State of Florida, Rev. 133C579
Version Date: August 25, 2023
Circuit Transit Inc. and its affiliated companies (collectively, “Circuit” or “Company” or “we” or “us” or “our”) respects the privacy of its users and/or riders (“user”, “you” or “rider”) that use our website located at www.ridecircuit.com, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”) and we are responsible for your information. We are the controller of the information that we collect from you, and as such we control the ways your personal information is collected and the purposes for which your personal information is used.
INFORMATION WE COLLECT
Registration Information. When you sign up for a Circuit account, you give us your name, email address, zip code, date of birth, gender and phone number.
Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our customer support, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information.
Location Information. Circuit is all about connecting riders to our drivers. To do this, we need to know where you are. When you open Circuit on your mobile device, we receive your location. We may also collect the precise location of your device when the app is running in the foreground or background. If you label certain locations, such as “home” and “work,” we receive that information, too. Your location information is necessary for things like matching riders with nearby drivers, determining drop off and pick up locations, and suggesting destinations based on previous trips.
Payment. If you transact business with us, we will receive your financial information such as your payment method (valid credit card number, type, expiration date or other financial information).
Device Information. Circuit receives information from users’ devices, including IP address, web browser type, mobile operating system version, phone carrier and manufacturer, application installations, device identifiers, preferences and settings, mobile advertising identifiers, and push notification tokens.
In-Vehicle Recordings. Circuit vehicles may be equipped with devices that use video camera and/or sensor technology to record events inside and outside the vehicle. If such devices are installed in our vehicles, we may collect video images of drivers and passengers, along with telematics data that includes vehicle location, speed, braking, relative proximity to other vehicles, and collision events that may occur during your ride. Subject to notice or consent requirements in accordance with applicable law, Circuit may also collect audio recordings within the vehicle. Certain devices may employ artificial intelligence to process images of a driver in real-time in order to identify or alert the driver to safety-related events such as indicators of distracted driving or unsafe distances between moving vehicles. To the extent that such images would be considered biometric information under applicable laws, the devices do not store or transfer such information and we do not disclose biometric information to third parties for any commercial purposes. In cases where we collect data from in-vehicle recording devices, Circuit will provide notice to passengers that there is a recording device in the vehicle; such notice may be provided through physical signs on the exterior and/or interior of the vehicle.
Usage Information. To help us understand how you use the Website and to help us improve it, we automatically receive information about your interactions with the Website, including ride information of the date, time, destination, distance, route, payment, the pages or other content you view, your actions within the Website, and the dates and times of your visits.
User Feedback. At Circuit, we want to make sure users are always enjoying great rides. Riders and drivers may rate and review each other at the end of every ride. We receive information about these ratings and reviews. We may also ask for participation in polls, contests, surveys or other features of our service, or response to offers or advertisements.
HOW WE USE THE INFORMATION WE COLLECT
We can only use your information for one or more of these reasons:
To fulfill a contract we have with you;
If we have a legal duty to use your information for a particular reason;
When you consent to it;
When it is in our legitimate interests. Legitimate interests are our business or commercial reasons
for using your information;
In conformance with the requirements of a local, state or federal law enforcement agency.
Within those stated reasons, we use the information we collect from all users to:
Deliver the services that you have requested;
Connect riders with drivers;
Provide, improve, expand, and promote the Website;
Analyze how the users use the Website including measuring user interest;
Evaluate information on your Website visit and how you move around different sections of our
Website for analytics purposes to understand how people use our Website so that we can make it
Company communications with you, either directly or through one of our partners, by email,
telephone and/or mobile devices;
Develop and display content and advertising tailored to your interests on the Website;
Identify information that you have clicked on our Website to target advertising that is relevant
to your interests;
Customize the Circuit experience for you;
Enhance safety and security with the use of in-vehicle recordings;
Assist insurance investigation and/or law enforcement; and
Provide you with customer support including resolving disputes and troubleshooting problems.
Company communications will use your name, telephone and/or email address to send you notifications regarding new services offered by the Website that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such company communications by unsubscribing to email communications or by contacting us, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.
GATHERING THE INFORMATION
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. We may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are a technique we may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and better understand the functionality of our Website and to serve ads based on your past activity on the Website, including Google Analytics and Facebook Pixel for display advertising . The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads). To opt out of Facebook Pixel using the Facebook site, log in and go to Settings > Ads > Ad Settings. On the app, go to Setting & Privacy > Settings > Ad > Ad Preferences > Ad Settings. Then choose the Not Allowed options under each category to stop Facebook from using data from partners and tracking your activity on Facebook and their partner’s sites to target you with ads.
SHARING THE INFORMATION WITH THIRD PARTIES
API and Integration Partners. If you connect to the Website through an integration with a third-party service, we may share information about your use of the Website with that third party. We may share your information with our third-party partners in order to receive additional information about you. We may also share your information with third party partners to create offers that may be of interest to you.
Third Party Services. We may share your information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Website’s functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
Social Media. We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in, such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated and your browser will directly connect to that provider’s servers. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.
Do-Not-Track-Policy. Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have information about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.
In addition, we may share your information with third parties in the following cases:
While negotiating or in relation to a change of corporate control such as a restructuring, merger,
sale of our assets, bankruptcy or other sale of all or a portion of our assets;
If a government authority requests information and we think disclosure is required or appropriate
in order to comply with laws, regulations, or a legal process;
With law enforcement officials, government authorities, or third parties with efforts to investigate,
prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing if we
think doing so is necessary to protect the rights, property, or safety of the Circuit community,
Circuit, or the public;
To comply with a legal requirement or process, including but not limited to, civil and criminal
subpoenas, court orders or other compulsory disclosures.
With our insurance partners to help determine and provide relevant coverage in the event of an
To provide information about the use of the Website to potential business partners in aggregated
or de-identified form that cannot reasonably be used to identify you; and
Whenever you consent to the sharing.
HOW LONG WE KEEP YOUR INFORMATION
We keep your information only for as long as we need it. How long we need that information depends on what we are using it for, whether that is to provide services to you, for our own legitimate interests or so that we can comply with the law. We will actively review the information we hold and when there is no longer a customer, legal or business need for us to retain the information, we will either delete it securely or in some cases anonymize it.
SECURITY OF YOUR INFORMATION
We take the security of your information seriously and use technical measures such as encryption and password protection to protect your information from loss, theft, alteration, misuse or destruction. We also use operational measures to protect the information, for example by limiting the number of people who have access to the databases in which the information is held. We keep these security measures under review and refer to industry security standards to keep up to date with current best practice. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures. If there is breach to the security of your information, you will be notified of such breach within 72 hours.
We are dedicated to protect all information on the Website as is necessary. However, you are responsible for maintaining the confidentiality of your information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.
If you gave us your consent to use your information, e.g. so that we can send you marketing emails, you can withdraw your consent. You can withdraw your consent through your account settings, unsubscribing from our commercial or promotional communications or contacting us using the contact information below. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your information before you withdrew your consent.
While you can prevent your device from sharing location information at any time through your mobile device’s operating system settings, user and driver location is core to the Website and without it we cannot provide our services to you.
You can object to our use of your information where we rely on our legitimate interests to do so.
To raise any objections or to exercise any of your rights, you can contact us using the contact information below.
When you get in touch, we will come back to you as soon as possible and where possible within one month. Please note that if your request is more complicated, it may take a little longer to come back to you and the response deadline can be extended by two months of your request where necessary. There is no charge for most requests, but if you ask us to provide a significant amount of information for example, we may ask you to pay a reasonable administration fee. We will also ask you to verify your identity before we provide any information to you.
The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. Our services are not directed to children and we do not knowingly collect or maintain information from anyone under the age of 13, unless or except as permitted by law. Any person who provides information through the Website represents to us that he or she is 13 years of age or older. If we learn that information has been collected from a user under 13 years of age on or through the Website, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Website or has otherwise transferred information to the Website, please contact Company using our contact information below to have that child's account terminated and information deleted.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below. If you are a California resident, you have the right to request that we delete the information we have collected from you, with a number of exceptions including but not limited to, when the information is necessary for us to complete the transaction, provide you a service, protect your security and prosecute those responsible for breaching it, fix our system in the case of a bug, comply with a legal obligation or make other lawful uses of the information.
Circuit Transit Inc.
501 East Las Olas
Fort Lauderdale, FL 33301