Privacy Policy
Last Updated: May 21, 2020
Welcome to the Life Long Driver LLC Privacy Policy. This Privacy Policy (the "Policy") describes the treatment of information provided or collected by Life Long Driver LLC (“Life Long Driver”) and its affiliates, including, but not limited to, Advanced Drivers Education Products and Training, Inc. (“ADEPT”) (collectively, “we” “us” or “our”) on our websites:
www.adeptdriver.com
app.teensmartdriving.com
app.advanced-driver.com
app.lifelongdriver.com
For purposes of this policy, “you” or “your” refers to you, as a user of our websites and services and software applications, whether operated by us or on our behalf (together, the “Services”). The purpose of this Policy is to describe how we collect, share and secure information provided by you. By visiting our websites, submitting information, using our software and services, and/or purchasing any products on our websites, you are agreeing to let us collect and use your personal information as described in this Policy. Therefore, before you provide us with any personal information, you should read through this Policy in its entirety, together with our Terms of Use, which this Policy is incorporated into and governed by, and any other notice we may provide to you, and understand how and why we are using your personal information. We may update the Policy from time to time, so please check it occasionally.
At present, our websites and Services are directed at users in the United States and Canada. If you are not a resident of the United States or Canada, please do not use our websites or Services.
- INFORMATION WE COLLECT
- WHAT WE DO WITH YOUR INFORMATION
- SHARING YOUR INFORMATION
- THIRD PARTIES & LINKS TO THIRD PARTY SITES
- SECURITY
- HOW WE COMMUNICATE WITH YOU
- CHILDREN
- CHANGES TO THIS POLICY
- NOTICE TO CALIFORNIA RESIDENTS
- CONTACT US
1. PERSONAL INFORMATION WE COLLECT:
“Personal Information” means any information about you that can, directly or indirectly, identify you. It does not include anonymous or aggregated data. There are three ways we collect your Personal Information: (1) Information you voluntarily provide to us; (2) Information we obtain when you use the Services; and (3) Information we obtain from third parties.
Information You Voluntarily Provide
When you interact with us, we collect Personal Information that you voluntarily share with us. For example, you may give us your personally identifiable information by filling in forms or by corresponding with us by mail, phone, email or otherwise, or when you make an order on any of our websites or use our software or otherwise use the Services. When you communicate with us, we will collect whatever information you volunteer. You should therefore not send messages or share content that you do not want us to see, save or share.
Information you voluntarily provide to us includes, but is not limited to, the following:
- Identifiers, such as your name, address, phone number, date of birth, gender, driver’s license or permit number, auto insurance policy number, and state;
- Financial Information, such as your credit card information;
- Commercial Information, such as details of the products or services you have purchased from us; and
- Marketing and Communications Information, such as source key and discount codes that we may combine with other Personal Information.
Information We Get When You Use Our Services
We also collect the following types of information about you when you use our Services:
Program Information. When you use our Services, our Services track your progress, and collect certain information including, but not limited to, segment completion dates; Biometric Information in the form of statistical, psychometric, and other analytical information relating to your actions, reactions, activities, and interactions with the software and the scenarios portrayed therein; location and timing of user clicks during driving scenarios; and quiz, simulation and certification test results.
Usage Information. We collect information about your activity on our services. For example, we may collect information about how you interact with our services.
System Information. We collect information from and about the devices you use. For example, we collect information about your hardware and software, including but not limited to the hardware model and related data, operating system version, unique device identifiers, and network.
Information Collected by Cookies and Other Technologies. We may use cookies (which are information stored on your computer by your browser to save your preferences while you are visiting a particular site) and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. If you remove or reject cookies, it could affect the availability and functionality of our services. For more information about cookies, please visit: www.allaboutcookies.org.
Information We Obtain From Third Parties.
We may, from time to time, supplement the Personal Information we collect from you with information collected from our affiliates and certain third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.
Google Analytics. We collect information through a platform called Google Analytics which utilizes cookies when you visit us. This tracking data is used for many purposes including, for example, to provide useful features to simplify your experience when you return to our sites; deliver relevant content based on your preferences, usage patterns and location; monitor and evaluate the use and operation of our sites; and to analyze traffic on our sites and the sites of third parties. You may opt-out from Google Analytics tracking the activity of your browser with this add-on: https://tools.google.com/dlpage/gaoptout?hl=en You may choose whether to have your information collected for these purposes, but not allowing that collection may result in you not being able to use all of the features of our sites.
Third Party Service Providers. We collect Personal Information from service providers where we operate accounts on third-party platforms, such as financial processing platforms, credit check providers, debt collection and payment processors, email platforms, call centers, and social media platforms.
Third Party Advertising Partners. We collect Personal Information received from third party advertising partners, including partners who host and manage various advertisements and online forms where you can request additional information.
2. WHAT WE DO WITH YOUR INFORMATION:
We will use your Personal Information to provide you with our services and carry out our business. Specifically, we may use your information for the following business purposes:
- Provide you with information regarding our services or respond to your requests.
- Send you information about features on our services or changes to our policies.
- Send you marketing communications and other information regarding our products and services.
- Personalize content and experiences.
- Optimize, improve, deliver, maintain, and protect our services and operations.
- Monitor and analyze trends and usage.
- Enhance the safety and security of our products and services.
- Verify your identity and prevent fraud or other unauthorized or illegal activity.
- Use information we’ve collected from cookies and other technology to enhance our services and your experience with them.
- Enforce our Terms of Service and other usage policies.
- Detect, investigate and prevent activities that may violate our policies or be illegal.
How Long We Keep Your Information. We store your information for as long as your account is active or as needed to provide you services and to maintain a record of your transaction(s) and progress for reporting purposes. We will retain and use your information as necessary to comply with our legal obligations, to resolve disputes and to enforce our agreements. We may also retain your information in an anonymized form for analysis, research, and marketing purposes. If you wish to cancel your account or to request that we no longer use your information as specified herein subject to the terms and conditions of the , you may contact us via the contact information provided below. Please note that requests for removal of your information may not ensure complete or comprehensive removal of the information from our network, website, online service, or Software in some circumstances.
3. SHARING YOUR INFORMATION:
We share your information only as set forth in this Privacy Policy.
- Life Long Driver Affiliates. We may share Customer, Program and Usage information collected on our services with our affiliates.
- Third Parties. We may use third-party vendors to perform certain services on our behalf, such as hosting our website, designing and/or operating website or software features and functionality, payment processing, tracking website activities and analytics, or performing other administrative services. We may provide these vendors with access to user information, including device identifiers and Customer, Program and Usage Information, to carry out the services they are performing for you or for us. Third-party vendors are required to protect and secure Customer Data with appropriate controls. Third-party analytics and other service providers may set and access their own tracking technologies on your device, and they may otherwise collect or have access to information, potentially including Personal Information, about you.
- We may inform our partners as you progress through our services. Customer and Program Information may be provided for application of discounts, analysis, research, marketing, or other purposes. You acknowledge and understand that once our partners obtain certain personal information on you from or through our services, they may be able to access your driving records and other information on you from your State's and/or other governmental agency's motor vehicle departments or their equivalents, as permitted by law.
- Business Transactions. In the event that we, or any portion of our assets, are acquired or we undergo another transaction in our business, your information may be transferred to the acquiring company or other entity surviving such transaction.
- Law Enforcement. We may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we reasonably believe may aid a law enforcement investigation into unlawful activity. In addition, we reserve the right to release your information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies, or the release of your information may protect the rights, property, or our safety or the safety of another person.
- Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
- Certain anonymized statistical information may be shared for analysis, research, and marketing purposes. Shared information may consist of program information, performance data, and demographic information such as ages, genders and geographic information.
4. THIRD PARTIES & LINKS TO THIRD PARTY SITES:
This Privacy Policy only addresses your interaction with us on our websites and/or through our services. Our websites may contain content that is supplied by a third party, and those third parties may collect usage information and your device identifier when pages from the website are served to you. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. These third-party owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. Be sure to review any available policies before submitting personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We have no control over, and cannot and do not assume responsibility for, the content, privacy policies or practices of such websites or the companies that own them.
5. SECURITY:
The security, integrity and confidentiality of your information are important to us. We take reasonable and appropriate measures to secure this information. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable and, therefore, we cannot guarantee that your information will remain secure.
When registering an account on our services, it is your responsibility to choose an account password that is difficult for others to guess, preferably a password you do not use on any other website or account, and never reveal it to anyone else. If you use a shared or public computer, DO NOT choose to have your login ID or password remembered and log out of your account completely every time you leave the computer. Also, please verify that your web browser has a secure connection to the websites before entering any personally identifying information and avoid including personally identifying information in e-mails to us (particularly credit card or banking information).
6. HOW WE COMMUNICATE WITH YOU:
We may email you certain communications relating to our products and/or services, such as service announcements and administrative messages. You consent to receipt of any and all transactional and administrative messages while your account is active. You can manage your subscription preferences for all other communications from us by accessing the “unsubscribe” options included in such messages. If you have any difficulty managing your communication preferences or if you have any questions about our Policy, please contact us via the contact information provided below.
If we need, or are required, to contact you concerning any event that involves your personal information, we may do so by email, telephone or mail.
7. CHILDREN:
Our websites are not directed to children under 13 years of age and we do not provide services to children, or knowingly collect or solicit personal information from children under 13 years of age.
8. CHANGES TO THIS POLICY:
We may, in our sole discretion, update this Privacy Policy periodically without prior notice to you to reflect changes in our information practices or with respect to applicable laws. We will post the updated version on our websites and indicate at the top of the Privacy Policy when it was last updated.
Please revisit this page periodically to stay aware of any changes to this Privacy Policy. In the event that the modifications materially alter your rights or obligations hereunder we will make commercially reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification after such material changes are made. Our amended Privacy Policy will automatically take effect upon the date that an update is published. If you do not agree with any changes to the Privacy Policy, you should cease using our services. Your continued use of our services after the revised or updated Privacy Policy has become effective indicates that you have read, understood and agreed to the then-current version of the Privacy Policy.
9. YOUR CALIFORNIA PRIVACY RIGHTS:
California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Upon verification of your identity you may:
- No more than twice in any 12-month period, request disclosure of the following information:
- Categories of Personal Information we collect.
- Categories of sources from which Personal Information is collected.
- Categories of Personal Information sold or disclosed to third parties.
- Categories of third parties with whom such Personal Information is sold or disclosed.
- Business or commercial purpose for collecting or selling Personal Information.
- Specific pieces of Personal Information we collect.
- Request deletion of your Personal Information, subject to the exceptions provided by law.
Requests can be submitted by calling our toll-free number (800) 808-5678 or through our website at https://www.adeptdriver.com/contact/.
Please note that these rights apply only to select California consumers and exclude job applicants, employees, and business contacts. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable consumer request must:
- Include your full legal name and phone number, which we will need to contact you in order to verify that you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. In order to verify your identity, one of our representatives will call you at the phone number provided.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
The CCPA provides the right to be free from discrimination if you choose to exercise your rights under the statute, and we will not discriminate by:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
OTHER CALIFORNIA PRIVACY RIGHTS:
If you are a California resident, California Civil Code Section 1798.83 permits you to request a notice regarding the disclosure of your personal information by us to any of our partners for the partners’ direct marketing purpose. If you are a California resident and would like a copy of this notice, please contact us via the contact information provided below. Please allow 30 days for a response.
We do not track our users and visitors over time and across third party websites to provide targeted advertising. Consequently, we do not respond to Do Not Track (DNT) signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
10. CONTACT US
If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you or your preferences, please contact us as indicated below:
Life Long Driver, LLC
2374 Maritime Drive
Elk Grove, California 95758
or email Life Long Driver at: info@adeptdriver.com
