Finloc 2000 Inc. (the “Company”) values its customers and respects their privacy. We have created this privacy policy to demonstrate our firm commitment to your privacy and security, and to advise you about the collection, use and disclosure of personal information when we provide our apps, websites, features, and services (collectively, the “Services” or “vHub”). This privacy policy applies to all users of vHub, including all customers, prospects and job applicants. This privacy policy also provides you information on your ability to “optout” of providing personal information that you do not wish to provide and to access, change or remove any personal information already collected.
You are responsible to ensure that your access to vHub and material available on or through vHub is legal in each jurisdiction in or through which you access or view vHub or such material.
The terms “Company,” “we”, “us”, and “our” used in this privacy policy refer, collectively, to the Company and its affiliates, divisions, successors and assigns and their respective employees, workers, mandataries and agents (collectively, the “Company Affiliates”).
1. WHAT INFORMATION IS COLLECTED BY THE COMPANY?
Any time you use our Services or introduce any information, content or other materials through vHub or otherwise provide personal information to the Company (including via mail or email in regular correspondence), it may be collected, used and disclosed by the Company for various purposes as described herein.
Information created when you use our Services:
- Device Information: Every time you visit or use vHub, the following information may be collected automatically: your internet protocol (IP) address and the domain name registry information associated with that IP address; identification of your internet browser, operating system and/or hardware you are using; the date and time of your visit; the name and address (URL) of the web page you viewed immediately prior to accessing vHub; your entire query (if any) that was entered into a search engine which led you to vHub; any other “click stream” data; and other similar information. This information may be stored in our log files. Occasionally, if your browser is not configured to prevent disclosure of such information, the following information may also be revealed to us: your name, email address, home and work addresses, telephone and fax numbers and any plain text commentary.
- Usage Information: We may collect the complete record of your actions on vHub, including without limitation access dates and times, app features or pages viewed, the time spent on each page, the information sent or received and the names of all files uploaded or downloaded, and other information related to your use of the Services.
- Geolocation Information: Depending on the Services that you use, your device settings and device permissions, we may collect your precise or approximate location information as determined through data such as GPS, IP address and WiFi. This information may include:
- Geolocation information when vHub is running in the foreground (app open and on-screen) or background (app open but not on screen) of your device.
- If you have not restricted permission for the processing of location data, we collect location information when vHub is running in the foreground or information provided from other geolocation devices in your vehicle while using the Services. You hereby represent and warrant to the Company that you have all required third-party consents and authorizations to provide such geolocation data to us for our collection and use.
- You may use vHub without enabling us to collect your geolocation data. However, this may affect or restrict the functionalities available on vHub.
- Transaction Information: We may collect transaction details related to your use of our Services and navigation on vHub, including the types and frequency of services you requested or provided, your transaction details, date and time the Services were used, amounts charged or transferred, distances traveled, routes considered and taken for transit, requests made, as well as payment methods.
- Communications Data: We may enable users to communicate with each other and us through vHub. For example, we may enable renters or service providers, as the case may be, and owners to call or text each other. To provide this Service, the Company receives some information regarding the calls or texts, including the date and time of the call/text, and the content of the communications. Renters or service providers, as the case may be, and owners may also exchange contact information and communicate directly outside of vHub. The Company may also, but is not obligated to, use this information to improve our products and services and for analytics.
Information you provide:
- User profile: We may collect information when you create, edit or update your vHub account. Such information shall namely include, as the case may be, your name, e-mail, phone number, login name and password, address, payment information (including related payment verification information), licenses, your pictures including those of physical persons, movables or things, restrictions or instructions regarding assets provided to users through vHub, government identification numbers such as driver’s license, birth date, photo and signature. This also includes equipment or insurance information and certificates as well as the preferences and settings that you enable for your vHub account(s).
- Demographic data: We may collect demographic information about you, including through user surveys.
- User content: We may collect information that you submit when you provide ratings, comments and feedback to others through vHub or otherwise contact us.
Children’s Privacy: In light of the importance of protecting children’s privacy, we do not intend vHub for child audiences, and we do not collect, process or use on vHub any information relating to an individual whom we know to be under 13 years old without the prior, verifiable consent of his or her parent or other legal representative. If a parent or guardian discovers that his or her child has provided us with personally identifiable information, such parent or guardian has the right, upon request, to view the information provided by the child and/or to require that it be deleted from our records. In such a case we ask that the parent or guardian of the child contact us at the contact information provided in the “Contacting Us” section below for such purpose.
2. HOW IS YOUR PERSONAL INFORMATION USED?
We may use the information we collect to:
- Develop, Offer and Provide Services and Features: We use the information we collect to develop, offer, provide, personalize, maintain and improve the Services. This includes using the information to:
- Create and update your account.
- Verify your identity.
- Process your information.
- Process or facilitate payments for Services.
- Track the progress of your rental or repositioning services, as the case may be.
- Create and enable features that allow you to share information with other people, such as when you submit a rating about a renter, service provider or owner.
- Create and enable features to personalize your vHub account.
- Perform internal operations necessary to provide the Services and develop new products, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.
- Develop new products, services and offerings.
- Research and Development: We may use the information we collect for testing, research, analysis and product development. For example, this allows us to improve and enhance the efficiency and quality of our Services, develop new features and products, and facilitate insurance and finance solutions in connection with our Services.
- Communications Among Users: We may use the information we collect to enable communications between our users. For example, a driver may text or call an owner.
- Communications from Us: We may use the information we collect to tailor and send you communications about products, services, promotions, studies, surveys, news, updates and events.
- Legal Proceedings and Requirements: We may use the information we collect to investigate or address claims or disputes relating to your use of the Services, to investigate any actual or threatened security breach of vHub, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
- Consent: We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
We may also use information collected from vHub to measure interest in the various areas of vHub, to ensure that links on vHub facilitate easy navigation and to help make vHub more interesting and user friendly.
You acknowledge and agree that the Company shall also have the right to incorporate, use and reproduce any text, image, video, audio, or any information, content or other materials you provide through vHub, in whole or in part, in connection with the operation, marketing and promotion of the Company’s business. You always have the right to revoke such consent in the manner described in the section “How do I exercise my choices about the collection, use and disclosure of my personal information?” below.
In order to better serve you as well as maintain and improve our product and service offering, we may combine and aggregate information we collect directly or indirectly from you through your use of the Services. We may also combine your information with readily available personal information we obtain from third parties, including demographic or geographic information, for various purposes, including to enable us to communicate with you, by telephone (including by way of automated dialing answering device), email, mail, text, sms or otherwise.
We may use personal information and other information to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access the Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws.
3. TO WHOM MAY YOUR PERSONAL INFORMATION BE DISCLOSED?
We may disclose your personal information as provided below:
- With Other Users: We may share information with other users including personal name and photo, make, model, color, license plate, specifications, location and photos of any equipment added to vHub; ratings provided by other users, for how long you have been using vHub, contact information (depending upon applicable laws) and any other information required to provide the Services.
- To Company Affiliates: We may disclose your personal information to any of the Company Affiliates, so that it may communicate with you (whether by email, telephone, text, post or otherwise) and provide you with promotional materials and additional information about its products, services, promotions and special offers that may be of interest to you, or collect and use that information subject to and for other purposes contemplated by this privacy policy.
- In a Sale Context: In the event of a sale of all or substantially all of our business or another similar transaction (such as a sale of a division or business unit), we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating and/or effecting a proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this privacy policy.
- Non-Affiliated Third Parties: We may provide information to vendors, consultants, marketing partners, research firms, and other service providers or business partners of vHub. This may include, for example:
- Payment processors and facilitators.
- Background check providers.
- Cloud storage providers.
- Marketing partners and marketing platform providers.
- Data analytics providers.
- Research partners, including those performing surveys or research projects in partnership with the Company or on the Company’s behalf.
- Vendors that assist the Company to enhance the safety and security of its apps.
- Consultants, lawyers, accountants and other professional service providers.
- Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
- As Required by Law: We reserve the right to disclose your personal information as required by law, in response to legal or regulatory process and/or law enforcement requests by government authorities that have asserted a lawful right to access such information, to our legal counsel, or as we deem appropriate to protect the property, interests and rights of the Company, any Company Affiliates, and other third parties.
4. WHAT ARE “COOKIES”, “WEB BEACONS”, AND SIMILAR TECHNOLOGIES AND HOW DOES THE COMPANY USE THESE ON THE SERVICES?
We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, web beacons, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
- Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
- Web Beacons/Pixel Tags. A web beacon (also known as a pixel tag) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a web beacon allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
- Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
- Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
- Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising- or Targeting-Related. We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
See the section below titled “HOW DO YOU EXERCISE YOUR CHOICES ABOUT THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION?” to understand your choices regarding these Technologies.
- Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
- Google Analytics. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
- Hotjar (Session Replay Provider). We use Hotjar for session replay analytics. Hotjar’s service allows us to record and replay an individual’s interaction with the Services. This helps us understand our user’s experience and how we can improve our Services.
For more information about Hotjar, please visit Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.
5. HOW DO YOU EXERCISE YOUR CHOICES ABOUT THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION?
We will collect, use and share your personal information for the purposes and in the manner described in this privacy policy, including in order to contact you and provide you with promotional communications. We want you to know that you may have choices about how we collect and use your personal information, including your choice to refuse to provide us with personal information and withdraw any consent you have provided to us, in accordance with applicable law and/or as described below.
General. You have the choice simply not to submit any personal information to us, however this may limit our ability to serve you as it may prevent you from using or restrict your use of the Services. You may also choose only to submit information constituting required fields. In the event that you have already consented to the collection, use and/or disclosure of your personal information, you may be able to subsequently “optout” at any time, in accordance with applicable laws or contractual restrictions and reasonable notice, by contacting our privacy officer as described in the section entitled “Contacting us” below. Our privacy officer will also be able to provide you with more information regarding the implications of withdrawing consent.
Promotional Communications. You can opt-out of promotional communications from us by following the opt-out instructions provided in the promotional materials sent to you. If you send us a request not to receive promotional communications from us, please be sure to include your full name, address, telephone number and any email address you used when you signed up on vHub or otherwise communicated with us. It may take up to twenty (20) business days to process your request, during which period you may continue to receive communications from the Company or the Company Affiliates. If you prefer not to receive promotional information from the Company or Company Affiliates, please follow the unsubscribe instructions set out in the privacy policy or in the respective privacy policies and/or communications of the Company Affiliates.
Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
6. HOW CAN YOU ACCESS OR CHANGE YOUR PERSONAL INFORMATION OR MAKE INQUIRIES OR COMPLAINTS IN RELATION TO THIS PRIVACY POLICY AND THE COMPANY’S PRIVACY PRACTICES?
In accordance with applicable law, you may be entitled to request access to and/or correct your personal information collected by us. In order to make such a request, please contact our privacy officer in writing (see “Contacting Us” below).
You can also contact our privacy officer for any questions about or to make any complaint in relation to the privacy policy, as well as to the Company’s privacy practices in general (see the “Contacting Us” section below).
7. HOW LONG IS YOUR PERSONAL INFORMATION RETAINED?
We will keep your personal information only as long as is reasonably necessary for the purposes described in this privacy policy or such longer period as may be required or permitted by applicable law.
8. HOW SECURE IS YOUR PERSONAL INFORMATION?
We use commercially reasonable efforts to adopt physical and technological processes and procedures designed to protect the confidentiality of personal information and designed to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. Furthermore, Company employee, worker, mandatary or agent must abide by the privacy policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any personal information we process. To the fullest extent permitted by applicable law, we do not accept liability for any theft, misuse, unauthorized disclosure, loss, alteration or destruction of data.
The Company also strives to offer its customers a secure environment. vHub uses PCI compliant third-party payment processors for all payment processing services and thus all credit card information will be secured in accordance with their own security practices and your payment information and credentials are not stored on our servers. vHub reserves the right to change third-party payment processors from time to time without any obligation to provide notice to users.
9. CALIFORNIA PRIVACY PROVISIONS.
The following provisions supplement the information contained in this privacy policy and apply solely to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”) in our role as a business. Any terms defined in the CCPA have the same meaning when used in this section.
Information We Collect
The CCPA provides California residents with the right to know what categories of personal information Company has collected about them and whether Company disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
|
Category |
Examples |
Collected |
Categories of Third Parties Personal Information is Disclosed to for a Business Purpose |
|
Identifiers. |
Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, e-mail address, account name, Social Security, or other similar identifiers. |
Yes |
• Other users • Service providers • Company Affiliates • Advertising partners |
|
Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
Yes |
• Other users • Service providers • Company Affiliates
|
|
Internet or other electronic network activity. |
Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement. |
Yes |
• Other users • Service providers • Company Affiliates • Advertising partners |
|
Geolocation data. |
Physical location or movements is collected as part of administering the Services. |
Yes |
• Service providers • Company Affiliates
|
|
Personal information categories listed in the categories above, but references in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories. |
Yes |
• Other users • Service providers • Company Affiliates
|
|
Professional or employment-related information. |
Current or past job history. |
Yes |
• Other users • Service providers • Company Affiliates
|
|
Inferences drawn from other personal information to create a profile about a consumer. |
Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
Yes |
• Other users • Service providers • Company Affiliates • Advertising partners |
Categories of Sources from Which Personal Information is Collected
We obtain the categories of personal information listed above from the types and categories of sources described above in this privacy policy.
Business or Commercial Purposes for Collecting Personal Information
We may use or disclose the personal information we collect for the business purposes described above in this privacy policy.
Sales of Personal Information
In the preceding twelve (12) months, we have not disclosed your Personal Information to any third party in a manner that would be considered a sale under the CCPA, nor do we have actual knowledge of any sale of personal information of minors under 16 years of age under the CCPA.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
- Right to Know – You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you a copy of your personal information in a readily available format, and the information required under the CCPA.
- Right to Delete – You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception in the CCPA applies.
Exercising Your Rights
To exercise the access and deletion rights described above, or if you have any questions about these rights, please submit your request to us at privacy@vhubapp.com or contact us in writing at the address listed below in this privacy policy. We will process such requests in accordance with applicable laws.
Non-Discrimination
California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.
Verification
When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include confirming the e-mail address associated with any personal information we have about you.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below in this privacy policy.
10. NEVADA PRIVACY PROVISIONS
If you are a resident of the State of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.
11. INTERNATIONAL TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States of America, Canada or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
12. PRIVACY POLICY CHANGES
We may revise this privacy policy from time to time in our sole discretion. If there are any material changes to this privacy policy, we will notify you as required by applicable law. Following the effective date of such changes, you will be bound by such changes unless you advise us in writing, by phone or by email before the effective date of such changes that you do not agree to the changes in which case you may not be able to continue using the Services. You are responsible for regularly reviewing this privacy policy and any changes thereto.
13. OTHER WEBSITES/APPLICATIONS
VHUB MAY CONTAIN LINKS TO OTHER WEBSITES/APPLICATIONS THAT ARE NOT OPERATED BY THE COMPANY. THE POLICY DOES NOT APPLY TO THE PRACTICES OF THIRD PARTIES AND THE COMPANY DOES NOT ASSUME ANY RESPONSIBILITY FOR ANY SUCH THIRD-PARTY PRACTICES OR FOR THE PRIVACY PRACTICES OF THE WEBSITES/APPLICATIONS THAT IT DOES NOT OPERATE. BY USING VHUB AND/OR ACCESSING A THIRD PARTY’S WEBSITE/APPLICATION FROM VHUB, YOU RELEASE THE COMPANY OF ANY RESPONSIBILITY FOR THE ACTIONS, PRACTICES AND OMISSIONS OF THIRD PARTIES. BY CLICKING ON ANY HYPERLINKS TO OTHER WEBSITES/APPLICATIONS FROM VHUB, YOU MAY AUTOMATICALLY SUBMIT TO THE PRIVACY PRACTICES OF THOSE WEBSITES/APPLICATIONS. PLEASE CHECK THE PRIVACY POLICIES OF THESE THIRD-PARTY WEBSITES/APPLICATIONS. IN NO EVENT SHALL THE COMPANY OR ANY COMPANY AFFILIATES BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DAMAGES OR INJURY WHATSOEVER (INCLUDING BUT NOT LIMITED TO DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES) ARISING OUT OF OR IN CONNECTION WITH THE MISUSE OF PERSONAL INFORMATION BY THOSE WEBSITES/APPLICATIONS.
14. CONTACTING US
The Company has appointed our Corporate Secretary as our Privacy Officer. The Privacy Officer is accountable for the Company’s compliance with the principles of any applicable privacy legislation and this privacy policy.
If you have questions or complaints with respect to our privacy policy and practices or if you wish to exercise any rights you may have in your personal information, please contact the Privacy Officer at:
|
BY E-MAIL |
BY PHONE |
BY POST MAIL |
|
privacy@vhubapp.com |
1-866-849-0189 |
11505, 1st Avenue Attention: Privacy Officer |
Last updated: August 9, 2021