PRIVACY POLICY

Effective Date: October 27, 2013.

This Privacy Policy (“Privacy Policy“) explains how DefensiveDrivingApp.com (“DefensiveDrivingApp”, “us”, “our”, and “we”), collects and uses information when you interact with us. This Privacy Policy applies to all users of DefensiveDrivingApp’s website published at www.DefensiveDrivingApp.com (and any other websites with “DefensiveDrivingApp” branding that link to this Privacy Policy, including, without limitation, the DefensiveDrivingApp on Facebook application) and any mobile-device applications we offer, such our iOS and Android applications, that are branded “DefensiveDrivingApp” and link or reference this Privacy Policy (collectively, the “Services“).

Please read this Privacy Policy carefully. This Privacy Policy replaces and supersedes the last version of this Privacy Policy for all users (including for those users that registered prior to the Effective Date). If you do not agree to our practices, please do not register, subscribe, create an account, or otherwise interact with the Services.

Please Contact us if you have any questions or comments about our privacy practices or this Privacy Policy.

Our Privacy Policy is organized as follows:

  1. Types of Personal Information We Collect
  2. How DefensiveDrivingApp Collects Personal Information
  3. How DefensiveDrivingApp Uses Personal Information
  4. When and Why DefensiveDrivingApp Discloses Personal Information
  5. Cookies and Related Technologies
  6. Your Choices
  7. Accessing and Correcting Personal Information
  8. Security of Personal Information
  9. Notice to Residents of Countries outside the United States of America
  10. Privacy Practices of Third Parties
  11. Communities
  12. Changes to this Privacy Policy
  13. Children’s Privacy

1. Types of Personal Information We Collect

Personal Information is information that can be used to identify, locate, or contact an individual. It also includes other information that may be associated with Personal Information. We collect the following types of Personal Information:

  • Contact Information that allows us to communicate with you, such as your name, postal addresses, email addresses, social media website user account names, telephone numbers, or other addresses at which you receive communications from or on behalf of DefensiveDrivingApp.
  • Relationship Information that helps us to understand who you are and what types of Traffic Schools or Traffic School Courses you might be interested in. This includes lifestyle, preference, and interest information; location information related to your state/province, city, or neighborhood; the types of Traffic Schools Courses that interest you; information collected from social media interactions (such as via Facebook Connect); and demographic information (e.g., birth date, age, gender).
  • Transaction Information about how you interact with the Services, such as the Traffic Schools, Traffic School Courses or coupon codes you view and redeem; other information about how you use our Services, email, other communications, and applications; and how you interact with DefensiveDrivingApp’s merchants, business partners, and service providers.

2. How DefensiveDrivingApp Collects Personal Information

We may ask you for Personal Information when you register, subscribe, create an account, or otherwise interact with the Services or contact DefensiveDrivingApp. For example, you may be required to provide us with Contact Information or Relationship Information in order to register for certain services.

We collect Transaction Information when you use our Services. For example, we may track the coupons you redeem, traffic schools you look at, traffic school courses you clicked on and the comments you make to the forums, bulletin boards, discussion groups or other methods of communication that may be offered on or through the Services from time to time (collectively, “Communities“), or to those related to our social media pages or accounts. We use cookies and related technologies to collect information about your computer and your interaction with the Services and our business partner websites. You can read more about cookies and other technologies in the Cookies and Related Technologies section.

We also collect Transaction Information if you contact us via telephone, email, text, postal mail, social media interaction, or other methods of communication, such as for customer support purposes.

If you use a social media platform, a mobile device or other third-party method of communication to interact with DefensiveDrivingApp or the Services, that platform may have a specific privacy statement that governs the use of Personal Information related to that platform. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

If you use the Services on a mobile device and your mobile device’s settings allow it, we may collect Personal Information from your mobile device. Our application may be designed to collect information even if you are not logged into one of the Services. Please see the Your Choices section under the heading “mobile” for more information on the types of Personal Information that DefensiveDrivingApp may collect from the Services operating on a mobile device.

From time to time, we may obtain additional Personal Information from third parties. For example, we may collect Personal Information from third parties to enhance other information we have about you, to help us better understand you, and to otherwise enhance the Services.

3. How DefensiveDrivingApp Uses Personal Information

DefensiveDrivingApp uses Personal Information to:

  • Operate and improve our Services;
  • Evaluate eligibility of users for certain Traffic School courses, products or services;
  • Provide Traffic School course offers;
  • Evaluate the types of Traffic School courses, products or services that may be of interest to users;
  • Track redemption of coupons, clicks to recommended Traffic Schools and perform other analytics;
  • Provide user support, including to our merchants or business partners;
  • Fulfill requests for DefensiveDrivingApp services;
  • Communicate and provide additional information that may be of interest to you about DefensiveDrivingApp and our merchants and business partners, such as DefensiveDrivingApp news, special offers and coupons, announcements, and marketing materials;
  • Send you reminders, technical notices, updates, security alerts and support and administrative messages service bulletins, or marketing;
  • Provide advertisements to you through the Services, third-party sites, email messages, text messages, applications, or other methods of communication;
  • Administer surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our partners;
  • Create user profiles that may contain inferences about users such as age range, income range, gender, and interests;
  • Manage our everyday business needs such as website administration, forum management, analytics, fraud prevention, Terms of Use or to comply with the law;
  • Allow you to apply for a job, post a video or sign up for special offers from third parties through the Services; and
  • Carry out other purposes that are disclosed to you and to which you consent.

4. When and Why DefensiveDrivingApp Discloses Personal Information

We may share your Personal Information as required or permitted by law as described below:

  • With affiliated companies (e.g., subsidiaries and other companies owned by or controlled by DefensiveDrivingApp) who may only use the Personal Information for the purposes described in Section 3 above;
  • With our service providers that provide services for us to assist us in carrying out the purposes described in Section 3 above such as sending emails on our behalf and processing payments. Qualcomm Labs, Inc., for example, is a service provider that enables certain geo-location features of our mobile-device applications. Consequently, Qualcomm Labs, Inc. and its affiliates collect, store, and process, on DefensiveDrivingApp’s behalf, certain Location Information and related data on servers in the United States. Our service providers are bound by law or contract to protect Personal Information and are only allowed to use the Personal Information in accordance with the terms of our service agreements with them;
  • Merchants, but only to the extent you have redeemed a coupon offered by the merchant, or participated in an offer, contest or other activity sponsored or offered through DefensiveDrivingApp on behalf of the merchant;
  • DefensiveDrivingApp business partners or advertisers, as part of an offer, contest, or other activity that is provided by or in conjunction with DefensiveDrivingApp and its business partners and in which you have elected to participate. For example, if you are referred to DefensiveDrivingApp from a business partner’s website or through an invitation facilitated by or in conjunction with a DefensiveDrivingApp business partner, DefensiveDrivingApp may provide that business partner with Contact Information and Transactional Information to validate the referral and to support the terms of the relationship between DefensiveDrivingApp and the business partner, which may allow such business partner to contact you directly and to advertise to you;
  • To effect a merger, acquisition, or otherwise; to support the sale or transfer of business assets; to enforce our rights or protect our property; to protect the rights, property or safety of others, investigate fraud, respond to a government request; or as needed to support auditing, compliance, and corporate governance functions. We may also disclose Personal Information to defend ourselves in litigation or a regulatory action, and when required or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate. If DefensiveDrivingApp is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on one or more of our Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information; or
  • Otherwise with your consent.

We encourage DefensiveDrivingApp merchants and business partners to adopt and post privacy policies. However, the use of your Personal Information by such parties is governed by the privacy policies of such parties and is not subject to our control. When you choose to interact with a DefensiveDrivingApp merchant or business partner, we encourage you to read any privacy policy they may have posted on their website.

We may also disclose information about you that is not personally identifiable. For example, we may provide our merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our users.

When you use our Services, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. As you use our Services, your browser and devices communicate with servers operated by us, our business partners and services providers to coordinate and record the interactivity and fill your requests for services and information.

The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or mobile devices, which are then transmitted back to our Services by your computers or mobile devices. These servers are operated and the cookies managed by us, our business partners or our service providers.

For example, when you access our Services, DefensiveDrivingApp and our service providers may place cookies on your computers or mobile devices. These cookies may include means for tracking your Transaction Information with a Merchant and may include tracking technology from third-party affiliate-network operators. Cookies allow us to recognize you when you return, and track and target your interests in order to provide a customized experience. They also help us provide a customized experience and help us to detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Services. Some cookies contain serial numbers that allow us to connect your activity with the Services with other information we store about you in your profile or as related to your other interactions with the Services.

Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases Session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use Persistent cookies for a number of purposes, such as retrieving certain information you have previously provided (such as your user id if you asked to be remembered), and storing your preferences.

Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve our web pages and promotions.

We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our Services, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol (“IP”) addresses of the devices you use to interact with the Services. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to our Services and the website you visit after you leave our Services, if this information is supplied to us by your browser.

In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about users to optimize our Services and understand its traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. In that case, this Privacy Policy governs how we use that information.

Additionally, if you have visited one of our mobile websites or activated one of our mobile-device applications, and if the settings on your location-aware device allow us to receive Location Information, we will collect that automatically. If we associate Location Information with other Personal Information, this Privacy Policy governs how we would use that information too.

DefensiveDrivingApp has relationships with third party advertising companies to place advertisements on our behalf onto other websites, and to perform tracking and reporting functions for our Services and our advertisements. We do not share Personal Information with third party advertising companies; however, these third parties may automatically collect information about your visit to our Services and other websites, your IP address, your ISP and the browser you use to visit our Services. They do this by using cookies, clear gifs and other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Services and the other websites tracked by these third parties. This Privacy Policy does not cover the collection methods or use of the information collected by these third parties, and DefensiveDrivingApp is not responsible for cookies or clear gifs in third party ads. We encourage you to review the privacy policies or statements of these third party advertising companies to learn more about their use of cookies and other technologies. If you would like more information about this practice and to know your choices about not having this information used by third party advertisers, please visit http://www.networkadvertising.org.

We also use third party services, such as Google Analytics, to help us understand how visitors interact with our website and to help improve our user experience.

6. Your Choices

We think that you benefit from a more personalized experience when we know more about you and the kinds of Traffic Schools or Traffic School Courses you like. However, you can limit the information you provide to DefensiveDrivingApp, and you can limit the communications that DefensiveDrivingApp sends to you.

Email
You can manage your subscriptions by following subscription management instructions contained in the commercial messages that we send you. You may choose to subscribe to some types of messages, and may choose to unsubscribe from others. You may also update your subscription preferences from time to time. If you wish to opt out of receiving offers directly from DefensiveDrivingApp merchants or business partners, you can follow the opt-out instructions in the emails that they send you.

Cookies
You may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. Please note that if you disable cookies, you may be unable to access some customized features of our Services. You can opt-out of being targeted by certain third party advertising companies online at www.networkadvertising.org/consumer/opt_out.asp.

Mobile
If you access any of our Services through a mobile device or mobile browser, you may manage how your Personal Information is shared with DefensiveDrivingApp. The Personal Information collected by our Services via a mobile device may include the following: (i) periodic collection of your location and time of day; (ii) the names of the other applications on your mobile device and, if you use an Android-based mobile device, how you use them (e.g., frequency and duration of use); (iii) if you use an Android-based mobile device, the URL addresses of the webpages you access; (iv) information about your mobile device (e.g., make, model, operating system, and other similar information, but not phone number); and (v) information about your use of features, functions, or clicks on notifications or content. In addition to the other uses of your Personal Information described in this Privacy Policy, DefensiveDrivingApp may use and process Personal Information we collect via a mobile device to: (a) send notifications when you arrive at or leave places; and (b) infer the location of the places you visit most often, determine your frequency at these locations, and send notifications when you arrive at or leave those places.

You may adjust the settings on your mobile device to prevent the sharing of Location Information. You may also manage how your mobile device or mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your mobile device and mobile browser settings. Please note that if you disable the sharing of Location Information, you may be unable to access some features of our Services that are designed for mobile devices.

Connecting through Social Networks
You may manage the sharing of certain Personal Information when you register with us through a social media platform or application, such as through Facebook Connect. Please refer to the privacy settings of the social media platform or application to determine how you may adjust our permissions and manage the interactivity between DefensiveDrivingApp and your social media account. By registering with DefensiveDrivingApp through a social media platform, you grant DefensiveDrivingApp permission to access all of the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Privacy Policy.

7. Accessing and Correcting Personal Information

Keeping Personal Information about you current helps ensure that we offer you the best information available about Traffic Schools and their courses. You can manage your information by following subscription management instructions contained in the email messages that we send you.

If you want to close your account or have other questions or requests, or if you would like to access or request a correction to any other personal information we hold regarding you, please Contact Us.

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at support@DefensiveDrivingApp.com. In response, we will cancel or remove your information but may retain and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Security of Personal Information

DefensiveDrivingApp follows generally accepted industry standards to protect the Personal Information that you provide. For example, we regularly monitor our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. No method of transmission over the Internet, or method of electronic storage, is one hundred percent secure, however. For this reason, there is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you have any questions about our security practices, please Contact Us.

9. Notice to Residents of Countries outside the United States of America

DefensiveDrivingApp is headquartered in the United States of America. Personal Information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, merchants, or service providers elsewhere in the world. By providing us with Personal Information, you consent to such access and transfers. You also acknowledge and agree that Personal Information may be subject to access requests from governments, courts, law enforcement officials, and national security authorities in the United States in accordance with United States laws. We will protect the privacy and security of Personal Information according to our Privacy Policy, regardless of where it is processed or stored.

Safe Harbor
DefensiveDrivingApp complies with the US-EU Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. DefensiveDrivingApp has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit http://www.export.gov/safeharbor/

In compliance with the US-EU Safe Harbor Principles, DefensiveDrivingApp commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact us at support@DefensiveDrivingApp.com.

DefensiveDrivingApp has further committed to refer unresolved privacy complaints under the US-EU Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

10. Privacy Practices of Third Parties

This Privacy Policy only addresses the use and disclosure of information by DefensiveDrivingApp through your interaction with the Services. Other websites that may be accessible through links from our Services may have their own privacy statements and personal information collection, use, and disclosure practices. Our merchants and business partners may have their own privacy statements, too. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking Traffic School course or using an offer or promotion.

11. Communities

Our Services may contain Communities and other areas where you may be able to publicly post information, communicate with others (such as via discussion boards or blogs), review products and merchants, and submit media content. Prior to posting in these areas, please read our Terms of Use carefully. All the information you post will be accessible to anyone with Internet access, and any Personal Information you include in your posting may be read, collected, and used by others in a manner we cannot control. For example, if you post your email address along with a comment explaining how to take a traffic course, you may receive unsolicited messages from other parties. We are not able to control the use by third parties of Personal Information you post to public areas of the Services. Please avoid publicly posting Personal Information. If you have questions about Personal Information that you have publicly posted in our Communities, please contact support@DefensiveDrivingApp.com.

12. Changes to this Privacy Policy

From time to time, we may update this Privacy Policy to clarify our practices or to reflect new or different privacy practices, such as when we add new features to our Services. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of notice on the Services prior to the change becoming effective. Your continued access or use of the Services after any such changes become effective constitutes your acceptance of the Privacy Policy as revised. We encourage you to periodically review this page for the latest information about our privacy practices.

13. Children’s Privacy

DefensiveDrivingApp does not intend that any portion of the Services will be accessed or used by children under the age of eighteen, and such use is prohibited. The Services are designed and intended for adults. By using the Services, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old in order to create an account and purchase the goods or services advertised through the Services. We will promptly delete information associated with any account for which we obtain actual knowledge that the registered user associated with the account is not at least eighteen years old.