Privacy Policy

I. Introduction

When you use flexup DIRECT, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices. This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data.

If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any other CCPA specific information mentioned in this Policy.

II. Overview

A. Scope

This notice describes how flexup DIRECT and its affiliates collect and use personal data. This notice applies to all users of our websites, features, or other services anywhere in the world, unless covered by a separate privacy notice.

This notice also governs flexup DIRECT’s other collections of personal data in connection with flexup DIRECT's services. For example, we may collect the contact information of individuals who use accounts owned by flexup DIRECT for Business customers or of owners or employees of flexup DIRECT partners. We may also collect the personal data of those who start but do not complete applications through a flexup DIRECT's website or app, or in connection with our other features.

All those subject to this notice are referred to as "users" in this notice.

Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

B. The data we collect

flexup DIRECT collects:

• Data provided by users to flexup DIRECT, such as during account creation and job application.
• Data created during use of our services, such as location, website usage, and device data.      
  
• Data from other sources, such as flexup DIRECT partners and third parties that use flexup DIRECT APIs.

The following data is collected by or on behalf of flexup DIRECT:

1- Data provided by users. This includes:

• User Profile: We collect data when users create or update their flexup DIRECT accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes emergency contact information, user settings, and evidence of health or fitness to provide services using flexup DIRECT website. This also includes gender and/or occupation.
• We may use the photos submitted by users to verify their identities, such as through facial recognition technologies.
• Background check and identity verification: We collect background check and identity verification information for candidates. This may include information such criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on flexup DIRECT’s behalf.
• Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.
• User content: We collect the information users submit when they contact flexup DIRECT customer support, provide ratings or compliments for other users, or otherwise contact flexup DIRECT. This may include feedback, photographs or other recordings collected by users.

• Location data: We collect precise or approximate location data from users’ laptop, mobile and tablet devices if they enable us to do so. flexup DIRECT collects this data any time the website is running in the foreground of their device. We use this data to enhance your use of our website to enable safety features, and prevent and detect fraud.
• Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, website features or pages viewed, website crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
• Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers and advertising identifiers.

• User feedback, such as ratings, feedback, or compliments.
• Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.
• Google Analytics and other third-party analytics tools help us understand how you use the site and ways that we can improve your experience.
• Users or others providing information in connection with claims or disputes.
• flexup DIRECT business partners through which users create or access their flexup DIRECT account, such as payment providers, social media services, or apps or websites that use flexup DIRECT’s APIs or whose APIs flexup DIRECT uses.
• Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
• Publicly available sources.
• Marketing service providers.

C. How we use personal data

• To enhance the safety and security of our users and services
• For customer support
• For research and development
• To enable communication between users
• To send marketing and non-marketing communication to users
• In connection with legal proceedings

• Create and update users' accounts.
• Verify candidate identity, background history, and eligibility to work.
• Offer, process, or facilitate payments for our services.
• Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

• In certain regions, using information derived from driver’s license photos, and other photos submitted to flexup DIRECT, for safety and security purposes.
• Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
• Using user ratings and feedback to encourage compliance with our guidelines and as grounds for deactivating persons with low ratings or who otherwise violated such guidelines in certain countries.

• Direct questions to the appropriate customer support person
• Investigate and address user concerns
• Monitor and improve our customer support responses and processes

• Matching users to jobs, based on availability, preference, and other factors.
• Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm flexup DIRECT, its users, and others. In some cases, such as when a user is determined to be abusing flexup DIRECT’s referral program, such behavior may result in automatic deactivation.
  

D. Cookies and third-party technologies

• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

• Firefox:https://support.mozilla.org/en-US/kb/Cookies
• Google Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
• Safari:https://support.apple.com/kb/PH5042
• Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/view-cookies-in-microsoft-edge-a7d95376-f2cd-8e4a-25dc-1de753474879
• Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• Safari iOS (iPhone, iPad):https://support.apple.com/kb/HT1677

E. Data sharing and disclosure

flexup DIRECT may share the data we collect:

1- With other users:
This includes sharing:
- Users’ first name with other users     
- For those who participate in flexup DIRECT’s referral program, we share certain personal data of referred users, with the user who referred them, to the extent relevant to determining the referral bonus.
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2- At the user’s request:
‍This includes sharing data with flexup DIRECT business partners: For example, if a user requests a service through a partnership or promotional offering made by a third party, flexup DIRECT may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurant partners or other flexup DIRECT business partners and their users in connection with promotions, contests, or specialized services.

3- With the general public
Questions or comments from users submitted through public forums such as flexup DIRECT blogs and flexup DIRECT social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

4- With flexup DIRECT subsidiaries and affiliates
We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, flexup DIRECT processes and stores data in the United States on behalf of its subsidiaries and affiliates.
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5- With flexup DIRECT service providers and business partners
flexup DIRECT provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:·     
- Payment processors and facilitators·     
- Background check and identity verification providers·     
- Cloud storage providers·     
- Google, in connection with the use of Google Maps in flexup DIRECT’s apps (see Google’s privacy policy for information on their collection and use of data)·     
- Facebook, in connection with the use of the Facebook Business Tools in flexup DIRECT’s websites (see Facebook’s privacy policy for information on their collection and use of data)·     
- Marketing partners and marketing platform providers, including social media advertising services·     
- Data analytics providers·     
- Research partners, including those performing surveys or research projects in partnership with flexup DIRECT or on flexup DIRECT’s behalf·     
- Vendors that assist flexup DIRECT to enhance the safety and security of its websites·     
- Consultants, lawyers, accountants, and other professional service providers·     
- Insurance and financing partners

6- For legal reasons or in the event of a dispute
flexup DIRECT may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect flexup DIRECT’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.

This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

7- With consent
flexup DIRECT may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.
If there are any questions regarding this privacy policy, you may send an email to info@flexupdirect.comSome of flexup DIRECT’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

F. Data retention and deletion

flexup DIRECT retains user data for as long as necessary for the purposes described above.

Users may request deletion of their accounts at any time. flexup DIRECT may retain user data after a deletion request due to legal or regulatory requirements or for the reasons stated int his policy.

‍flexup DIRECT retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the category of user to whom the data relates, the type of data, and the purposes for which we collected the data.

Following an account deletion request, flexup DIRECT deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements, this generally means that we retain their account and data for a minimum of 7 years after a deletion request.

G. Grounds for processing

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of flexup DIRECT’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

‍We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

A- To provide requested services and features
In order to provide our services, we must collect and use certain personal data. This includes:

• User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users, and accounts; and enable users to make payments
• Usage data, which is necessary to maintain, optimize, and enhance flexup DIRECT’s services, including to determine incentives,
• Transaction information
• Information relating to customer support

B- For purposes of the legitimate interests of flexup DIRECT or other parties
‍This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of flexup DIRECT’s websites.

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing flexup DIRECT’s Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

C- To fulfill flexup DIRECT’s legal obligations
For example, flexup DIRECT is subject to laws and regulations in many cities and countries that require it to collect and retain data about our users’ trips and deliveries, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

flexup DIRECT may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. flexup DIRECT may also share information with public health authorities where required or permitted bylaw.

D- With consent
flexup DIRECT may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

III. CCPA

This section tells you about the rights and choices you have with respect to your Personal Information under California law.

• Right to Know: You have the right to know what personal information is being collected, used, disclosed and sold over the last 12 months, including the categories, sources, and business purposes for collecting your personal information. To exercise this right, a California consumer must submit a verifiable request to flexup DIRECT to know such information.
• Right to Delete: You have the right to request the deletion of your Personal Information collected or maintained by flexup DIRECT, if we do not have a legal or business reason to keep it.
• Right to Modify / Correct: You may have the right to correct inaccurate personal information we have about you.
• Right to Opt Out of Sale or Sharing: You may have the right to ask us not to share or sell your personal information or use it for purposes of targeted advertising or profiling.
• Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights: You have the right to not be discriminated against if you exercise any of the consumer’s rights under the CCPA. That means that a company may not deny goods or services to the consumer, charge different rates for goods or services, or provide a different level or quality of goods or services if the consumer chooses to exercise their rights under the CCPA (unless the different level or quality is reasonably related to the the consumer’s data).
• Right to Limit Processing of Sensitive Personal Information: You may have the right to ask us to limit our use of your sensitive personal information, including your Social Security number, state ID card, driver’s license number, passport number, to accomplish the purpose included in this privacy policy.

These rights may be subject to certain limitations or exceptions under California Law and the purpose for which we process personal information about you.  

Submitting a CCPA Data Request

• How to Make a Request: If you would like to make a request, please email us your first and last name, phone number, request details, relationship with us (employee / vendor) and the type of request to info@flexupdirectcom.
• We will make good faith efforts to make requested changes in our then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information. Further, we reserve the right to retain data (a) as required by applicable law; and (b) as long as we need it or as long as the law allows or requires.
• Your request will be evaluated to determine whether the requested change meets legal regulatory requirements.  If we aren’t able to honor any part of your request, we will tell you that in our response, as well as the reason(s) we cannot do so.

Requests by Authorized Agents: 
You may designate an authorized agent to exercise a CCPA right on your behalf. The authorized agent needs to provide the following proof to ensure that the agent has been authorized to act on the consumer’s behalf:
- Proof of written permission by you for the authorized agent to act on your behalf and verification of yours and agent’s identity·     
- Proof that the authorized agent holds a power of attorney to act on your behalf

IV. Choice and Transparency

flexup DIRECT enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that flexup DIRECT restrict its processing of user personal data.

‍A- Marketing opt-outs
Users may opt out of receiving promotional emails from flexup DIRECT, Users may also opt out of receiving emails and other messages from flexup DIRECT by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for rides or information about their account.

B- User data requests
flexup DIRECT provides users with a variety of ways to learn about, control, and submit questions and comments about flexup DIRECT’s handling of their data.

• Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.
• Receiving data: Users can ask for a copy of data that flexup DIRECT collects from them with their consent or as necessary to provide our services.
• Deleting data: Users may request deletion of their account at any time by sending email to info@flexupdirect.com
• Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. flexup DIRECT may continue to process data after such objection or request to the extent required or permitted by law.