients to provide customers with other benefits or to improve upon the services. In such instances, clients are given the opportunity to provide or decline that information.
   

• We obtain the categories of information identified above directly from our customers, from clients of our customers, from drivers of our customers, from third party sources and from publicly available government records. We also collect information regarding vehicle history, driving records, company history, and insurance claim records from third-party sources and use that to provide our services. These parties have their own privacy and information collection practices and security measures.
  

1. How We Disclose Your Personal Information
   We disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below. Please note that because this list is comprehensive it may refer to types of information that we disclose about people other than yourself.
   

1. We share Identifying Information such as name and contact information with third parties that help administer, manage and analyze our programs and services, provide marketing and data analytics services, and payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
   
2. We share Financial Information with payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
   
3. We share Network Activity Data with third parties that help administer, manage and analyze our programs and services, provide marketing and data analytics services, and payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
   
4. We share Geolocation Data with third parties that help administer, manage and analyze      our programs and services, and provide marketing and data analytics services.
   
5. We share Audio and Visual Information with third parties that help administer, manage and analyze our programs and services and help administer customer service and fraud or loss prevention services.
   
6. We share Professional and Employment Information and Protected Characteristics with third parties that help administer, manage and analyze our recruitment process.
   

1. In addition to the specific situations discussed above, we disclose information in the following situations:
   

1. Affiliates and Acquisitions. We may disclose information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also disclose information with that company, including at the negotiation stage.
   
2. Other Disclosures with Your Consent. We may ask if you would like us to disclose your information with other unaffiliated third parties who are not described elsewhere in this Notice.
   
3. Compliance with Law or Other Legal Process. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also disclose your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
   
4. Third-Party Partners.  Certain of our services and functionality are provided by our Third-Party partners. When you accept the services of any of our third-party partners the information that you provide will be disclosed to us and with them. Their use of your information is not governed by this Privacy Notice.
   
5. Social Media Platforms and Networks. Our website and platform may feature plugins, widgets, or and other tools made available by third parties that may result in information being collected or shared between us and the third-party. Their use of your information is not governed by this Privacy Notice.
   

1. Tracking Technologies
   

1. ‍What are cookies? A cookie is a small file stored on your device when using a browser that enables a variety of features and functionality. We use first-party cookies and other similar technologies to ensure everyone who uses our website and platform has the best possible experience. We also use them for marketing and advertising.
   
   ‍How are cookies used for advertising purposes? We use third-party cookies and other ad technologies such as beacons, pixels, and tags, to help us display adds that cater to your interests. They also help us provide aggregated auditing, research, and reporting for our advertisers and to understand and improve our products and services. Our website uses Google Analytics, a web analytics service provided by Google. If you sign in as a registered user, we may use your user ID in combination with Google Universal Analytics and Google Analytics to track and analyze the pages you visit. 
   
   ‍Controlling cookies. Most browsers allow you to control and erase cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may degrade your overall user experience, since it will no longer be personalized to you. Additionally, website users who do not want their data collected with Google Analytics can visit the Google Analytics opt-out page and install the Google Analytics opt-out add-on for your browser: https://tools.google.com/dlpage/gaoptout
   
   ‍Keep in mind that, if you opt out of interest-based advertising on our website, you may still see customized advertising displayed by advertising networks from which you have not opted out. In addition, your opt out will not prevent any advertising network from displaying advertising that is not customized to you and your interests and, consequently, may be less relevant to you. Please also note that you will need to make such choices on each browser and device you may use to visit our website.
   

1. Your Choices

1. Where applicable to you in accordance with applicable data protection law, you can make the following choices regarding your personal information:
   

1. Access to Your Personal Information. If you are a California residents and would like more information concerning the categories of personal information (if any) we disclose with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the “Contact Information” section below.
   
2. Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
   
3. Promotional Emails. We send free newsletters, surveys, offers, and other promotional materials to you, as well as occasional targeted offers from third parties. You are automatically subscribed to these emails when you make a purchase or account with us. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
   
4. Ground Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO GROUND MAIL” in the subject line along with your name, and address. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
   

1. How We Protect Personal Information

1. Protecting your personal information is important to us. While we work to protect your information, a breach may still happen. In the event of a breach that we are required by law to inform you of, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
   
   If you choose to create an online account, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
   

1. Other Important Information

1. The following additional information relates to our privacy practices:
   

1. Third-Party Applications/Websites.  Our website and platform may include links to websites or applications that are owned or operated by third parties. Please note that any personal information that you provide to such third parties will be governed by their privacy policies, and we have no control over or responsibility for their privacy practices. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or disclosed prior to providing any personal information.   
   
2. Anonymized and Aggregated Data. We may compile, use and disclose anonymized, aggregated reporting and statistics generated from the use of our various insurance-related services and offerings for our lawful business purposes. None of these anonymized, aggregated reports or statistics will enable users or customers to be personally identified.  
   
3. Changes to This Privacy Notice. We may change our Privacy Notice and practices over time. To the extent that our Notice changes in a material way, the Notice that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy Notice. Our Privacy Notice includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
   ‍
   

1. Contact Information

1. If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.
   

• Email: support@lula.is
  Telephone: (855) 241-9318
  Mail:
  LULA Technologies, Inc.
  PO BOX 566747
  Miami, FL 33256

1. Effective Date: March 7th, 2022
   Last Updated: March 7th, 2022