Last Revised on August 30, 2021

 

This Privacy Policy for OffWeGo, Inc. (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Company’s applications, services, tools and features (collectively, the “Services”).  For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.

 

PLEASE READ THIS PRIVACY POLICY CAREFULLY.  BY USING, ACCESSING, OR DOWNLOADING ANY OF THE SERVICES, YOU AGREE TO THE USE OF YOUR INFORMATION IT DESCRIBES AND TO THE OTHER TERMS OF THIS PRIVACY POLICY.  IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE THE SERVICES.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make changes that are material[LW2] , we will use reasonable efforts to attempt to provide notice to you and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on the Services, or by other means, consistent with applicable law. However, it is your sole responsibility to review the Privacy Policy from time to time to view any such changes.  The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy.  If you do not agree to this Privacy Policy, including any changes, then PLEASE DO not access or CONTINUE TO use the Services.

2.COMPANY’S COLLECTION AND USE OF INFORMATION

In order to provide you with particular services, we may ask you to provide us with certain details or information about you. Information that you submit through our Services include:

 

  • Basic contact details, including name, address, phone number, email. We collect basic contact details to communicate with you and provide you with Services.

  • Account information, including username, password, security questions, travel preferences, travel destination. We collect account information to maintain and secure your account with us and provide you with the Services. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.

  • Profile information, including your social media accounts, your travel preferences, locations you visit while travelling, your current location and other travel related information to provide you the Services, customize your experience with the Services, allow you to connect with other users of the Services and provide you with customized offers and advertising.

  • Any other information you choose to include in communications with us, for example, when responding to a survey, sending a message through the Contact Us web form or when you post content on the services.

Some features of the Services may require you to enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

We also automatically collect certain information about your interaction with the Services (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs, or other geolocation tracking technologies (“Tracking Technologies”). Usage Data may include:

 

  • Unique device identifier

  • Precise location

  • Device type, such as your phone, computer, or tablet

  • IP address

  • Browser type

  • Date and time stamps, such as the date and time you first accessed the Services or took a particular action on the Services

  • Operating system

  • Log data

  • Precise location

  • Other information regarding your interaction with the Services, such as clickstream data and ad impressions

 

We use the information we collect automatically to tailor features and content to you, to run analytics and better understand user interaction with the Services and to monitor your usage of the Services. We also use the information that we collect automatically in connection with the information you provide us to make certain inferences about your use of the Services. 

 

We may obtain information about you from outside sources, such as information from third parties that you choose to share with us, for example, when you choose to link any social media platforms to your account, such as Facebook or Twitter. This information is used to maintain your account and login information.

 

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. See Section [ ] below for more information.

 

In addition to the foregoing, we may use all of the above information to comply with any applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, the rights of our users, or others.

 

3. HOW THE COMPANY SHARES YOUR INFORMATION

In certain circumstances, the Company may share your information with third parties. Such circumstances may include:

 

  • With your university or sponsoring institution.

  • With vendors or other service providers, such as:

    • Data analytics vendors

    • Cloud storage providers

    • IT service management vendors

    • Email marketing services vendors

    • Security vendors

    • Insurance vendors

  • To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries

  • In connection with an asset sale, merger, bankruptcy, or other business transaction

  • To enforce any applicable terms of service

  • To ensure the safety and security of the Company and/or its users, including yourself

  • When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations or when you connect with other users of the Services

  •  With professional advisors, such as auditors, law firms, or accounting firms

You acknowledge that such sharing of information may occur in all of the aforementioned circumstances and is permitted by and subject to this Privacy Policy.

4.COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

 

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

 

Cookies and Other Tracking Technologies

 

You may control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

 

Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Services without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule.  For example, in the Internet Explorer menu bar, select: Tools Internet OptionsBrowsing HistoryDelete to view manual and automatic options.

 

To opt out of tracking by Google Analytics, click here.

 

If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

5.USER GENERATED CONTENT

The Services also provides functionality to let you connect with and share content with other users of the Services, which you may elect to join and/or participate in. The purpose of these features is to allow you to share experiences and connect with other users. Through your participation, you may submit messages, photos, recordings, reviews, and other comments (“User-Generated Content” or “UGC”). We or others may store, display, reproduce, publish, or otherwise use UGC, and may or may not attribute it to you. Others may also have access to UGC and may have the ability to share it with third parties. If you choose to submit UGC to any public area of the Services, your UGC will be considered “public” and will be accessible by anyone, including the Company. If you submit UCG anonymously, please be advised that will may not share the UCG with other users of the Services, but we may still share your UCG in an non-anonymous form with your sponsoring institution. 

Please note that we do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure.  We are not responsible for the privacy or security of any information that you make publicly available on the features permitting creation of UGC or what others do with information you share with them on such platforms.  We are not responsible for the accuracy, use or misuse of any UGC that you disclose or receive from third parties through the forums or email lists.

6.SOCIAL FEATURES

Certain features of the Services permit you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to click and access the Company’s pages on certain third-party platforms, such as Facebook and Twitter, and from there to “like” or “share” our content on those platforms. Use of Social Features may entail a third party’s collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both the Company and the third party may have access to information about you and your use of both the Services and the third-party service. For more information on third-party websites and platforms, see Section 7.

7.THIRD PARTY WEBSITES AND LINKS

Our Services may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Services. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

8.CHILDREN’S PRIVACY

Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

9.DATA SECURITY

Please note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you send us through any means is transmitted at your own risk.

10.CALIFORNIA PRIVACY RIGHTS

Sharing for Direct Marketing Purposes

We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine The Light Law”) with third parties for their direct marketing purposes.

 

Users Under 18

 

Any California residents under the age of eighteen (18) who have registered to use the Services, and who have posted content or information on the Services, can request that such information be removed from the Services by contacting us at the e-mail or address set forth in the “Contact us” section below. Such request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished the post and archived copies of it may be stored by search engines and others that we do not control.

11.INTERNATIONAL USERS

The Services are designed for residents of the United States only and are not intended for users located outside the United States.

12.HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at info@offwego.io or contact us at 66 Canal Center Plaza, STE 100, Alexandria, VA 22314.

 [LW1] [LW1]Note to OWG:  [LW1] [LW1] Please note that this Privacy Policy assumes that the client is not subject to the GDPR, CCPA, or industry-specific privacy laws. When/if you become subject to those laws, this policy should be revisited to ensure compliance.

 

Please review this Privacy Policy in its entirety to confirm the accuracy of all provisions.

 [LW2]Note to OWG:  [LW2]Please note that under FTC precedent, material changes to the privacy policy require:

  • For updates relating to personal information already collected, opt-in consent before their information can be used/disclosed in accordance with the new policy; and\or

  •  updates on a forward-looking basis only, the opportunity to opt-out of the policy (which in practice typically means that they must not use the services/website).