Firefly: Our Privacy Policy

Firefly Systems Inc. (“Firefly,” “we,” “our,” and/or “us”) operates a street-level digital media network that delivers dynamic and useful content through rooftop advertising displays installed on taxis and rideshare drivers’ vehicles. We value your privacy, and this privacy policy (the “Privacy Policy”) explains how we collect, use, and share information. This Privacy Policy covers information collected through Firefly’s services, which includes information about the drivers who host Firefly displays, information about the Firefly partners who communicate through these displays, data collected from the displays, data we purchase from third party vendors, and data collected from users who interact with our website at https://fireflyon.com or our apps (collectively, our "Services"). Beyond this Privacy Policy, the use of our Services also is subject to our Terms and Conditions.

Information We Collect

Information Provided To Us. You provide certain personal information directly to us when you use the Services.

Registration and Profile Information. If you sign up to drive with us, we ask for information about you such as your first and last name, address, email address, phone number, driver’s license and vehicle information (which may include insurance information), Social Security number, and any other information you may provide on your W9 form. If you sign up to advertise with us, we ask for information about you such as your full name, company name, work email, and phone number.

Payment Information. If you sign up to drive with us, we ask for your bank account information, such as your bank name, account and routing number, in order to disburse payments to you. If you sign up to advertise with us, we may ask for your payment information, such as your credit card number, in order to provide our Services to you.

Communications. If you contact us directly, we may receive additional information about you. For example, if you contact customer support, we may receive your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

Information Collected From Our Advertising Displays. The rooftop advertising displays installed on taxis and rideshare drivers’ vehicles (“Advertising Displays”) collect the precise geolocation of the Advertising Displays in order to provide our Services and to serve relevant advertising.

Information Collected When You Interact With Our Services. We collect additional information when you use our website or apps:Analytics. We work with analytics providers such as Google Analytics to collect and process certain analytics data. Google provides some additional privacy options regarding Google Analytics Cookies described at www.google.com/policies/privacy/partners/.

Location Data Collected Through Our App. If you download the Firefly driver app and opt in to share your location data, your mobile device allows us to collect information regarding the location of your device by using GPS coordinates provided by your device (“Location Data”). The Location Data enables us to estimate the number of hours that the Advertising Display on your vehicle is turned on each day, which helps us determine your eligibility to participate in the Firefly driver program. If you no longer wish to participate in the Firefly driver program, you have the option to turn off the sharing of location data through the Firefly app.

Device and Log Information. We receive information about the devices and software you use to access our website, such as your device’s internet protocol (IP) address, web browser type, operating system version, and phone carrier and manufacturer.

Usage Information. We collect certain information about how you use and interact with our Services, such as the pages and content you view and click, and the dates, times, and duration of your visits or interactions with our Services to help us understand how you use our Services and to help us improve them.

Information Received From Third Parties. We receive additional information from third party sources that includes personal information about individuals that do not interact directly with our Services, such as mobile advertising IDs (MAIDs), IP addresses, and inferences drawn from this information. If you sign up to drive with us, we also may receive information from third party providers about your background and driving record. We purchase and process this data from third parties who have collected the information in compliance with applicable laws.

How We Use the Information We Collect

We store and process the information we collect for legitimate business purposes to:

- Provide, improve, expand, personalize, and promote our Services;

- Understand and analyze how you use our Services and how to make them more effective;

- Develop new products, services, features, and functionality;

- Serve relevant advertising;

- Communicate with you, either directly or through one of our partners, including for customer service and support, to provide you with updates and other information relating to our Services, and for marketing and promotional purposes;

- Send you text messages;

- Facilitate transactions and payments;

- Find and prevent fraud; and

- For compliance purposes, including enforcing our Terms and Conditions or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

How We Share the Personal Information We Collect

Service Providers. We share personal data for legitimate business purposes and with service providers who process it for us, based on our instructions, and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research, and surveys.

Advertising Partners. We share geolocation information collected from our Advertising Displays combined with personal information that we receive lawfully from third parties, and aggregate information, such as impression data estimating the number of individuals located within viewing distance of an advertisement, with our advertising partners so that they can understand their advertisements’ audience.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) ensure legal and regulatory compliance; (b) comply with law enforcement requests and legal process, such as a court order or subpoena; (c) protect your, our or others’ rights, property, or safety; or (d) respond to your requests. Please note: Our policy is to attempt to notify you of legal process seeking access to your information, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy or liquidation where the business will not continue as a going concern, receivership, sale of our assets, or transition of our Services to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We will continue to take measures to protect the confidentiality of personal information before transferring any personal information to a new entity.

Consent. We may also disclose your information with your permission.

Your Choices

You can unsubscribe from our newsletters or promotional emails via the link provided in the emails. Even if you opt-out of receiving newsletters or promotional messages from us, you will continue to receive administrative messages from us.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy will not apply to your activities or any information you disclose to these third parties.

Security and Data Retention

We are committed to protecting your information. Even though we take reasonable precautions to protect your data, because our Services are hosted electronically, we cannot guarantee the security or privacy of your information.We retain your personal data for as long as necessary to provide our services to you and comply with applicable law. You can request deletion of your personal data by contacting us at privacy@fireflyon.com.

Children’s Privacy

Children under the age of 13 may not sign up for our Services, use or interact with our Services, or otherwise provide us with personal information. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you may alert us at privacy@fireflyon.com.

Your California Privacy Rights

If you are a California resident, this Privacy Policy complies with the California Consumer Privacy Act (CCPA) requirement that we provide you with notice that you have a right to know about your personal information collected, obtained, disclosed or sold by Firefly, the business purpose for collecting the information, the specific pieces of information that we have collected, and the categories of sources we obtain this data from and with whom we share this data. California residents also have the right to opt-out of the sale of their personal information and may exercise this right at any time by contacting us at privacy@fireflyon.com or by completing the form located at https://www.fireflyon.com/personal-information.

To better protect you and your personal information, we will only respond to access or deletion requests that we have been able to properly verify through our authentication processes. To verify your identity, you will be asked to provide certain information, which may include your device’s mobile advertising ID, which we will use only to verify your identity and/or your authority to make the request.

You also may submit an access or deletion request through an agent that you have authorized to act on your behalf. Requests from authorized agents must be submitted via the same methods identified above. To protect your privacy, you may be required to verify your identity directly with us or provide evidence of an agency relationship.

You may request we delete the personal information we have about you by contacting us at privacy@fireflyon.com.You have the right to be treated without discrimination should you exercise these rights.To make a request under the CCPA or for any questions or concerns about our Privacy Policy or practices, please contact us at privacy@fireflyon.com.

Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through our Services, we will provide a more prominent notice (such as attempting to notify you through our Services, by email, or other communication).

Contact Us.

If you have questions about this Privacy Policy, please contact us at privacy@fireflyon.com.

Firefly Systems Inc.
1612 Remuda Lane, San Jose, CA 95112
United States of America

Effective Date: October, 9th 2020