Privacy Policy - FlexiVan

Flexi-Van Leasing, LLC
Last Revised: June 26, 2023

This Privacy Policy (“Privacy Policy”) describes how Flexi-Van Leasing, LLC (“FlexiVan”, “Company”, “we”, “us”, or “our”) collects and processes personal information, including online through www.flexivan.com and all other FlexiVan websites and mobile applications, and the provision of our services to FlexiVan’s customers that link to this Privacy Policy (collectively, the “Services”), and personal information about FlexiVan’s employees and vendors.

1. Personal Information That We Collect

Personal information or personal data is information, or a combination of pieces of information, that could reasonably allow you to be identified. We collect personal information from a variety of sources, including from you directly (e.g., when you provide your name, address, or contact information), from your devices, (e.g., data collected from cookies and similar technologies as described in our Cookies Policy below or when you use our website or applications), and information we collect about you from other sources, such as public records. Note that we and our service providers may automatically collect certain technical information from your computer or mobile device over time and across different websites when you use the Services.

If you use our Services, we may collect the following categories of personal information from and about you:

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers. We also collect chassis numbers, which may be considered personal information under applicable privacy laws.
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information about your interactions with websites, applications, or advertisements, including, but not limited to, interaction with our website or AIM360 application.
Geolocation data as inferred by your IP address, as it relates to your physical location or movements.
Call recordings for compliance, quality assurance, and training purposes.
Sensitive personal information, including personal information that reveals your driver’s license number, your account login, and your precise geolocation.
Professional or employment-related information: If provided voluntarily, such as job title or company information.
Inferences drawn from any of the information listed above: FlexiVan may derive certain information or draw inferences about your preferences, characteristics, behavior, or attitudes based on the collected data.

If you are a job candidate applying to join FlexiVan, or an employee of FlexiVan, we may collect the following categories of personal information from and about you:

Identifiers, such as name, title, home address, work and personal telephone numbers and email addresses, IP address, photograph, date of birth, employee identification number, social security number, driver’s license number, passport number, or other similar identifiers.
Personal Information categories described in California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, social security number, physical characteristics or description, address, telephone number, driver’s license number, passport number, state identification card number, education and employment history.
Protected classification characteristics under California or federal law, such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.
Internet activity, such as browsing history, search history, and information regarding your interaction with websites and applications.
Geolocation data, such as your physical location.
Professional or employment-related information, including past and current employment history.
Non-public education information (per the Family Educational Rights and Privacy Act) such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts and student financial information.
Sensitive personal information, such as your Social Security number, driver’s license number, state identification card information, and/or passport number, your business account logins (in combination with any required security or access code), passwords or other credentials allowing access to the account, your racial or ethnic origin, religious or philosophical beliefs, union membership, the contents of your business mail, emails and text messages.
Inferences drawn from other personal information, such as information about your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.
Additional employment-related information including:
- Date of birth, gender identity, nationality.
- Dependents, next of kin and emergency contact information, including details of relatives, guardians, associates, or authorized representatives (including legal representatives).
- Salary and compensation history, annual leave, pension, and benefits information, notice period.
- Start date (or desired start date) at FlexiVan.
- Location of employment or workplace (or desired location).
- Recruitment information (including copies of right to work documentation, references and other information included in a resume or cover letter or as part of the application process).
- CCTV footage and other information obtained through electronic means such as access key card records.
- Visual images and photographs required for business purposes.
- Bank details for payment of salary, business expenses etc.
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about criminal convictions and offenses.
- Health information in order to comply with legal obligations (health and safety) and data to assist in the control of infectious diseases (e.g., temperature checks).

2. How We Use Your Personal Information

We may use the information we collect or receive:

To provide and improve our products and services: We use your personal information to deliver the services you request. If you are an employee, we may use your personal information to deliver services to our customers.
Identification and authentication: We use your information to verify your identity when you access and use our Services, apply for a job with us, or otherwise engage with us, and to ensure the security of your personal information. We also use your information to facilitate account creation and log on functions, including when you log in with a third-party account (e.g., Google or Facebook).
Marketing: We may use your personal information to design and implement marketing campaigns, including to market our services to you, subject to any opt-outs you may exercise.
Service improvement and feedback: We may use your personal information to improve our services, or to request and respond to feedback from you.
Analytics: We may use your personal information for data analysis and to develop new products or services.
Exercising our rights: We may use your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to intellectual property infringement claims or violations of law.
Dealing with accidents and claims: We may process your personal information (e.g., driving license details) where required in the event of an accident or claim.
Complying with our obligations: We may process your personal information to carry out fraud prevention checks or comply with other legal or regulatory requirements, when required by law.
Processing your job application: If you apply for a role with us, we use your personal information to process your application.
Complying with your employment or consultancy contract: If you are an employee, we use your personal information to comply with our obligations as your employer. Likewise, if you are an individual consultant, we use your personal information to comply with our obligations under our contract with you.
Where necessary to protect your (or someone else’s) interests: For example, we may use health information about an employee to call an ambulance if they become seriously ill at work.

For the purposes of California law, we use and disclose your personal information for our commercial purposes (namely, enabling and effecting commercial transactions with you – or, if you are an employee, with our customers), and for the following business purposes:

Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
Performing services on behalf of the Company’s business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the Company’s business.

We may also anonymize your personal information in such a way that you may not reasonably be reidentified by us or any other company, and may use this anonymized information for any other purpose. We will not use personal information for purposes not addressed herein without your consent.

3. How And When We Disclose Your Personal Information

We disclose information with your consent, to comply with laws, to provide you with services, to protect your rights or those of others, to maintain and expand our business, and to fulfill business obligations, as further described below. We may disclose your personal information (including, as required, your sensitive personal information) to the following categories of third parties:

Vendors, consultants and similar third parties: We may disclose your data to third party vendors, contractors, consultants or agents who perform services for FlexiVan or on our behalf and require access to such information to do that work. Examples include third parties that support: payment processing, data analysis, email delivery, data storage, content hosting, customer service, recruitment, and marketing.
Analytics providers: We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.
Third-party advertisers: We may use third-party advertising companies to serve ads when you visit our Website(s) or mobile applications. These companies may use information about your visits to our Website(s), our mobile applications and other websites that are contained in web cookies and other tracking technologies in order to provide or serve advertisements about goods and services of interest to you on this and other websites. This constitutes “selling” and “sharing” of personal data under California law. If you are located in California, you can choose to opt out of this sharing of your personal information as set out in Section 10 below.
Affiliates: We may disclose your information to our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any subsidiaries, parent companies, joint venture partners, and/or other companies that we control or that are under common control with FlexiVan.
Advisors, auditors and regulatory bodies: We may disclose your data to our third-party professional advisors, auditors and any regulatory bodies to which we are subject (e.g., data privacy regulators).
Business Transfers: We may disclose or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Legal Obligations: We may disclose personal information to comply with applicable laws, rules regulations, and/or legal processes.

Where the Services use Google Maps, the use of Google Maps features and content is subject to the Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html and the Google Privacy Policy at https://www.google.com/policies/privacy/.

In the previous twelve (12) months, we have disclosed the categories of personal information described above (in Section 1) for a business purpose. However, we did not: (a) sell personal information to third parties in the last twelve months; or (b) disclose information to third-party advertisers in the last twelve (12) months.

FlexiVan may “share” (using the definition in the CPRA) your personal information with third parties for our commercial purposes. However, in the preceding twelve months, FlexiVan has not shared any personal information.

4. How Long We Retain Your Personal Information

Unless we stop requiring it beforehand, or you exercise your right to deletion, we will retain each category of your personal information for the purposes set out in Section 2 above:

for the duration of our relationship with you, and
as required by law and for our business purposes following the termination of our relationship with you.

We will retain cookie data for the periods of time set forth in Section 8 below.

5. Children’s Privacy Protection

We do not knowingly solicit, sell or share data from, or market to, children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at Privacy@FlexiVan.com.

6. Data Security

We have implemented appropriate technical security measures designed to protect the security of personal information we collect against unauthorized access, disclosure, alteration, or destruction. However, no data transmission or storage system is completely secure, and we therefore cannot guarantee the absolute security of data collected via the internet. Transmission of personal information is done at your own risk, and you are responsible for the security of your computing environment.

7. International Data Processing & Transfer

Information collected through the Services will be processed in and subject to the laws of the United States, which, if you are not located in the United States, may not provide the same level of protection for your personal information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.

8. Cookies and Similar Technologies

A cookie is a small text file that can be placed on your device. The cookie helps analyze web traffic and lets you know when you visit a particular site. Cookies, and other similar technologies, allow us to respond to your individual preferences when online and tailor operations by gathering and remembering information about your preferences.

Our Services may also have cookies provided by third parties. Data collected by these third parties, including via the cookies on our Services, may be subject to that third party’s privacy policy. We currently use the following cookies:

Cookie Name	Website or App	What The Cookie Does	Retention Period
cookie_consent	Website	Displays cookie popup	365 days
utm_source	Website	Tracks campaigns	7 days
utm_campaign	Website	Tracks campaigns	7 days
utm_content	Website	Tracks campaigns	7 days

As the cookies we use are currently all necessary for the functioning of the Services, we do not ask your permission to set them. If you do not want us to collect information through the use of cookies, you can set your web browser to reject cookies. Each browser is different, so you should check your browser’s support channels to learn how to change your cookie preferences. If you reject or block cookies, the Services may not function as intended.

You may also visit https://optout.aboutads.info/ or https://www.networkadvertising.org/ to exercise your cookie preferences.

9. Your Choices Over Your Personal Information

Depending on which state you are a resident, you may have the following rights:

Right of access. The right to confirm whether a business is processing personal information concerning you and to access that personal information.
Right to correction. The right to correct inaccuracies in your personal information, taking into account the nature of the information and the purposes of the processing.
Right to deletion. The right (which may be limited) to delete personal data concerning you.
Right to data portability. The right to obtain the personal information obtained under the right of access in a portable and (to the extent technically feasible) readily usable format, allowing you to transmit it to another business without hindrance. Exercise of this right may be limited.
Right to opt-out of processing of personal data for:
- targeted advertising;
- the sale of personal data; and/or
- profiling in furtherance of decisions producing legal or similarly significant effects concerning you.
Right to non-discrimination. The right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by visiting https://flexivan.com/subscription-preferences/. You will then be removed from the marketing email list. However, we will still need to send you service-related emails that are necessary for the administration and use of your account.

If you are based in the United States (except California, Colorado, Connecticut, Virginia or Utah – see sections 10 through 14 below) and would like to exercise any of the above rights, please submit your request to Privacy@FlexiVan.com or send a letter to Flexi-Van Leasing, LLC, Attention: Legal Department, 7320 E. Butherus Drive, Suite 201, Scottsdale, AZ 85260. Once we receive your request, we will review it to determine whether it is verifiable. Please note that we may require additional information from you in order to verify and/or honor your request.

If you do not agree with our decision in respect of your rights request, you may appeal our decision in the same manner within a reasonable period (not to exceed 90 calendar days).

If you have questions or comments about your privacy rights, you may email us at Privacy@FlexiVan.com. If you would at any time like to review or change the information in your account or terminate your account, you can contact us at Privacy@FlexiVan.com.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, to comply with legal requirements, or any other purpose permitted by law.

10. For California Residents

California law, subject to certain limitations, grants its residents certain rights regarding the collection and use of their personal information.

Right to know and request information about what personal information we have collected. This includes the right to know if we have sold or disclosed your personal information.
Right to delete. California residents have the right to request the deletion of their personal information, subject to certain exceptions.
Right to opt-out of selling personal information. California residents have the right to tell a business to stop selling their personal information.
Right to non-discrimination. California residents have the right to not be discriminated against for exercising any of the above-listed rights. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information.
Right to correct personal information. California residents can request the correction of inaccuracies in their personal information collected by the Company.
Right to opt-out of sharing sensitive personal information. California residents can opt-out of the use and disclosure of their sensitive personal information.
Right to limit use and disclosure of sensitive personal information. California residents have the right to opt out from the sharing or sale of their sensitive and non-sensitive personal information.
Right to see personal information. California residents can now see personal information collected, with no statute of limitations.

If you are a California resident, California’s Shine the Light law also permits you to request certain information about our disclosure of personal information to third parties for their direct marketing purposes, using the contact details below.

If you are a California resident and would like to exercise any of the above rights, please submit your request by:

Clicking here: Do Not Sell or Share My Personal Information;
Clicking here: Limit the Use of Sensitive Personal Information;
Emailing: Privacy@FlexiVan.com;
Calling: 1-866-883-5394; or
Sending a letter to: Flexi-Van Leasing, LLC, Attention: Legal Department, 7320 E. Butherus Drive, Suite 201, Scottsdale, AZ 85260.

Once we receive your request, we will review it to determine whether it is verifiable. Please note that we may require additional information from you in order to verify and/or honor your request.

11. For Colorado Residents

Under the Colorado Privacy Act (CPA), Colorado residents have certain rights regarding their personal information:

Right to access: You may request access to the personal information we hold about you.
Right to correction: If you believe that any personal information we hold is inaccurate or incomplete, you may request its correction.
Right to deletion: You may request the deletion of your personal information, subject to certain exceptions.
Right to opt-out of sale: You have the right to opt-out of the sale of your personal data.
Right to opt-out of collection: You have the right to opt-out of the collection and use of your Personal Data:
Right to data portability: You may request the transfer of your personal information to another entity.
Right to opt-out of targeted advertising: You have the right to opt out of targeted advertising based on your personal information.

To exercise your rights or make inquiries about your personal data, please click here: Do Not Collect, Sell or Use My Personal Information for Targeted Advertising or contact us using the contact information set forth in Section 15 below. Once we receive your request, we will review it to determine whether it is verifiable. Please note that we may require additional information from you in order to verify and/or honor your request.

12. For Connecticut Residents

Under Connecticut’s data privacy laws, including the Connecticut Act Concerning Data Privacy (CADP), Connecticut residents have certain rights regarding their personal information:

Right to access: You may request access to the personal data we hold about you.
Right to obtain: You may request a copy of your personal data in a portable and readily usable format that allows you to transfer the data to another controller with ease.
Right to correction: If you believe that any personal data we hold is inaccurate or incomplete, you may request its correction.
Right to deletion: You may request the deletion of your personal data, subject to certain exceptions.
Right to opt-out of the sale of personal data: You have the right to opt-out of the sale of your personal data.
Right to opt-out of targeted advertising: You have the right to opt out of the processing of your personal data for the purposes of targeted advertising.
Right to opt-out of profiling: You have the right to opt out of profiling that may have a legal or other significant impact.
Right to nondiscrimination: We will not discriminate against you for exercising your rights under Connecticut’s data privacy laws.

To exercise your rights or make inquiries about your personal data, please contact us using the contact information set forth in Section 15 below. Once we receive your request, we will review it to determine whether it is verifiable. Please note that we may require additional information from you in order to verify and/or honor your request.

13. For Utah Residents

Under the Utah Consumer Privacy Act (UCPA), Utah residents have certain rights regarding their personal information:

Right to confirm: You have the right to confirm whether or not FlexiVan is processing your personal data.
Right to access: You may request access to the personal information we hold about you.
Right to obtain: You have the right to obtain a copy of your personal data that you previously provided to FlexiVan, which we will provide in a portable and readily usable format that allows you to transfer the data to another controller with ease.
Right to deletion: You may request the deletion of your personal information, subject to certain exceptions.
Right to opt-out: You have the right to opt out of the processing of your personal data for purposes of targeted advertising or the sale of personal data.
Right to nondiscrimination: We will not discriminate against you for exercising your rights under the UCPA.

14. For Virginia Residents

This Section 14 outlines how we handle personal data collected from individuals residing in Virginia in compliance with the Virginia Consumer Data Protection Act (CDPA). Under the Virginia CDPA, you have certain rights regarding your personal information:

Right to confirm: You have the right to confirm whether or not FlexiVan is processing your personal data.
Right to access: You may request access to the personal data we hold about you.
Right to obtain: You have the right to obtain a copy of your personal data that you previously provided to FlexiVan, which we will provide in a portable and readily usable format that allows you to transfer the data to another controller with ease.
Right to correction: If you believe that any personal data we hold is inaccurate or incomplete, you may request its correction.
Right to deletion: You may request the deletion of your personal data, subject to certain exceptions.
Right to opt-out of sale: We do not sell personal information in the traditional sense, but we may engage in certain data sharing activities. You have the right to opt out of such sharing.
Right to opt-out of targeted advertising: You have the right to opt out of the processing of your personal data for the purposes of targeted advertising.
Right to opt-out of profiling: You have the right to opt out of profiling that may have a legal or other significant effect.
Right to nondiscrimination: We will not discriminate against you for exercising your rights under the Virginia CDPA.

15. Contact Us

If you have questions or concerns regarding the way in which your personal information has been used, please contact us by:

Emailing Privacy@FlexiVan.com
Calling 1-866-883-5394
Sending a letter to Flexi-Van Leasing, LLC, Attention: Legal Department, 7320 E. Butherus Drive, Suite 201, Scottsdale, AZ 85260

16. Changes to The Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible on FlexiVan’s website. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.