Last Updated: October 15, 2018
I. Information We Collect
A. Information You Provide to Us
Your Rider Profile Information. When you subscribe to the Services, you give us your name, address, email address, phone number, photograph, login name and password, and billing information (including any credit card numbers and expiration dates). As you utilize the Alto Platform and the Services, you may also provide preferences and settings that you enable for your Alto account. We may collect both “Personal Information” and “Anonymous Information” about you when you use the Alto Platform. Personal Information is information that can be used to contact or identify you, such as your full name, email address, phone number, payment method and profile picture, as well as information that is linked to such information. “Anonymous Information” is information that cannot be used to contact or identify you and is not linked to information that can be used to do so. It includes passively collected information about your activities on the Service, such as usage data, to the extent that information is not linked to your Personal Information.
You can access and browse certain portions of the Alto Platform without disclosing your Personal Information, although, like most website and mobile app providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system. Please note that you can choose not to provide us with certain information, but this will limit the features of the Service you can access and use. In order to utilize the Service, you must register with Alto through the Alto Platform.
Communications With Alto. We may collect information that you submit when you contact our Alto Rider support team, provide ratings or compliments for Drivers, or otherwise contact us. For example, when you contact our Alto Rider team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.
Demographic Data: When you respond to our Rider surveys, we may collect your responses as well as certain demographic information that you submit to us.
B. Information We Collect From You When You Use the Alto Platform or Services
ALL DRIVERS, RIDERS AND OTHER PERSONS WITHIN ALTO VEHICLES (INCLUDING MINORS) ARE RECORDED (WITHOUT AUDIO) AT ALL TIMES. PERSONS OUTSIDE OF AN ALTO VEHICLE BUT WITHIN ITS IMMEDIATE VICINITY MAY ALSO BE RECORDED.
Security Recordings. We record all persons (without audio) inside of our Alto Vehicles at all times through cameras equipped within our vehicles. Recordings of all trips initiated within Alto vehicles (each, a “Security Recording”) are uploaded to a secure cloud server through our third party service partner Samsara Networks Inc.. Each person that enters into an Alto Vehicle acknowledges and agrees (i) to be recorded at all times during a trip and its immediate aftermath and (ii) that Alto is the sole and undisputed owner of all Security Recordings.
We store Security Recordings to increase the safety and security of our Riders, Drivers and any other persons within our Vehicles. We do not review Security Recordings, except (i) upon the express written request of any Driver or Rider, (ii) if we believe in good faith that the safety or security of any person is at risk, or that a Security Recording contains a violation of our Terms of Service or any applicable law, or (iii) to manage, evaluate and/or analyze the Alto Services (including but not limited to Driver performance metrics).
Location Information. When you open the Alto app on your mobile device, we receive your location. We may also collect the precise location of your device when the app is running in the foreground or background. If you mark certain locations as favorites (or other designations, such as “Home”) we receive that information too.
We use your location information for multiple purposes, including matching you with nearby Drivers, determining drop off and pick up locations, and suggesting destinations based on previous trips. If necessary, our security team may use and share location information to help protect the safety of Alto’s Riders, Drivers or a member of the public. If you give us permission through your device settings or Alto app, we may also collect your location while the app is turned off to identify promotions or service updates in your area.
Device Information. We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.
Usage Information. To help us understand how you use the Alto Platform and to help us improve it, we automatically receive information about your interactions with the Alto Platform, like the pages or other content you view, your actions within the Alto app, and the dates and times of your visits.
Call and Text Information. We work with a third party partner to facilitate phone calls and text messages between our Riders and Drivers who we have connected for a ride. The information about these communications that we receive includes their date, time of the call or SMS message, the parties’ phone numbers, and the content of any SMS messages. For security purposes, we may also monitor and/or record the contents of phone calls made on the Alto Platform, such as those between Riders and Drivers. You hereby consent to the monitoring of the communications as outlined herein above.
Information from Cookies and Similar Technologies. We collect information through the use of “cookies”, tracking pixels, and similar technologies to understand how you navigate through the Alto Platform and interact with Alto advertisements, to learn how you utilize the Services, and to save your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Alto Platform. If you would like to opt-out of cookie collection, you should consult your web browser(s) to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may be missing out on certain features of the Alto Platform.
C. Information We Collect from Third Parties
Third Party Services. If you choose to register for Alto or otherwise link your Alto account with a third party’s service (such as Facebook), we may receive the same type of information we collect from you (described above) directly from those services.
Third Party Partners. We may receive additional information about you, such as demographic data, payment information, or fraud detection information, from our third party partners and combine it with other information that we have about you. We use Google Analytics to help us collect data on who is using our service, including Google Analytics Advertising Features (e.g., Demographics and Interests reporting).
Enterprise Programs. If your company, university, or organization participates in one of our enterprise programs, we may receive information about you, such as your email address, from your participating organization. We also may give your participating organization the opportunity to request a ride on your behalf, in which case they may provide us with your name, phone number, and the pickup and drop off location for your ride.
II. How We Use the Information We Collect
We use the information we collect from persons who access the Alto Platform or utilize the Services to:
- Register and administer your account;
- Provide, improve, expand, and promote the Alto Platform;
- Connect Riders to our Drivers;
- Analyze how Riders and Drivers use the Alto Platform;
- Communicate with you, either directly or through one of our partners, including for marketing and promotional purposes;
- Customize the Alto experience for each Rider;
- Send Riders text messages and push notifications;
- Facilitate Rider transactions and payments;
- Provide Riders with customer support;
- Find and prevent fraud;
- Comply with and enforce applicable legal requirements, relevant industry standards and our policies; and
- Respond to trust and safety issues that may arise, including auto incidents, disputes between Riders and Drivers, and requests from government authorities.
We may use Anonymous Information for the following purposes:
- Improve the Alto Platform and Services and customize your experience, such as by providing targeted useful features and promotions based on the type of services you seek.
- Aggregate the information collected via Cookies and similar technologies to use in statistical analysis to help us track trends, evaluate the effectiveness of our ads and analyze patterns.
III. How We Share the Information We Collect
A. Sharing Between Riders and Drivers
Sharing with Drivers. Drivers that have been matched with Riders for a ride are able to see basic information about the Rider, such as names, photo, and certain other information they have provided to Alto in order to facilitate our provision of the Services to Riders using the Alto Platform. Drivers see the pick-up location that the Rider has provided. Riders see our Driver’s vehicle information and real-time location as our Driver approaches the Rider’s pick-up location.
Although we help Riders and Drivers communicate with one another to arrange a pickup, we do not share your actual phone number or other contact information with other Riders. However, if you report a lost or found item to us, we will seek to connect you with the relevant person, including sharing actual contact information with your permission.
B. Sharing Between Alto and Third Parties
API and Integration Partners. If you connect to the Alto Platform through an integration with a third party service, we may share information about your use of the Alto Platform with that third party. We may share your information with our third party partners in order to receive additional information about you. We may also share your information with third party partners to create offers that may be of interest to you.
Third Party Services. The Alto Platform may allow you to connect with other websites, products, or services that we don’t have control over (for example, we may give you the ability to make a reservation at a restaurant from within the Alto app). If you use these services, we will provide the third party with information about you to allow them to provide the service to you (for example, we would give the restaurant your name and phone number to secure the reservation). We can’t control the privacy practices of these third parties, and we encourage you to read their privacy policies before deciding whether to use their services.
Enterprise Partners. If you participate in an enterprise program and charge a ride to your organization’s billing method or credits, we will provide your organization’s account holder with information about your use of the Alto Platform, including ride details such as date, time, charge, and pick up and drop off locations. If you create a Business Profile, at the end of each ride you will have the option to designate the ride as a business ride. If you do so, and your organization has a corporate account with Alto, we may share information about your use of Alto Platform with your organization including ride details such as date, time, charge, and region of the trip. If you change organizations, it is your responsibility to update your Business Profile with the new information. (Please remember to check and set your designation settings accordingly.) If you integrate your account with an expense platform we will share the ride details to your expense account.
Other Sharing. We may share your information with third parties in the following cases:
- While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets;
- If a government authority requests information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process;
- With law enforcement officials, government authorities, or third parties if we think doing so is necessary to protect the rights, property, or safety of the Alto community, Alto, or the public;
- To comply with a legal requirement or process, including but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures;
- If you signed up for a promotion with another Rider’s referral or promotion code, with your referrer to let them know about your redemption of or qualification for the promotion;
- With our insurance partners to help determine and provide relevant coverage in the event of an incident;
- To provide information about the use of the Alto Platform to potential business partners in aggregated or de-identified form that can’t reasonably be used to identify you; and
- Whenever you consent to the sharing.
IV. Your Choices
Email Subscriptions. You can always unsubscribe from our commercial or promotional emails, but we will still send you transactional and related emails about your account’s use of the Alto Platform. Each time you use the Alto Platform, you consent to receiving these emails.
Text Messages. You can opt out of receiving commercial or promotional text messages by emailing email@example.com stating explicitly and unambiguously your request to unsubscribe from commercial or promotional text messages and including the telephone number to which you desire your request to apply. You may also opt out of receiving all texts from Alto (including transactional or relational messages) by emailing firstname.lastname@example.org stating explicitly and unambiguously your request to unsubscribe from all text messages from Alto and including the telephone number to which you desire your request to apply, however, opting out of receiving all texts may impact your use of the Alto Platform. To re-enable texts at any time, you can email email@example.com stating your request to re-enable text messages from Alto and including the telephone number to which you desire your request to apply.
Push Notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Alto Platform (such as receiving a notification that your ride has arrived).
Rider Profile Information. While your name will always be shared with our Drivers, you can delete any additional information that you added to your Alto Profile at any time if you don’t want our Drivers to see it, however, your deleted information may be retained for a certain period of time until permanent deletion is processed in the Alto Platform.
Location Information. While you can prevent your device from sharing location information at any time through your Device’s operating system settings, Rider location is core to the Alto Platform and without it we can’t provide the Services to you.
Information Security. The security of your information is very important to us and will only collect personally identifiable information to the extent we deem necessary to serve you in view of our legitimate business purposes as set out above. We use Secure Socket Layer (SSL) encryption technology to protect the security of your online order information.
Any information stored by us is treated as confidential. All information is stored securely and is accessed by authorized personnel only. We implement and maintain appropriate technical, security and organizational measures to protect your Personal Information and Anonymous Information against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure. In the unlikely event of a security breach compromising your personally identifiable information, we will notify you within 72 hours of our becoming aware of its occurrence.
While we implement these and other security measures on our sites, please note that 100% security is not always possible. You play a role in protecting your information as well. Because your password permits access to your Personal Information and Anonymous Information, please keep your password secret and do not disclose it to others.
How can you opt-out or withdraw your consent? If after you opt-in, you change your mind, you may withdraw your consent for us to contact you for the continued collection, use or disclosure of your Personal Information, at any time, by contacting us at firstname.lastname@example.org stating your request to opt-out or withdraw your consent.
How can you correct or delete your Personal Information? You can request access to all your personally identifiable information maintained by us by sending an e-mail to us at the address listed below. Upon request we offer you the ability to have inaccuracies corrected in your personally identifiable information. You can have this information corrected by sending us an e-mail at the address listed below.
Alto Experience, Inc.
900 Dragon St, Dallas, TX 75207