Effective Date: August 30 2022
Thank you for using our Services. Your privacy is very important to us, and it is
our intent to comply with any applicable law regarding the personal information
we collect about you. This Privacy Policy explains our processing of the personal data
collected through https://tram.global (the “Site”) and our related mobile application (the
“App” together with the Site, the “Services”). By using the Services, you agree to this
Privacy Policy. The Services are provided by TRAM GLOBAL Inc., and we are a data
controller. We are committed to protecting and respecting your privacy so you can
navigate and use the Services safely.
This Privacy Policy discloses what information we collect about you, how we gather it,
how we use and share it, and what rights you have. This Privacy Policy may change
from time to time, so we recommend that you read it periodically. This Privacy Policy is
incorporated into our Terms which, together with this Privacy Policy, govern your use of
the Services. We want to make this Privacy Policy as clear as possible. If, however, you
have any questions, comments, or concerns about this Privacy Policy, please send us
an email at privacypolicy@tram.global.
As a user of our App or a visitor to our Site, you must accept this Privacy Policy. If you
do not consent to the terms of this Privacy Policy, do not use the App or access the
Site. By using the App or accessing our Site, you agree to this Privacy Policy and to our
processing of Personal Information as described in this Policy.
1. INFORMATION WE COLLECT ABOUT YOU
Some of the information we collect about you identifies you. If it identifies you, we call it
“Personal Information.” Personal Information does not include any information that is
publicly available or information that has been anonymized to the point where a specific
individual or household cannot be identified from the remaining information. If we
associate non-identifiable information with information that identifies you, we will treat it
as Personal Information.
We only collect Personal Information that is reasonably necessary to provide our
Services to you and for the purposes set forth in this Policy. The information we collect
can come from information you provide, information we collect through automated
means, and information we collect from other sources.
A. Information You Provide.
1. Profile Information. When you register on the Site, we will need to collect
demographic and personal details about you. When you download and interact with us
on the App, we will need to collect further details about you. The Personal Information
you provide in the App may include the following:
● Personal details, including your name, address, email address, phone number,
and date of birth;
● Demographic information such as age or gender;
● Transaction information, including payment details;
● Account information, such as your user name and the password you use to
access our Services;
● University ID numbers;
● Vehicle ownership data; and
● Other Personal Information you choose to provide us when you interact with us.
You are responsible for the accuracy of the Personal Information that you submit. You
can choose whether you provide Personal Information to us, but if you do not provide it
to us, we may not be able to offer certain features of the Services.
2. Financial Information.
3. Other Information. When you contact customer support or communicate
with us in any other way, we’ll collect whatever information you volunteer or that we
need to resolve your question. Note that our ability to resolve your question could be
dependent upon you disclosing the information we require.
B. Information We Collect Automatically.
1. Geospatial Information. Our App collects information about the exact
location of your device on which you’ve downloaded the App by using geolocation and
technology such as GPS, Wi-Fi, Bluetooth, or cell tower proximity. You generally can
disable the collection of this information in your device settings. Some of our Services
may not work properly without information about your location.
2. Usage and Device Information. When you access our App or use our Site,
we automatically /passively collect certain browser or device-generated information by
using various types of technology (“Usage Information”). This information includes, but
is not limited to:
● The type of mobile internet / Web browsers you are using.
● The manufacturer and model of your mobile device.
● Your mobile operating system.
● Device location by using geolocation and technology such as GPS, Wifi,
Bluetooth or cell proximity.
● IP address or other device addresses and ID’s.
● Date, time and place of accessing our services.
● Information regarding your email message interaction, such as whether you have
opened, clicked on, or forwarded a message.
You generally can disable the collection of information in your device settings. Some of
our services may not work properly without information about your location.
3. Cookies and Other Tracking Technologies. Like most online services and
mobile applications, we use cookies and similar tracking technologies to collect Usage
Information. Please see the “Cookies and Other Tracking Technologies” section below
for more information.
4. Analytics. We may work with different companies that offer services that
can assist us in better understanding how users interact with and use the Services. For
example, we may use a product called Google Analytics by permitting Google to use
technologies such as web beacons and cookies to collect certain non-personally
identifiable information that helps us understand your use of our Services. Google and
other analytics providers may combine information collected through our Services with
information collected from third-parties to help us better understand you. They may also
use information collected on our App and Site to help their other customers understand
you better.
C. Information From Third Parties. We may, from time to time, supplement the
information we have about you with information from third parties for various purposes,
including to enhance our ability to serve you, to offer you opportunities that may be of
interest to you, and to improve the performance of our ads.
2. HOW WE USE YOUR INFORMATION
A. To Provide Services. We use your information to improve your experience and
to deliver the Services you have requested. We will use your information to customize
or personalize your experience with our App and to provide you with customer support.
We may also use your information if we need to contact you about your relationship with
us.
B. To Manage Our Business. We also use the information for our business
purposes, which include the following.
● Planning and managing our activities, including marketing our App and the Site,
delivering targeted advertisements, researching and analyzing your use of the
App or your visits to the Site, tracking user behavior, and collecting feedback;
● To develop inferences about you;
● Administering our business, such as managing agreements with our suppliers;
● Monitoring aggregate usage metrics such as total number of visitors to our Site;
● Developing new features, functionalities, and services;
● Operating, evaluating, maintaining, improving, or developing our App and Site;
● Protecting and ensuring the safety of the Services, our confidential and
proprietary information, and our employees;
● Managing, protecting against, and investigating fraud, risk exposure, claims and
other liabilities, including but not limited to violation of the Terms, laws or
regulations;
● For internal recordkeeping purposes;
● Anonymizing your Personal Information for further internal and external uses in a
manner that does not identify you; and
● The ways we describe elsewhere in this Privacy Policy.
C. To Make Inferences. We may use any of the information we collect about you to
develop inferences about you, including your interests and characteristics about you.
3. HOW WE SHARE INFORMATION
Except as described in this Privacy Policy, we
do not disclose your Personal Information without your consent.
A. To Provide Services. We may share Personal Information as necessary to
provide our Services, complete a transaction, market the Services to you, or fulfill your
requests. For example, we work with third party service providers to help us provide the
Services and we may need to share your information with them so they can fulfill their
obligations to us. We may share your information to monitor, improve, or better market
our Services such as with third party cookie providers.
B. Sale of Personal Information and Targeted Advertising. After obtaining your
consent, we sell and/or share your Personal Information with third parties for
commercial or marketing purposes. We also sell and/or share your Personal Information
with third-parties so they can market to you and so they can better deliver targeted
advertisements to you. You may change your mind or opt-out of the sale or sharing of
your information for these purposes. Please note that other parties may collect Personal
Information about your online activities over time and across different Web sites when
you use our Services. Please see the “Targeted Advertising” section below for more
information.
C. To Manage Our Business.
1. Related Parties and Affiliates. We may share Personal Information with a
parent, subsidiary, or affiliate of our company.
2. Service Providers and Professional Advisors. We work with third party
service providers to help us provide the Services and to assist us in operating our
business. For example, service providers are used in areas such as email management
and deployment, analytics, marketing, advertising, market research, identity validation,
content distribution, customer service, payment fulfillment, logistics, website
maintenance and data storage and security, and we share your Personal Information so
they can fulfill their obligations to us. We may also share your Personal Information with
our professional advisors such as our legal representatives or insurance brokers.
3. Legal Requirements and Law Enforcement. We will disclose your
Personal Information if we have a good faith belief that such disclosure is necessary to
comply with valid legal requirements such as a law, regulation, search warrant,
subpoena or court order and to meet national security or law enforcement requirements.
We will also disclose your Personal Information to respond to a physical threat to you or
others or to defend or assert legal rights of us or others. We may disclose your Personal
Information to credit reporting agencies, courts, tribunals, and regulatory authorities, in
the event you fail to pay for goods or services we have provided to you.
4. Dispute Resolution. We will disclose your Personal Information as
necessary to resolve disputes, inquiries or complaints. We may disclose your Personal
Information if we believe you have violated our Terms.
5. Business Transfers. We may also share your information in the event we
are transferred or sold to another entity as a result of a corporate sale, merger,
consolidation, asset sale, or in the unlikely event of bankruptcy.
6. Other Sharing of Personal Information. We reserve the right to disclose
Personal Information that we believe, in good faith, is appropriate or necessary to:
(a) take precautions against liability, (b) protect us or others from fraudulent, abusive, or
unlawful uses or activity, (c) investigate and defend us against any third-party claims or
allegations, (d) protect the security or integrity of the Services and any facilities or
equipment used to make the Services available, or (e) protect our property or other
legal rights, or the rights, property, or safety of others.
D. Your Consent. We may disclose your Personal Information to a third party in a
manner not addressed by this Privacy Policy, subject to your consent at such time.
E. Aggregate and Anonymous Information. We make automatically-collected,
aggregated, or otherwise non-personally-identifiable information available to third-
parties for various purposes, including: (a) for compliance with various reporting
obligations; (b) for business or marketing purposes; (c) to assist us in improving the
products or Services; or (d) to assist such parties in understanding our users’ interests,
habits, and usage patterns for certain content, services, advertisements, promotions,
and/or functionality available through the Services.
We expressly disclaim any and all liability for the actions of third parties. The privacy
practices of any third parties are outside the scope of this Privacy Policy and their use
or disclosure of your information (including your Personal Information) are governed by
their own privacy practices.
4. YOUR RESPONSIBILITIES.
You are responsible for securing and maintaining the
privacy of your login information and password(s) and verifying that your Personal
Information is accurate and current. We are not responsible for the privacy or security of
any information on the Services that you make publicly available or what others do with
information you share with them. Please think carefully before deciding what information
you share, including Personal Information, in connection with your use of the Services.
Be aware that certain Personal Information and other information in connection with
your use of the Services may be stored on your device (even if we do not collect that
information). You are solely responsible for maintaining the security of your device from
unauthorized access.
5. YOUR CHOICES AND RIGHTS.
You have choices when it comes to the privacy
practices and communications described in this Privacy Policy. Many of your choices
may be explained at the time you sign up for or use our Services or in the context of
your use of our App or Site. You may be provided with instructions and prompts within
the experiences as you navigate the App or Site. If you do not want your Personal
Information used or shared as provided in this Privacy Policy, you should not use the
Services. You may, of course, decline to share certain Personal Information with us in
which case, we may not be able to provide some of the features and functionality of the
Services.
A. Targeted Advertising. When you use our App, we may collect information about
your activities with your consent, so that we can provide you with advertising tailored to
your interests.
We also use ad networks. Ad networks track your online activities over time by
collecting information through use of cookies, web beacons, and other technologies. We
use ad networks that combine information collected through our App with information
collected from third-party sites that also take part in the relevant ad network. This
information includes, for instance, the pages or advertisements you view and how you
use the websites. This information helps us deliver advertisements that are targeted
towards you based on your interests, other information related to you, and contextual
means. Ad networks may also use this information to help their other customers deliver
advertisements that are targeted towards you on those third-party sites. We request
your separate consent before we use or disclose your information for targeted
advertising purposes.
You can opt out of targeted advertising by contacting us to privacypolicy@tram.global,
or by visiting the Digital Advertising Alliance website or the
Network Advertising Initiative website. If you choose to opt out, you will continue to
receive advertisements, but they will not be tailored to your interests. Depending on the
type and version of the operating system of your mobile device, you may also be asked
whether to enable targeted advertising.
B. Marketing Communications and Commercial Email Opt-Out. When you
create an account with us, unless you opt-out, we will use your email address to deliver
digital communications from us or our advertisers or sponsors. When you communicate
with us through any means such as chat or email, we may use your contact details for
marketing communications. You can unsubscribe from email and other digital
communications by following the instructions in the communication or by sending a
request to us using the contact information listed below or through the Contact Us link
provided at the bottom of every page of the Site.
If you opt-out of receiving commercial emails from us or otherwise modify the nature or
frequency of promotional communications you receive from us, it may take up to ten
business days for us to process your request, and you may receive promotional
communications from us that you have opted-out from during that period. Additionally,
even after you opt-out from receiving commercial messages from us, you will continue
to receive administrative messages from us regarding the Services.
With your consent, we may share Personal Information with third parties for their own
direct marketing purposes.
C. Applicable Law. Subject to applicable law, you may have different rights
regarding our use of your information. For example, you may have the following rights:
● Right to request access to and to check what Personal Information we maintain
about you;
● Right to request copies of your Personal Information;
● Right to update and correct inaccuracies in your Personal Information;
● Right to have your Personal Information deleted;
● Right to request restriction of the collection, processing, or use of information
about you;
● Right to request data portability;
● Right to lodge a complaint with a supervisory authority; and
● In some cases, the right to object to our processing of your information and to
withdraw your consent to our processing of your information.
You can perform many of these actions by going back to the App, logging-in, and
making the desired change.
When you request the deletion of your information, object or withdraw your consent to
the processing of your information, we may not be able to provide all the features of the
Services to you. You should be aware that it is not technologically possible to remove
each and every record of the information you have provided to the Services from our
servers.
To exercise any of these rights please contact us using the contact information listed
below or through the Contact Us
provided at the bottom of every page of the Site.
We will promptly review all such requests in accordance with applicable laws.
Please see the Special Notice for California Consumers and Special Notice for
International Users for more information about rights that apply to residents of certain
geographic locations.
6. CHILDREN’S PRIVACY.
The Services are designed and intended for use by adults
and are not intended for nor designed to be used by children under the age of eighteen
(18) years. We do not intend to collect Personal Information from any person we know
is under the age of eighteen (18). We direct potential users under eighteen (18) years of
age not to use the Services. If we learn that Personal Information of persons younger
than eighteen (18) years of age has been collected, then we will take the appropriate
steps to delete this information. To make such a request or if there are any questions or
concerns about this Privacy Policy or its implementation, please contact us using the
contact information listed below or through the Contact Us link provided at the bottom of
every page of the Site.
7. COOKIES AND OTHER TRACKING TECHNOLOGIES.
“Cookies” are alphanumeric identifiers
that are stored on a computer, browser, laptop, tablet, mobile phone, or other device
(each, a “Device”), which collect information about your activity, browser, and Device. A
“web beacon” (sometimes referred to as pixels and tags) is a small object or image that
is embedded into a web page, application, or email, and is used to track activity.
We may use both session (for the duration of your visit) and persistent (for the duration
of a fixed period of time) cookies and tracking technologies. A cookie does not provide
us with access to your computer or to Personal Information beyond what you provide to
us.
Some cookies are necessary to use the Services, and these cannot be disabled. Other
cookies are not required to use our Services and may be disabled or deleted, but this
may prevent you from properly using the Services. Most browsers allow you to adjust
your cookie settings.
8. HOW YOUR INFORMATION IS SECURED.
We follow generally accepted industry
standards, including the use of appropriate administrative, physical, and technical
safeguards, to protect the Personal Information submitted to us. For example, when you
enter Personal Information, we encrypt the transmission of that information.
Despite efforts to protect your Personal Information, no method of electronic
transmission or storage is 100% secure, and there is always some risk that an
unauthorized third party may find a way around our security systems or that
transmissions of your information over the internet may be intercepted.
If we learn of a security system breach, then we may attempt to notify you so that you
can take appropriate protective steps. We may post a notice through the Services if a
security breach occurs. Depending on where you live, you may have a legal right to
receive notice of a security breach in writing, and we will follow all applicable laws.
9. HOW LONG WE KEEP YOUR PERSONAL INFORMATION.
We will retain your Personal
Information as long as your account is active or as needed to provide you Services. At
any time, you can remove your Personal Information or instruct us to remove it, but you
should be aware that it is not technologically possible to remove each and every record
of the information you have provided to us from our servers. See “Your Choices and
Rights” for more information on how you can remove your Personal Information.
Even though you may make changes or request deletion of your Personal Information,
we may retain all information for backups, archiving, prevention of fraud and abuse,
analytics, satisfaction of legal obligations, or where we otherwise reasonably believe
that we have a legitimate reason to do so.
10. SPECIAL NOTICE FOR CALIFORNIA CONSUMERS.
This part of our Privacy Policy applies
to consumers who reside in the State of California.
A. Personal Information We Collect About California Consumers. We describe
the Personal Information we have collected about California consumers in the
twelve(12) months preceding the Effective Date of this Privacy Policy in Section 1
(“Information We Collect About You”). This information includes the following
categories:
● Identifiers
● Postal address
● Email address
● Telephone number;
● Online identifier (e.g., IP address)
● Bank account number, credit card number, debit card number and/or other
financial information
● Driver’s license number / state ID;
● Electronic network activity (e.g., browsing history);
● Geolocation data
● Transaction information.
● Inferences used to create consumer profiles
B. Use of Personal Information. We use the Personal Information we collect about
California consumers for the business purposes disclosed within our Privacy Policy and
described in Section 2 (“How We Use Your Information”).
C. Disclosures of Personal Information. As is common practice, within the past
12 months, we have disclosed Personal Information in all or substantially all of the
categories identified in Section A of this Additional Notice for California Consumers to
vendors who provide services to us, in connection with a sale or transfer of all or part of
our business, and as otherwise provided in Section 3 (“How We Share Your
Information”).
D. Sale of Personal Information. While we sell Personal Information, we do not
sell Personal Information of individuals we know to be under the age of 16 to other
businesses or third parties.
E. Your California Privacy Rights. If you are a California resident, you may have
the following rights. We will honor requests received to the extent required by
applicable law and within the time provided by law.
1. Right to Access and Right to Know Your Personal Information.You may
have the right to request that we disclose the following to you, in each case in the
twelve-month period preceding your request:
o the categories of Personal Information we have collected about you;
o the categories of sources from which the Personal Information is collected;
o our business or commercial purpose for collecting or selling Personal
Information;
o the categories of third parties with whom we share Personal Information;
o the specific pieces of information we have collected about you;
o the categories of Personal Information about you, if any, that we have
disclosed for monetary or other valuable consideration and the categories
of third parties to which we have disclosed the information, by category or
categories of Personal Information for each third party to which we
disclosed the Personal Information; and
o the categories of Personal Information about you that we disclosed for a
business purpose.
2. Right to Deletion of Personal Information. You may have the right to
request that we delete Personal Information about you that we have collected from you.
3. Right to Opt Out. You may have the right to opt out of the sale of your
Personal Information. Select Do Not Sell My Info to be directed to an interactive form
through which you may submit an online request to opt-out. To opt-out of collection of
information by analytics, advertising, and social media partners, you can use our
preferences management tool by contacting us here privacypolicy@tram.global, and
also visit the opt-out tools provided by the Network Advertising Alliance and the Digital
Advertising Alliance.
4. Right to Non-Discrimination.We may not discriminate against you
because of your exercise of any of the foregoing privacy rights, or any other rights under
the California Consumer Privacy Act, including by:
● Denying you goods or services;
● Charging different prices or rates for goods or services, including through the use
of discounts or other benefits or imposing penalties;
● Providing you a different level or quality of goods or services; or
● Suggesting that you will receive a different price or rate for goods or services or a
different level or quality of goods or services.
We may, however, charge different prices or rates, or provide a different level or quality
of goods or services, if that difference is reasonably related to the value provided to us
by your Personal Information.
5. Requests to exercise your rights. You may request to exercise these rights
by:
● Submitting a request privacypolicy@tram.global .
● Calling us toll-free at # (800) 402-6445
As required or permitted under applicable law, please note that we may take steps to
verify your identity before granting you access to information or acting on your request
to exercise your rights. We may limit our response to your exercise of the above rights
as permitted under applicable law.
6. Agent Authorization. You may designate an authorized agent to request
any of the above rights on your behalf. You may make such a designation by providing
the agent with written permission, signed by you, to act on your behalf. Your agent may
contact us to make a request on your behalf. Even if you choose to use an agent, as
permitted by law, we may require verification of the agent’s authorization to act on your
behalf, require you to confirm you have authorized the agent to act on your behalf, or
require you to verify your own identity.
F. Do Not Track. Please note that our Services are not designed to respond to “do
not track” requests from Web browsers.
11. SPECIAL NOTICE FOR INTERNATIONAL USERS
A. Location of Data. Our Services are located and operated in the United States.
The Personal Information that you provide to us is stored on servers located in the
United States. If you are located in another jurisdiction, you should be aware that in
order to provide the Services to you, we must transfer your Personal Information to the
United States where it will be stored and processed in accordance with this Privacy
Policy. By using the Services, you consent to such collection, storage and processing in
the United States. The United States and other jurisdictions may not afford the same
level of data protection as considered adequate in your own country. We will take
commercially reasonable steps to protect your Personal Information.
If you do not consent to such transfer, you may not use the Services. If you choose to
access and use the Services from outside the United States, you acknowledge that you
are doing so on your own initiative, at your own risk, and are responsible for compliance
with applicable laws.
B. Additional Disclosures for European Data Subjects. If we are subject to the
General Data Protection Regulation (“GDPR”) or the UK General Data Protection
Regulation (“UK GDPR”), the legal bases for the processing of your Personal
Information are:
● You have given us consent by agreeing to abide by our Privacy Policy and Terms
and by continuing to access the Services;
● Processing is necessary for us to perform a contract with you;
● Our prevailing legitimate interest to provide the Services, improve your overall
customer experience and achieve the purposes set out above or in our Terms;
and
● Processing is necessary for us to comply with legal obligations.
Certain users may be considered “data subjects” for whom the processing of Personal
Information is subject to the GDPR or the UK GDPR (each, a “Covered Person”).
Covered Persons have the rights described in sections (1) through (4) below:
1. Right of access, rectification, erasure, and restriction of processing: You
may obtain access to your Personal Information stored by us. If we process or use your
Personal Information, we shall endeavor to ensure, by implementing suitable measures,
that your Personal Information is accurate and up to date for the purposes for which it
was collected. If your Personal Information is inaccurate or incomplete, you may obtain
the rectification of such Personal Information. You may obtain the erasure or restriction
of processing of your Personal Information in situations where no legitimate business
purpose exists, or the further storage is unnecessary.
2. Right to data portability: You may receive the Personal Information that
you have provided to us, in a structured, commonly-used, and machine-readable format
or transmit this information to another controller.
3. Right to object: You may object, on grounds relating to your particular
situation, to the processing of your Personal Information. To the extent your Personal
Information is processed for reasons other than direct marketing, you understand and
agree that we have compelling legitimate reasons for information processing, such as
providing access to our Services. You may use ad-blocking software to limit information
capture and usage. Making a request does not guarantee that the request will be
honored.
4. Right to withdraw consent: If you consented to the collection or processing
of your Personal Information, you may withdraw your consent without affecting the
lawfulness of processing based on consent before its withdrawal.
To exercise any of these rights, please contact us by email at
privacypolicy@tram.global
12. CHANGES TO OUR PRIVACY POLICY.
We reserve the right to amend our Privacy Policy
at any time and as needed. When we make changes to this Privacy Policy, we will post
the updated Privacy Policy on our Site and update the Privacy Policy’s effective date.
Your continued use of any of the Services following the posting of changes constitutes
your acceptance of such changes.
13. CONTACT US.
If you have any questions about the Services, or this Privacy Policy,
please contact us at:
privacypolicy@tram.global
