We respect your privacy and are committed to protecting your personal information. This policy explains what information we collect about the Primary Driver and Secondary Driver under a Subscription Agreement with Subaru Just Drive (Primary and Secondary Driver, collectively, are referred to in this policy as “you” and “your”), how we collect such information, the measures we take to keep your information secure, and how we use it. We also explain the options you have regarding your personal information. When you request services from us, access our website, utilize our mobile “apps” or otherwise interact with us, you consent to our collection, retention and use of your personal information in the manner described in this policy.
Who We Are: We are Subaru Just Drive. This policy governs any information that Subaru Just Drive receives from you or that we share with third parties or affiliates who are engaged by or working with us in connection with the provision of our products and services under a subscription agreement between you and Subaru of America.
What We Collect: We collect the personal information we need to provide the services you request from us, for our operational and marketing uses listed in this policy and for such other purposes as you authorize. By subscribing for our vehicles and using our services and providing personal information to us, you consent to our use and disclosure of your information as described and for the purposes listed in this policy.
Sources: We collect your information directly from you, through various channels including our website, mobile app, computer systems and in-vehicle and in-equipment technology, and from companies involved in our provision of services to you, including our licensees and third party providers.
Storage: We retain personal information about our subscribers for as long as needed for the purposes for which it was collected and to comply with applicable laws.
Security Measures: We maintain commercially reasonable physical, procedural and electronic safeguards to protect your personal information.
Contact Us: We hope this policy answers your questions about our collection and use of your personal information. If you have any questions, please contact us by following the instructions in the Contact Us section below.
Changes: We may change this policy from time to time. The policy was last updated on May 29th, 2018 .
Scope of Policy
This policy covers the personal information we collect about you in connection with our vehicle subscription business and services that identify you as an individual. It does not address data that does not personally identify you as an individual, for example, but without limitation, aggregated anonymous data, computer operating systems, personal preferences, vehicle identification numbers, etc. We are free to use information that does not identify you as an individual as we wish. This policy does not apply to information collected by third party social networks (such as Facebook), mobile device manufacturers, third party “mobile apps”, wireless service providers, internet service providers or the operators of any networks through which you may interact with us and we expressly disclaim any responsibility for the data collection, privacy or data security practices of those entities. This policy only applies to personal information we collect through our pages (those with a direct link to this policy) and does not apply to any third party pages or pages of our affiliates or licensees.
When you request services from us, operate a vehicle or equipment with in-vehicle or in-equipment technology, access our websites, utilize our mobile “apps” or otherwise interact with us, you consent to our collection, retention and use of your personal information in the manner described in this policy and accept the risks outlined in the Security Measures section below.
Personal information means information that identifies you as an individual, or that we can combine with readily available information to identify you as an individual. We collect a range of information about you from a variety of sources as described in this policy.
Use of Personal Information
The principle purposes for which we collect and store your personal and financial information are to process your application and subscription agreement, allow you to reserve and use our vehicles and services, authorize payment, bill you, respond to your inquiries, improve our products and services and maintain your account with us. The examples we provide throughout this policy are illustrative rather than a complete list of our practices.
Collection of Information
When you visit our websites or apps, we collect information about your activities such as the pages you visit or the ads or links you click on. When you are signed in to our mobile apps, you will be identified to us by your account email and/or phone number. Information about tracking technologies and cookies used on our website are described in more detail below.
We collect information that you voluntarily submit to us, such as:
Name, address and contact details, including telephone and mobile number, and email;
Date and place of birth, passport number and driver's license number and a copy of your driver's license;
Employer(s) name and address;
Credit card information;
Driving record and accident history;
Location data such as geographic location of electronic devices used to contact us or to access our mobile "apps" or of the vehicle you are using;
Information regarding the vehicles you subscribe for and use, and the operation of our vehicles during your subscription period;
Charges you incur and other information relating to your transactions;
Information transmitted by your computer's browser software; and
Information about your credit history or other publicly available information about you from consumer reporting agencies.
Your telephone calls, text messages and email correspondence with us may be recorded or monitored for quality control, training and similar purposes. By using these communication methods you are consenting to the recording or monitoring of your calls and emails with us and to our use of the information you provide us for the purposes described in this policy.
If you subscribe with us, we collect personal and financial information as you proceed through the stages of our online application, subscription agreement and reservation process. In addition to your name and contact information, we will also collect your driver’s license number, the jurisdiction in which you are registered as a licensed driver, credit card or other payment information, and other information needed to process your application and transaction requests. We may also collect information such as your driving record from regulatory bodies where you live, and from third parties. This information is used to process your subscription application and, if you are approved, for the purposes described below. From time to time we will send newsletter emails. To unsubscribe from our newsletters please use the opt-out in the newsletter email footer.
If you use our vehicles and services, we collect information about the vehicles’ use and your use of our services. This may include details about your vehicle reservations, the dates, times and locations of use, mileage, driving performance, accidents and other data. We use this information to bill you, respond to your inquiries, ascertain whether you are in compliance with our polices and rules, provide and improve our products and services and maintain your account with us, and to provide content and offers that we think may be of interest to you.
Our vehicles may be equipped with vehicle tracking and other technologies. We use Global Positioning Systems (GPS), a network of satellites that allows us to determine the location of our vehicles. This information is transmitted to us or our designee and can be stored for extended periods. We use this information for a variety of important purposes. For example, we use GPS data to help you find our vehicles, to provide roadside assistance, to ensure that a vehicle is available at the place and time you have reserved, to ensure that the vehicle is not driven to unauthorized locations and to locate a lost or stolen vehicle. We also maintain in-vehicle and in-equipment technologies to track and monitor performance of our vehicles and to assist us with ensuring that our vehicles are used only in accordance with applicable laws and our rules and policies. By entering into the subscription agreement you are consenting to our use of GPS and other technology for vehicle location and monitoring purposes. Disabling, disconnecting or destroying any such technology device or equipment is strictly prohibited.
We also gather personal information about you from a variety of other sources, including:
Transactions you complete with us and our vendors and licensees, including options you take, charges you incur and any incidents or accidents that may occur;
To the extent you have made such information available, from third party social networks;
Consumer and other reporting agencies; and
Other companies that have business relationships with us, such as our licensees, affiliates and business partners, including roadside assistance and other service providers and insurance companies.
Where and How Long We Hold Personal Information
We utilize servers in various locations throughout the United States. By subscribing for and using our vehicles and services, you consent to the transfer of your personal and financial information to other locations within the United States for the purposes described in this policy.
We will use your information for as long as needed to provide you services or as long as required under applicable laws. Please contact us if you wish to cancel your account and request that we no longer use your information to provide you services. We will retain your information for as long as we believe appropriate for the purposes for which it was collected and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Where We May Share Your Personal Information
Except as described in this policy, we will not share your personal information with third parties outside our group of affiliated companies unless it is necessary to provide our services, verify information you provide to us, fulfill a transaction you have requested, or in other circumstances with your consent. We do however disclose your personal information within our related company group and to contractors, advisors, consultants and service providers acting on our behalf or under our instructions, including for purposes relating to the operation, maintenance, administration, improvement, and oversight of our services, websites and advertising services, or to fulfill your requests for information or service.
If you subscribe for our vehicles and services, some of the information you supply must necessarily be shared with regulatory bodies where you live and/or service providers we utilize to obtain your driving record from such regulatory bodies. In addition, if you are associated or affiliated with another primary account, the primary account holder or administrator of that account may have access to limited information regarding your use of our services.
We may disclose your personal information in connection with a corporate transaction, proceeding, or reorganization involving the business activities for which the information is maintained. In the event that ownership of our business was to change as a result of a merger, acquisition, sale of assets or transfer to another company, your personal information may be transferred. If such a transfer results in a material change in the way your personal information is used, we will provide notice about the choices you have to decline to permit such a transfer.
We may disclose your personal information, including location/GPS data and data gathered from in-vehicle and in-equipment technologies, in response to legal process (for example, a court order, search warrant or subpoena) or requests from law enforcement authorities; in other circumstances in which we believe our services, our vehicles or our technology are being or have been used in violation of applicable law or otherwise in the commission of a crime; when we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; when necessary to protect our rights or property (or those of third parties); and as further described below in Protective and Legal Uses.
To Provide You Services
We will share your personal information among our employees and affiliated companies and employees, our representatives and agents, our licensees and vendors, and other companies that we engage in business with, to provide services to you, including to:
Fulfill your vehicle subscription and make your reservations for alternate vehicles;
Process and/or confirm your transactions;
Provide you with enhanced services, such as services provided in connection with our membership programs and similar services;
Provide you services in connection with your use of our vehicles; such as navigation assistance or roadside emergency assistance;
Provide you services in connection with your use of our vehicles; such as navigation assistance or roadside emergency assistance;
Provide you with customer assistance;
Bill and collect amounts owed in connection with your subscription and use of our vehicles and services; and
For customer satisfaction and market research purposes to help us improve our services.
To Communicate With You
We may use your personal information to communicate with you, including with regards to:
Your subscription or any other transaction(s) with us;
Your status in our membership program(s); or
Changes to the terms or features of your subscription or any policy or rule related thereto.
By entering into a subscription agreement to use our vehicles and services and by contacting us with your mobile telephone/device or providing us information regarding such mobile telephone/device, you give us your consent to call you on or send text messages to your mobile telephone/device. You also consent to our use of auto-dialers and pre-recorded messages in connection with any such telephone call or text message, including calls or texts to mobile telephone numbers. We will not charge you for such calls or texts, although you may be charged by your mobile service provider to which you subscribe.
Disclosure To Companies You Use
We will also share your information with companies you use in connection with your subscription, including:
Your credit card provider and other companies that process your charges;
Any company or organization that is paying all or part of your charges; and
Any service provider you use, such as a repair provider, insurance company or other vendor or provider related to any aspect of your subscription or use of our vehicles.
Protective and Legal Uses
We may use, share and disclose your personal information for legal reasons as we believe necessary or appropriate, including:
Under applicable law, including laws outside your state or country of residence;
To process, handle or otherwise respond to claims for damages, including claims or demands for bodily injury or property damage;
To enforce our policies and rules and the terms and conditions of your subscription;
To recover our vehicles, equipment or any monies due, such as through debt collection agencies;
To comply with legal process and to respond to requests from public and government authorities;
To protect our operations, rights, privacy, safety or property, and/or that of our subsidiaries, you or others; and
To allow us to pursue available remedies or limit the damages that we may sustain.
We may use personal information to present offers to you on our behalf and on behalf of our affiliates and business partners, but we do not share your personal information with those parties for such purposes. If you do not want us to send you promotional emails, please adjust your settings or utilize our “unsubscribe” feature in the footer of such emails.
Accuracy of Your Personal Information
With your assistance, we strive to ensure your information is accurate, current and complete as necessary for the purposes for which we use it. If you are a subscriber, you can review and correct personal information by navigating to the relevant section of our app or by contacting us.
As you may be aware, there is no completely secure method of transmitting or storing information and data. Although their physical characteristics are different, postal mail, telephone calls, text messages, faxes and transmissions over the Internet or wireless networks all present possibilities of loss, misrouting, interception and misuse of the information and data that is transmitted.
We try to strike a balance between the security of your information and your convenience. As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative.
For example, but not limitation, we may send you an e-mail or a text message in unencrypted form (i.e., instantly readable) because many of our customers are unable to access encrypted (i.e., coded) e-mail or messages. This means that our message, if misrouted or intercepted, could be read more easily than encrypted messages. For this reason, please do not include confidential information, such as your credit card number, in any e-mail or text you send to us or on any posting you make to a public area of a third party social network page, especially since any such posting immediately becomes public.
We take proactive measures to protect against the loss, misuse and unauthorized access or disclosure, alteration and destruction of your personal data by maintaining commercially reasonable physical, procedural and electronic safeguards to protect your personal information, including:
Restricting access to personal data to our employees on a "need to know" basis;
Destroying confidential personal information after it is no longer needed;
Enforcing policies and procedures for our employees in their handling of personal data; and
Using technologies designed to safeguard data during its transmission, such as SSL encryption for the data you provide on our websites and apps. In particular, we adhere to the appropriate standards for PCI compliance.
We have established safeguards to prevent unauthorized access to or misuse of your personal information, but cannot guarantee that your personally identifiable information will never be disclosed in a manner inconsistent with this policy (for example, as a result of unauthorized acts by third parties that violate applicable law or our policies and those of our affiliated providers). We may require a password to help verify your identity before granting access or making corrections to any of your personal information. It is your responsibility to safeguard your password, which you should never disclose to a third party. If you contact us by phone, we will ask you to verify certain information related to your account before providing any access to personal information.
Changes to Our Policy
We reserve the right to change this policy at any time, so it is advisable that you periodically review this policy. Changes to this policy will be announced on our website or through similar means and all amended terms shall automatically be effective when posted (or as indicated in our posts).
Subaru of America
Your Privacy and Use of Our Website
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Third Party Links
Do Not Track
The Subaru Just Drive website does not respond to “Do Not Track” signals at this time.
Information Collected From Third Parties