PRIVACY POLICY

 Last Updated and Effective Date: December 18, 2024

This Privacy Policy describes how TransGo LLC (“we,” or “us”) collects, uses, discloses, and processes your Personal Information (“you” and “your”), as well as rights that you may have regarding that information.  We reserve the right to change this Privacy Policy at any time.  If we change our Privacy Policy, we will post an updated version on this website.  Please check back periodically to see if our Privacy Policy has been updated.  Updates to the Privacy Policy will be referenced by the “Last Updated and Effective Date” date shown above.

1. Definitions.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person, household or device. “Personal Information” does not include: (a) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (b) information that is deidentified or aggregate information.

“Sensitive Personal Information” means Personal Information that reveals information such as: (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial, ethnic, or national origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; (e) the contents of an mail, email, and text messages unless we are the intended recipient of the communication; (f) genetic data; (g) information about a child; (h) biometric information for the purpose of uniquely identifying an individual; (i) mental health, physical health and pregnancy; (j) sex life or sexual orientation, including status as a trans or nonbinary individual; and (k) status a crime victim. Sensitive Personal Information that is publicly available is not considered Sensitive Personal Information or Personal Information.

Please note that various jurisdictions may use different terms.  For example, some jurisdictions use the terms “personal data” or “sensitive personal data”.  Moreover, some jurisdictions do not consider some of the Personal Information listed in the Sensitive Personal Information definition above as Sensitive Personal Information.

2. Information We Collect, the Categories of Source of Collection and the Purpose for Collection.

Set forth below are the categories of Personal Information we collect and that have collected in the preceding 12 months, the categories of sources from which the Personal Information was collected and the business or commercial purpose for such collection.  Please note that we may not collect all of the information referenced below regarding you and we may not use your Personal Information for all purposes set forth in this Privacy Policy.

Category of Personal Information	What We Collect	Categories of Sources from which Personal Information Collected	Business or Commercial Purposes for Collection
PERSONAL INFORMATION
Personal Identifiers	Real name Postal address Online identifier Internet protocol address Email address Telephone number Account name Credit card number (We use PayPal to process payments securely. Payment information is handled by PayPal, and we do not store or retain any payment card details on our servers)	Directly from you Automatically, such as when you visit our website (e.g., cookies and tracking technologies)* Our service providers	To facilitate account creation, authentication, administration and secure access to our resources To provide information regarding our products and services that you have requested To provide access to our technical resources To improve and personalize our website and user experience To communicate with you regarding updates, promotions, or customer service inquiries To provide tailored technical information relevant to user interactions To check for malicious activity and to protect our website from specific kinds of attacks
Commercial Information	Vehicle information, including vehicle identification number, year, make, model, and engine size Records of personal property, products or services purchased, obtained, or considered Other purchasing or consuming histories or tendencies. Type of work performed Quantity of services performed	Directly from you	To provide our services To communicate with you when you contact us To communicate with you regarding updates, promotions, or customer service inquiries
Internet Information	Electronic network activity information Browsing history Search history Information regarding interaction with a website, application, or advertisement	Automatically when you use our website	To improve and personalize our website and user experience To check for malicious activity and to protect our website from specific kinds of attacks
Geolocation Data	Internet protocol address	Automatically when you use our website	To improve and personalize our website and user experience To check for malicious activity and to protect our website from specific kinds of attacks
Audiovisual Information	Your picture	Directly from you	To customize your profile with us
SENSITIVE PERSONAL INFORMATION
Account Information	Username Password	Directly from you	To facilitate account creation, authentication, administration and secure access to your account with us

* See the section entitled Cookies below.

We only use Sensitive Personal Information for purposes disclosed herein.  We do not use or disclose Sensitive Personal Information for purposes other than those specified herein.

We also collect aggregated, de-identified or anonymous data that does not identify individual consumers.  We collect this information for various purposes such as statistical or demographic data for legitimate business purposes not prohibited herein or by law.  We commit to maintain and use such data without attempting to re-identify the data. 

3. Cookies and Tracking Technologies.

A cookie is a small file of letters and numbers that is stored on your browser or the hard drive of your computer.  Cookies contain information that is transferred to your computer’s hard drive. We and our service providers and partners use cookies or similar technologies, such as web beacons and tracking pixels to analyze trends, administer our website, personalize content and ads, track users’ movements around our website to provide you with the most relevant browsing experience, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or of the service we provide as some of our features or services may not function properly without cookies.

We use the following cookies on platforms:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Functionality/preference cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Statistical, analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Marketing/targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it and on third-party websites more relevant to your interests.
• Third party cookies. These cookies are placed on your device by a website from a domain other than our website.  Please note that various third parties may also use these types of cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.
  • We use third party advertising companies to place ads. We do this by allowing our advertising and social media partners to place their cookies on a browser of an individual who visits our site.  The data received by our third party advertising partners allows them to measure the effectiveness of such advertising and to provide advertisements on other websites about our services which are tailored to your interests.
  • We use Google Analytics to ensure website functionality and improve our website and services. The information that is collected by Google Analytics is aggregated.  Google Analytics is owned and controlled by Google LLC.  Data collected by Google is subject to its privacy policy.  To learn how Google uses data related to website analytics, please click here: https://policies.google.com/technologies/partner-sites.  You may opt-out of Google Analytics by installing the Google Analytics browser add-on, available here:  https://tools.google.com/dlpage/gaoptout.

In addition, we may use web beacons and pixels, which are images that can be placed in web pages and some forms of email.  These technologies can be used to deliver cookies and to collect information about your use of the site.  Finally, we may also collect information through tracking pixels. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel or Javascript tag) that is placed on a web page and, in combination with a cookie, allows us to collect information regarding the use of the page of the site that contains the tracking pixel.  We may use tracking pixels to trigger ads on participating websites based on activity tracked from the browser on a device used to visit our site.  Other entities may have access to some of this information.

Emails that we and our service providers send may include similar technologies that provide us with information related to whether you’ve opened an email or clicked on a link contained in an email.  More information on how to unsubscribe from our marketing emails is found below.

If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this.  Please bear in mind that deleting and blocking cookies may have an impact on your user experience as parts of the site may no longer work. Unless you have adjusted your browser settings to block cookies, our system may issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

By using our website and services you affirmatively agree to the use of cookies disclosed in this Privacy Policy.

4. Personal Information We Disclose and the Purpose for It.

Selling and Sharing (for Targeted Advertisement) of Personal Information

We do not sell your Personal Information.  We also do not share with others Personal Information we have collected from you for cross-context behavioral advertising (targeted advertising).

 

Disclosure of Personal Information to Service Providers

We disclose and have disclosed in the preceding 12 months Personal Information outlined above (i.e., Identifiers, Commercial Information, Internet Information, Geolocation Data, Audiovisual Information and Account Information) to our service providers and contractors for the following business purposes.  

• Security and Fraud Detection: We disclose Personal Information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
• Functionality & Debugging: We disclose Personal Information to engage in debugging to identify and repair errors that impair existing intended functionality.
• Services on Our Behalf: We disclose Personal Information in order to receive services performed on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing other services on our behalf.
• Advertising and Marketing Services: We disclose Personal Information to provide advertising or marketing services on our own behalf.
• Research & Development: We disclose Personal Information for internal research related to technological development and demonstration.
• Quality Control & Improvement of Products and Services: We disclose Personal Information to verify, maintain, and improve our products and services.

As Necessary:  We may also disclose Personal Information, as necessary: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.  We may also use Personal Information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

5. Our Retention Policy – How Long We Keep Your Personal Information.

We will retain each category of your Personal Information identified above for an amount of time that is reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention of Personal Information pursuant to any applicable contract, law or regulation.  To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Data Security.

We implement technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the Personal Information we collect, use, process and disclose. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Information.  We evaluate these measures on a regular basis to help ensure the security of the processing.  Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

7. Email Communications.

You may unsubscribe from our marketing communications by clicking the “unsubscribe” link found in our commercial emails we send, or by sending us a request to communications@transgo.com.  If you opt-out of receiving marketing email communications, we may still send you email messages related to specific transactions with us.  Unsubscribing yourself from our marketing communications will not affect our service to you.

8. Children.

We do not direct our websites or applications to children under thirteen (13) years of age.  We do not knowingly collect information from persons under 13 years of age or provide any Personal Information from such persons to any third party for any reason whatsoever.  We do not allow persons known to be under 13 years of age to receive direct marketing communications from us.  No information should be submitted to our website or applications by persons under 13 years of age.  When appropriate, we may ask you to indicate your date of birth to verify compliance with the age requirements set forth herein.

9. Video Content.

Our website may include content that is governed by the Video Privacy Protection Act (“VPPA”).  Some of the cookies and other tracking technologies that we have disclosed above may provide to others access to your personal information (or personally identifiable information as that term is used under the VPPA).  To the extent that the VPPA applies to our website, or any content on our website, by using our website you explicitly consent to our practices, including those that relate to video contents or otherwise governed by the VPPA.

10. Consumer Rights.

Your Rights if You Are a Resident of California  

California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and related regulations (CCPA).  Your right to submit certain requests as a California resident are described below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

• Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of Personal Information we have collected about you; (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting Personal Information; (4) the categories of parties to whom we disclose Personal Information; and (5) the specific pieces of Personal Information we have collected about you.  You also have the right to know the list of all third parties, if any, to whom we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes. You may submit a request by calling us at (888) 722-1491 or emailing us at communications@transgo.com.
• Right to Know Personal Information Disclosed.  You have the right to request that we disclose to you: (1) the categories of Personal Information that we collected about you; and (2) the categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.  You may submit a request by calling us at (888) 722-1491 or emailing us at communications@transgo.com.
• Right to Request Deletion of Your Personal Information.  You have the right to request that we delete your Personal Information, subject to a number of exceptions.  Following receipt of a request, we will let you know what, if any, Personal Information we can delete from our records.  If we cannot delete all of your Personal Information, we will let you know the reason.  You may submit a request by calling us at (888) 722-1491 or emailing us at communications@transgo.com.
• Right to Correct Inaccurate Information.  You have the right to request that we delete your Personal Information.  However, there a are number of situations where you do not have the right that we delete your Personal Information.  For example, you cannot request that we delete your Personal Information if it is reasonably necessary for us to complete the transaction for which the Personal Information is collected or provide the services that you have requested or reasonably anticipated by you within the context of our ongoing business relationship, or to otherwise perform a contract between us.  We also will not delete your Personal Information from our backup systems to the extent permitted by the CCPA.  Following receipt of a request, we will let you know what, if any, Personal Information we can delete.  If we cannot delete all of your Personal Information, we will let you know the reason.  You may submit a request by calling us at (888) 722-1491 or emailing us at communications@transgo.com.
• Right to Opt-Out of the Sale and Sharing of Your Personal Information.  As noted, we do not sell your Personal Information and do not share your Personal Information for cross-context behavioral advertising.  As such, this right does not apply to you.
• Right to Limit the Use of Your Sensitive Personal Information.  You have the right to limit the use of Sensitive Personal Information under circumstances.  You do not have this right where we collect, use or disclose your Sensitive Personal Information for the following purposes:  (i) to that use which is necessary to perform the services or provide the goods reasonably expected by you; (ii) to help to ensure security and integrity; (iii) to perform services on our behalf; (iv) to undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us; and (v) to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.  You also do not have the right to limit the use of Sensitive Personal Information where we only collect or process Sensitive Personal Information without the purpose of inferring characteristics about you.  Given the purpose for our collection, use and/or disclosure of your Sensitive Personal Information, this right does not apply to you.
• Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.

Your Rights If You Are a Resident Other than California

Depending on your state of residency, you may have certain rights related to your Personal Information.  California residents should refer to the “Your Rights if You Are a Resident of California” section above and for a description of California specific rights and Nevada residents should refer to the “Nevada Privacy Notice” below.

You may submit a request by calling us at (888) 722-1491 or emailing us at communications@transgo.com.  Please note that not all of these rights may be applicable to you, these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

• The Right to Know: You have the right to know whether we are processing your Personal Information, and, if you are a resident of Oregon, the categories of your Personal Information we have processed and the specific third parties to which we have disclosed it.
• The Right of Access: You have the right to access your Personal Information, and to obtain a copy of it in a readily usable format, if feasible.
• The Right to Correct Inaccuracies: You may request that inaccuracies in your Personal Information be corrected.
• The Right to Delete: You have the right to request that your Personal Information be deleted, except in cases where retention is required by law or contractual obligation.
• The Right to Data Portability: You have the right to obtain a copy of your Personal Information in a portable and, if feasible, readily usable format.
• The Right to Opt-Out: You may elect to prevent your Personal Information, to the extent applicable, from being:
  • Used in targeted advertising (as noted this right does not apply given our current practices);
  • Sold (as noted this right does not apply given our current practices);
  • Used for automated decision making or profiling purposes that may produce legal or similarly significant effects (this right does not apply given our current practices.

[To the extent we use profiling, you have the right to (1) question the result of the profiling, (2) be informed of the reason the profiling resulted in the decision, and (3) if feasible, be informed of actions you could have taken to result in a different decision. Additionally, you have the right to review the data used in the profiling, and if such data was inaccurate, correct the data and have the profiling decision reevaluated.]

• The Right to Non-Discrimination for Exercising Your Rights: If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.
• Rights Regarding Sensitive Personal Information: Depending on your state of residency, we will either: (a) not process your Sensitive Personal Information without first presenting you with clear notice and an opportunity to opt out of the processing; or (b) not process your Sensitive Personal Information without obtaining your consent.  You have the right to withdraw your previous consent and opt out of further processing of your Sensitive Personal Information.
• Rights Regarding Information We Share with Third Parties: If you are an Oregon or Minnesota resident, you may have the right to obtain, at our option, either a list of the specific third parties to whom we have disclosed your Personal Information. If you are a Delaware resident, you may have the right to obtain a list of the categories of third parties to whom we have disclosed your Personal Information.

Furthermore, if we have actual knowledge that you are 13 years of age and not older than 18 years of age, we will not without your consent process your Personal Information for the purposes of targeted advertising, profile you in furtherance of decisions that produce legal effects or effects of similar significance, or sell your Personal Information.

Verification of Consumer Requests

For all other requests, you may submit a request via email to communications@transgo.com or by calling us at (888) 722-1491. When you make a request to know, delete and/or correct, to help protect your privacy and maintain security, we will take steps to verify your identity.  Our verification procedure may differ depending on whether you have an account with us or not and the request you are making.  The following generally describes the verification processes we use:

• Password Protected Accounts.  If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting or deleting data.  If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know, correct or delete.

• Verification for Non-Accountholders.  If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
  • For valid requests to know categories of Personal Information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
  • For valid requests to know specific pieces of Personal Information, right of access and right to data portability, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us.
  • For valid requests to correct or delete Personal Information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion.  We will act in good faith when determining the appropriate standard to apply.

If there is no reasonable method by which we can verify your identity, we will state so in response, including an explanation of why we have no reasonable method to verify your identity.

We may also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative.

If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the authorized agent permission to submit the request.

There may be situations where we cannot grant your request.  For example, if you ask us to delete Personal Information that we are obligated to keep to comply with applicable law we may not be able to fulfill some or all of your request. We may also decline to grant your request where our use of your Personal Information serves a legitimate purpose such as for security purposes.  Your request may also be denied if it compromises the privacy of others, is overly repetitive or extremely burdensome to fulfill.

We will respond to valid requests to know, requests to delete and / or delete no later than 45 calendar days.  If we cannot verify your request within 45 days, we may deny your request.  If necessary, we may take up to an additional 45 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.

Valid requests under “Right of Access” and “Right to Data Portability” will be transmitted securely. If we cannot fulfill your request, we will notify you of that decision and the reasons why within 45 days. At that point if you believe our decision was in error, you may have the right to submit an appeal using the method(s) above.  If the result is the same, you can also seek assistance and/or redress from your state attorney general.

11. Nevada Privacy Notice.

Nevada law provides that Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, and online service activity.  Our uses of your Personal Information are not sales under Nevada law, so no opt-out right applies.

12. How to Contact Us.

If you have any questions or concerns about our privacy policies and practices, please feel free to contact us by calling us at (888) 722-1491, emailing us at communications@transgo.com or by mail at 2621 Merced Avenue, El Monte, CA, 91733.