What We Collect
In order to deliver our core features and functionality, this App collects identification, location and driving information from or about users and their devices, as follows:
- Personally identifiable information or “personal information” is data that can be used to identify or contact a single natural person.
When you initially log in with Facebook, the App pings Facebook and TrueMotion receives:
- your Email address,
- First and Last Name,
- user-provided location (e.g. Boston, MA),
- profile picture and
- your list of Friends.
NOTE: Any Friend of yours on Facebook can “Follow” you in the App and see you on their leaderboard. Your overall Mojo score and level will be visible, even if you unfriend them in Facebook.
These types of identifiable data are stored separately from the Location and Activity Data we collect via our sensors. We will retain your personally identifiable information for the period necessary to fulfill the purposes outlined in this Policy unless otherwise required or permitted by law.
By signing up for and using our App, you agree that we may collect and use technical data and related information, including but not limited to, technical information about any device running the App, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to our App. If we do pair or associate your Location or Activity Data with Personal Information you provide, we will treat the combined information as Personal Information.
- Location Data is information about the precise geographic location of the smartphone or other device you register with our App. In order to assess whether a registered user is driving, Location Data is always detected, including when you are in motion, whether you are a passenger or a driver.
The App requires access to location data to reach a determination about when you are operating a motor vehicle, to map your trips, and to track driving behaviors. The App will continuously detect and analyze data about location in the background. Where the App determines that you are the driver, TrueMotion stores trip locations and history, along with the Activity Data about driving behaviors such as Swiping & Typing, Handheld Calls, and Handsfree Calls, as well as frequent starting and/or ending points for a trip to enhance the performance of the trip capture.
Through sophisticated algorithms and other methods, we endeavor to correctly detect if the user is a driver or passenger of a motor vehicle during a journey; however, we also allow a user to see trip summaries and report problems with predictions they deem are not correct. Users can see a summarized list of trips together with start time, start and end city, total minutes of distraction free driving, and a breakdown of distracted time into Swiping & Typing, Handheld Calls, and Handsfree Calls.
- Activity Data, such as motion or fitness data. The App uses sensors to collect motion or fitness data, in order to —
- detect when you start driving a motor vehicle (as opposed to walking, running, or riding as a passenger in a motor vehicle or public transportation),
- assess distracted driving as evaluated by three factors: Swiping & Typing, Handheld Calls, and Handsfree Calls.
An internal ID is stored with both the activity data collected and the personal profile data of a registered user that allows True Motion, if needed, to connect personal profile to activity data. IMPORTANT: We use the motion sensor in the phone’s operating system and technical means to ascertain when a registered device is in use by the operator of the motor vehicle (as opposed to other types of journeys). We retain records about trips where the device was in motion but our analysis did not classify the journey as a trip where the registered user was operating a motor vehicle, so that users can access and view their trips. See the FAQs for more information.
- Passively Collected Data, such as IP address or Device ID. As is true of most applications, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, or device ID. We use this information that we collect, which does not identify individual users by name or contact information, to analyze trends, to administer the App, to track users’ movements with respect to the App. If we do pair or associate this data with Personal Information you provide, we will treat the combined information as Personal Information.
Use of Information Collected through the App
The App uses the information collected from or about you or your device to deliver the features and functionality of the Mojo App, and to improve our services to you by improving the App’s performance.
We store the account information we receive from Facebook when you create a Mojo account. This will include your email address, which may be used to contact you related to the features and functionality of the App, including rewards earned or won.
Information received from Facebook or collected through the App is not shared with unaffiliated third parties for marketing or their own use.
We also use the information we collect to help us create, develop, operate, deliver, and improve our products, services, content, and for anti-fraud purposes.
From time to time, we may use your personal information to send important notices, such as communications about changes to features and functionality, or terms, conditions, and policies. Because this information is important to your interaction with TrueMotion, you may not opt out of receiving these transactional messages while you continue to utilize the App. We may also use the information we collect for internal purposes such as auditing, data analysis, and research to improve TrueMotion’s products, services, and customer communications.
Disclosures to Third Parties
Anyone else who has access to the apps or data stored on your phone will have access to your registration details, distraction-free driving score or levels, and past trip information. You are responsible for keeping these details private and carefully screening the persons with whom you share access to your device.
Any Facebook friend (even if later unfriended) can see your: overall distracted-driving score and your level (determined by your accumulated minutes of distraction-free driving, all the time).
The App integrates third party analytics, in order to facilitate and improve the functioning of the App, including by performing statistical analysis of performance or of information collected from registered devices, such as analysis on sensor data and phone status (screen lock or unlock, wifi status, background app refresh). If you spin and win, we will share your email address with our service provider, who distributes prizes on our behalf. We also may share anonymous, aggregated statistics about your use of our websites and services with other companies.
TrueMotion will disclose information collected from or about you or your device, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with valid legal process served on TrueMotion; (b) protect and defend the rights or property of TrueMotion; and, (c) act under exigent circumstances to protect the personal safety of users of TrueMotion or the public. TrueMotion may also disclose information collected from or about you if TrueMotion determines that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose information collected through the App, subject to applicable contractual or legal restrictions, where we deem it necessary in connection with a sale of all or substantially all of the assets of TrueMotion or the merger of TrueMotion into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which TrueMotion is not the surviving entity.
We may also disclose information as necessary in connection with delivering features and functions of the App (including, for example, detecting public transportation trips by sending information to Google Maps), customer care, service quality, business management and operation, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends and dispute resolution.
Security of Information Collected through the App
TrueMotion protects your information using technical, physical, and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information. Some of our safeguards include firewalls, data encryption, physical access controls, and administrative informational controls. While we have employed security technologies and procedures to assist safeguarding the information we collect from or about our users and their devices, no system or network can be guaranteed to be completely secure.
Your Access to App Information
Please ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account, and advising us of changes.
We provide App users the opportunity to review trip history and other activity.
We will consider reasonable requests to access, modify or correct account data, which can be directed to email@example.com. However, we may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.
Communications With TrueMotion
We appreciate your questions and comments about the App and TrueMotion and welcome your messages to recipients listed on the App including messages or emails provided to our customer support. We will share your communications with those within our organization who are most capable of addressing the issues contained in your message. We may archive your message for a certain period of time or discard it, but your e-mail address and e-mail will only be used in accordance with this Policy.
Using the App From Outside the United States
If you are using the App from outside of the United States, please be aware that your information, including any data constituting “personal data” under the laws of the European Union, for example, to which we may be given access, may be transferred to, stored, or processed in the United States. The data protection and other laws of the United States and other countries may not be as comprehensive as those in your country. By using the App, you understand that your personal data information may be transferred to our facilities and to those third parties with whom we share such information as specified in this Policy.
No Information Collected from Children
As an App measuring and reporting the activities and behaviors of operators of motor vehicles, we do not knowingly collect, use or disclose any personal, location, or activity information from children under 13, or equivalent minimum age in the relevant jurisdiction. If you are a parent or guardian and believe we may have collected information about a child, please contact us as described in the “Privacy Questions” section, below.
Changes to this Policy
We may change this Policy at any time and from time to time. The most recent version of the Policy is reflected by the version date located at the bottom of this Policy. If we make any material changes to our Policy, those changes will apply to the personally identifiable information collected after the effective date listed on the Policy, and we will notify you by placing a notice on the App’s download page prior to the change becoming effective. We encourage all users to periodically review this Policy for the latest information on our privacy practices.
TrueMotion, Inc. 470 Atlantic Avenue, Suite 1400, Boston, Massachusetts, USA, 02210.
This Policy was last updated on March 15, 2017.
Copyright 2017 TrueMotion, Inc. All rights reserved.