Privacy Policy

Last Revision: June 11, 2018

Our Policy
Welcome to the web site (the “Site”) of AnyRoad Inc. ("AnyRoad”, “we”, “us” and/or “our”). This Site is operated by AnyRoad and has been created to provide information about our company and our experience relationship management solution services, mobile applications and related services (together with the Site, the “Services”). This Privacy Policy (the “Privacy Policy”) sets forth AnyRoad’s policy with respect to information including personally identifiable data (“Personal Data”) and other information that is collected from visitors to the Site and users of the Services (the “Visitors”, or individually, “Visitor”, “you”, and/or “your”). Any discussion of your use of the Service in this Privacy Policy is meant to include your visits and other interactions with the Site and Services, whether or not you are a user of AnyRoad’s SaaS product.

By using the Services, you do hereby warrant and represent that:

1. You have read, understood, and agreed to all terms and conditions stated herein, including our Vendor Terms of Service (“User Terms”), available at https://www.anyroad.com/terms and the End User Terms of Service ("End User Terms”), available at https://www.anyroad.com/end_user_terms, which govern the use of the Services, as applicable.
2. You are giving AnyRoad permission to use and store such information consistent with this Privacy Policy and our Vendor Terms of Service and End User Terms of Service.

VISITORS OUTSIDE OF THE U.S.
Important Information for Visitors Outside of the U.S. – Transfer of Data
We primarily store data about you, including personal information, on servers located and operated within the United States. If you reside outside of the United States, in order to provide and operate the Site and Services, we may send and store your Personal Data outside of the country where you reside or are located, to the United States. Therefore, our collection and use of your personal information is subject to the United States’ laws related to privacy and use of personal data and information. These laws, including what is determined to be “personal data and/or information,” are different and may be less protective than those applicable to you in your country of residence. By accepting the terms of this Privacy Policy, you acknowledge, agree and consent to (1) the transfer to and processing of personal information on servers located outside of the country where you reside, (2) our collection and use of your personal information as described herein and in accordance with the laws of the United States that may be different and may be less protective than those in your country and (3) that you are taking a risk by using the Site and Services. If your personal information is transferred from the European economic area to AnyRoad located in the United States, please see the Privacy Shield section below.

EU-US Privacy Shield
AnyRoad's commitment to comply with the Privacy Shield Principles
AnyRoad is a participant in the Privacy Shield and has self- certified to the Privacy Shield framework. AnyRoad confirms its commitment to comply with the EU-US Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. AnyRoad has certified that it adheres to each of the Privacy Shield Principles: Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov

Accountability for onward transfers
AnyRoad’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, AnyRoad remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless AnyRoad proves that it is not responsible for the event giving rise to the damage.

Right of access
You have a legal right to request the personal information about you held by us. On request, we will provide you with a copy of this information. You also have a right to correct, amend or delete such personal information where it is inaccurate or has been processed in violation of the Privacy Shield Principles.

Resolution of disputes and complaint mechanism
In compliance with the Privacy Shield Principles, AnyRoad commits to resolve complaints about your privacy and our collection or use of your personal information. If European Union citizens have any queries related to the processing of your personal information under the Privacy Shield framework, we encourage you to contact us directly in the first instance at privacy@anyroad.com or 540 Howard Street, San Francisco, CA 94105.

Independent recourse mechanism
For any complaints that cannot be resolved with AnyRoad directly, we have agreed to cooperate with JAMS. If you are unsatisfied with the resolution of your complaint, you may contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield for further information and assistance. These recourse mechanisms are available at no cost to you.

Binding arbitration
As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.

Enforcement
AnyRoad is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Disclosure of EU personal data to public authorities and law enforcement agencies
AnyRoad may be required to share your personal information in response to lawful by public authorities, including to meet national security and law enforcement requirements.


Information We Collect
When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Services and Offerings
We collect Personal Data (i.e., data that allows someone to identify or contact you, such as your name, address, geographic location of your computer or mobile device, phone number, email address, birthday, and bank account and other Financial Information) from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services, or purchase or otherwise obtain admission to an event, tour, or other offering provided by certain businesses (the “Offering”). We may also require you to provide us with your financial information, including billing name, address, and credit card number (“Financial Information”) in order use certain features of our Services or attend any Offerings. Further, AnyRoad may take and store photos or videos of you taken at the businesses with which you are purchasing or otherwise obtaining admission to an Offering. Wherever AnyRoad collects Personal Data we make an effort to provide a link to this Privacy Policy.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of AnyRoad and the authorized third parties referred to herein located in the United States. If your Personal Data is transferred from the European economic area to AnyRoad located in the United States, please see the Visitors Outside of the U.S. section above.

Aggregated Personal Data
In an ongoing effort to better understand and serve the users of the Services, AnyRoad often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This data and research may be compiled and analyzed on an aggregate basis (“Aggregated Personal Data”), and AnyRoad may share this Aggregated Personal Data with its affiliates, agents and business partners. This Aggregated Personal Data does not identify you personally. AnyRoad may also disclose Aggregated Personal Data in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Non-Identifiable Data
When you interact with AnyRoad through the Services, we receive and store certain personally non-identifiable information (“Non-Identifiable Data”). Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. AnyRoad may store Non-Identifiable Data itself or such information may be included in databases owned and maintained by AnyRoad affiliates, agents or service providers. The Services may use Non-Identifiable Data and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

In operating the Services, we may use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies are persistent cookies and help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use these cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features. Further, our Service may use web beacons on our Site and in our communications to provide additional functionality to the Services and help us analyze usage of the Services more accurately. These web beacons may also track your IP address.

Location Information
Our Service may collect and use your location information (for example, by using the GPS on your mobile device) to provide certain functionality of our Service (“Location Data”). If you choose to enable our location features, your Location Data may be publicly displayed within the Service. Please keep in mind that other users can see this information about you, and they may use it or disclose it to other individuals or entities outside of our control and without your knowledge. Your Location Data may be subject to abuse, misuse, and monitoring by others, so please be careful if you choose to enable location functionality. We may also use your Location Data in an aggregate way, as described above in the “Aggregated Personal Data” section.

Google Analytics
We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Service. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners


Our Use of Your Personal Data and Other Information
AnyRoad and its subsidiaries and affiliates (the “Related Companies”) use the Personal Data and other information you provide in a manner that is consistent with this Privacy Policy for the following general purposes:

to operate and make available the Site and Services
for billing, identification and authentication, and fraud prevention
to analyze Site usage and improve our products and the Site and Services
to contact you and deliver administrative notices, marketing notifications and offers and communications relevant to your use of our products and the Services via email, SMS, push notifications, or otherwise
to provide you with customer support
for internal market research, troubleshooting problems, and detecting and protecting against error, fraud or other criminal activity
to provide guidance to the businesses that are providing the Offerings on how to improve the Offerings
to enforce our Terms and End User Terms
as otherwise set forth in the Privacy Policy

Advertising
AnyRoad and its affiliates may use Personal Data to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

Analytics and Market Research
AnyRoad may analyze Personal Data and web navigational data based on your interests and may use the analysis from this information in a way that doesn’t reveal a Visitor’s Personal Data (“Market Research”) in order to market the Site and Services, improve the Offerings provided to Visitors, improve the likelihood of a group of Visitors attending an Offering, and increase the likelihood that an Offering or a group's experience with the Site and Services is relevant to Visitors.
AnyRoad uses data at the individual level to sell products and services to Visitors who express an interest in these products and services, through a poll for example, or to Users who can be presumed to have an interest based on results from our Market Research.

Mobile Services
AnyRoad may use your cell phone number to call or text you in order to provide you notifications about tasks and reminders about the Offerings, for marketing purposes, and to administer the Site and Services. If you would like more information about our policy, or to opt out, please review below or the “Mobile Services” section of our End Terms of Service, available at https://www.anyroad.com/end_user_terms or email privacy@anyroad.com. You may be liable for standard SMS and per-minute charges by your mobile carrier. For users of AnyRoad’s mobile application, we may also message you via “Push” messaging, which you can opt-out of on your mobile device. Data rates may apply.
You can opt out of receiving certain promotional communications from AnyRoad sent via text message at any time by following the instructions provided in text messages from AnyRoad to text the word, "STOP". Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, AnyRoad may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or AnyRoad’s ongoing business relations.

Financial Information
We use Financial Information solely as authorized by you in accordance with this Privacy Policy in order for you to use the Services. To keep your financial data secure, we do not store full credit card information on our servers. We have contracted with a third party to process your payment card information.

If AnyRoad intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.


Our Disclosure of Your Personal Data and Other Information
AnyRoad is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Services
To operate the Services, we will share your Personal Data, such as name, age, address, and birthday, with the businesses with which you are purchasing or otherwise obtaining admission to an Offering. We may also share other Personal Data with such businesses in order for them to provide their Offerings to you and follow up with you on your experience at an Offering. If you opted-in to marketing communication, we may share your Personal Data with businesses that you’ve attended an Offering with so in order for them to send marketing communications to you. If you choose not to receive further marketing communication, please contact the business from which you no longer wish to receive marketing communication. Further, your Aggregated Personal Data, Non-Identifiable Data, and Location Data with the businesses with which you are choosing and/or attending an Offering in order for them to do research on improving the Offerings. By choosing and attending an Offering with such business partners, your Personal Data is also subject to their respective privacy policies.

Business Transfers
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of AnyRoad (or its assets) will continue to have the right to use your Personal Data and other information in accordance with the terms of this Privacy Policy. Further, AnyRoad may also disclose Aggregated Personal Data in order to describe our services to prospective acquirers or business partners.

Related Companies
We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

Agents, Consultants and Related Third Parties
AnyRoad, like many businesses, sometimes hires other companies to perform certain business-related functions, where we may share Personal Data, Aggregated Personal Data, and Non-Identifiable Data. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements
AnyRoad may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of AnyRoad, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.


Your Choices
You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services. You may also opt out of receiving communications from us, remove your information from our database, and choose not to receive future communications unrelated to the Services (such as those about your account, transactions, servicing, or AnyRoad’s ongoing business relations) by cancelling your account; which you can do by contacting AnyRoad at privacy@anyroad.com. Further, if you register or attend an Offering or otherwise use any Services, we may occasionally contact you with information about special events, sales, activities, promotions, contests, submission opportunities, and programs. You always have the option to ask AnyRoad not to contact you with this information again. If you receive unsolicited email from an AnyRoad domain, please contact us at privacy@anyroad.com


Exclusions
This Privacy Policy does not apply to any Personal Data collected by AnyRoad other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to AnyRoad through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and AnyRoad shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution according to the terms set forth in the “User Content Transmitted Through the Service” section of the End User Terms.


Children
AnyRoad 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 AnyRoad through the Services, please contact us, and we will endeavor to delete that information from our databases.


Links to Other Web Sites
This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by AnyRoad (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that AnyRoad endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.


Integrating Social Networking Services
One of the special features of the Service is that it allows you to enable or log in to the Services via various social networking services like Facebook or Twitter (“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 AnyRoad 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 Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); 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.


Security
AnyRoad takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to AnyRoad via the Internet.


Changes to AnyRoad’s Privacy Policy
The Services and our business may change from time to time. As a result, at times it may be necessary for AnyRoad to make changes to this Privacy Policy. AnyRoad reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. 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.


Retention of Information; Access to Information; Contacting AnyRoad
To preserve the integrity of our databases, we may retain information submitted by Visitors for an indefinite length of time as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. If required by law, we will delete Personal Data by erasing it from our database. We will also respond to Visitors’ requests to delete or correct account or Personal Data, which you can do by contacting AnyRoad at privacy@anyroad.com
To keep your Personal Data accurate, current, and complete, please contact us at privacy@anyroad.com. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services. You have a right to access your personal information. Please contact us at privacy@anyroad.com to find out how to access and change information you cannot access on your own.

Please also feel free to contact us if you have any questions about AnyRoad’s Privacy Policy or the information practices of the Services.

You may contact us as follows: privacy@anyroad.com