Privacy Policy of FlexWheels, LLC

Your Privacy

We respect your privacy and are committed to protecting the personal information we
hold about you. This policy explains what information we collect about you, how we
collect it, the measures we take to keep your information secure and the uses we make
of it. We also explain the options you have regarding your personal information. When
you request services from us, access our websites, utilize our mobile “apps” or
otherwise interact with us, for example, but without limitation, through our service
centers, our invehicle or inequipment technology, our official corporate pages on third
party social networks (such as Facebook) or the “apps” on those pages, 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.

Summary of our Privacy Policy

Who We Are: We are FlexWheels, LLC and its subsidiaries, affiliates and third parties
providers including but not limited to Clutch Technologies ,LLC. This policy governs
any information that Company receives from you or that we share with third parties
who are engaged by or working with us in connection with the provision of our products
and services.

Legal Issues: We aim to comply with the privacy laws applicable to the personal
information we collect and use.

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 for the purposes listed in this policy.

What We Share: In order to optimize your experience using our service, we may share
your information with third parties who are engaged by or working with us in
connection with the provision of our products and services under this Agreement and
those third parties may share your information with us. Any information that we share
with such third parties, as well as any information that they receive from you, is
governed by such third party’s privacy policy.

Sources: We mostly collect your information directly from you, through various
channels including our website, 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.

Websites: Certain technologies may be used on our websites, our apps and other
electronic media including cookies and Pixel Tags, to collect information about your
visit to our site and sites upon which we advertise. You may choose to restrict the use
of cookies as suggested in this policy.

Storage: We generally retain personal information about our subscribers for as long as
we believe appropriate for the purposes for which it was collected.

Security Measures: We aim to maintain appropriate physical, procedural and
electronic safeguards to protect your personal information.

Access: You may access and review the personal information we retain about you and
correct any factual errors.

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

Detail of our Privacy Policy

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, IP
addresses, 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. With regard to
pages on third party social networks, 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 “unofficial” pages or pages of our affiliates or
licensees. Our websites are not directed to individuals under the age of 13, and we
do not knowingly obtain personal data from such individuals.

When you request services from us, operate a vehicle or equipment
with invehicle or inequipment technology, access our websites, utilize our mobile
“apps” or otherwise interact with us, for example, but without limitation, through
our kiosks, our official corporate pages on third party social networks (such as
Facebook) or the “apps” on those pages, you consent to our collection, retention
and use of your personal data in the manner described in this policy and accept
the risks outlined in the Security Measures section.

Who We Are

We are FlexWheels, LLC, a company based in Davie, Florida, which, together
with our affiliate companies, provides and supports vehicle subscription
services in the United States. In providing these services, we work with software
vendors, licensors and other third parties. As our vendors, licensors and affiliates
are independent companies, they are not owned or controlled by us and are not
covered by this policy, although they may have their own privacy policies to govern
the personal information they collect. We are not responsible for the privacy
practices of other parties.

Personal Information

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.

Personal Information We Collect and How We Use It

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. We
collect a range of information about you from a variety of sources for the purposes of
our business. The examples we provide throughout this policy are illustrative rather
than a complete list of our practices.

When you visit our websites or apps, our servers might automatically log certain
information about your use of our websites, such as your IP address, your browser type,
operating system, browser language and service provider. We also collect information
about your activities on our websites and apps, such as the pages you visit or the ads or
links you click on. The first time you visit our website, we may assign you a unique
identifier, which is stored in one or more cookies on your computer’s hard drive. These
cookies help us distinguish new visitors from returning visitors and enable us to
measure the effectiveness of content on the website and refine and tailor that content to
suit our visitors’ interests. If you have subscribed for our services or provided other
personal information about yourself (for example, if you send us an email), your cookie
ID can be associated with you personally. When you are signed in to our mobile apps,
you will be identified to us by your account email and/or phone number.

We collect information that you voluntarily submit to us, such as:

– Name, address and contact details, including telephone and mobile number, and
– 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.

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 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. From time to time we will send newsletter emails. To
unsubscribe from our newsletters please use the opt out in the email footer.

Our vehicles may be equipped with vehicle tracking and other technology. We
implement 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 invehicle and inequipment 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. Disabling, disconnecting or destroying
any such technology device or equipment is strictly prohibited.

Other Sources

We also gather personal information about you from a variety of other sources,

– Transactions you complete with us and our vendors and licensees, including
options you take, charges you incur and any incidents or accidents that may
– To the extent you have made such information available, from third party social
– 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 We Hold Personal Information

We utilize servers in various locations in the United States of America. If you are
accustomed to other countries privacy laws, please note that the laws governing the
processing of personal information in the United States of America may not be as
rigorous as they are in the United Kingdom, Canada or other nations. 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 do not conduct business in countries outside the United
States, but to accommodate subscribers from other countries, we aim to comply with
the privacy laws applicable to the personal data we collect and use.

We try to ensure that the personal data we retain about you is stored securely and, in
light of the information provided to us, is as accurate, current and complete as necessary
for the purposes for which we use it. We generally retain personal data about our
subscribers for as long as we believe appropriate for the purposes for which it was
collected or as otherwise required by applicable law.

Where We Can Send 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 or your approved additional drivers 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 (for example, if you are an
associate member or affiliated with a business’s or university’s 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 invehicle and inequipment 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
website 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; or when necessary to protect
our rights or property (or those of third parties).

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
– 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 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

To Communicate With You

We may use your personal information to communicate with you, including with
regards to:

– Your subscription or any other transaction 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

By subscribing for or using our vehicles and services, or by contacting us in any way,
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 relation to any aspect of your subscription or use of our

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
  • 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 affiliates, you or others; and
  • To allow us to pursue available remedies or limit the damages that we may


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 information that personally
identifies you with those parties. If you do not want us to send you promotional
emails, please adjust your settings or utilize our “unsubscribe” feature in the
footer of emails.

We may also use third party ad network providers and other service providers to help
present customized content and offers on our websites. These providers use cookies,
web beacons, or similar technologies on your computer to help present, better target,
and measure the effectiveness of their content and advertisements, using data gathered
over time and across their networks of web pages to determine or predict the
characteristics and preferences of their audience. We may share certain non-personally
identifiable information about you (such as age and zip code) with certain ad network
and service providers to help them deliver more relevant content and advertisements
through their networks. The use of cookies, web beacons, or similar technologies by
content and ad network providers is subject to such providers’ own privacy
policies, not ours.

Cookies are text files that are placed in your computer’s browser, and that can be used
to help recognize you on our websites. Web beacons are small pieces of code placed
on web pages that can be used, among other things, to count the users who visit that
web page, or to deliver a cookie to the browser of a user viewing that page. Many
websites, including our website, also may use Flash cookies that are similar to regular
browser cookies. You can control browser cookies through your browser’s
settings. You may delete cookies or set your browser to alert you when cookies are
being sent. If you reject all browser or flash cookies, however, some areas of our sites
may not function.

Third party advertiser/service providers may use cookies, web beacons, or similar
technologies in connection with offers, content, and services offered through our
website, including to help operate ad networks. When there are third parties that are
performing such activities, we will endeavor to list the parties in this privacy notice and
to provide a link to their web sites. The use of cookies by our partners, affiliates, and
service providers is not covered by our privacy statement. We do not have access or
control over these cookies. Our partners, affiliates, and service providers use session
ID cookies to make it easier for you to navigate our site.

Our web site may include social media features, such as the Facebook Like button and
widgets or interactive mini-programs that run on our site. These features may collect
your IP address, which page you are visiting on our site, and may set a cookie to enable
the feature to function properly. Social media features and widgets are either hosted by
a third party or hosted directly on our site. Your interactions with these features are
governed by the privacy policy of the company providing it, not by us.

Review and Correct Your Personal Information

We are committed to providing you with reasonable and practical access to your
information to allow you the opportunity to identify inaccuracies. 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. If you would like to access, delete
and/or correct other personal information, please contact us in one of the ways provided
below and we will respond to your request within 30 days. If we are informed of the
inaccuracy we will make the appropriate corrections.

We will retain your information for as long as your account is active or as needed to
provide you services. Please contact us if you wish to cancel your account or request
that we no longer use your information to provide you services. We will retain and use
your information as necessary to comply with our legal obligations, resolve disputes,
and enforce our agreements.

Security Measures

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

We take reasonable measures to protect against the loss, misuse and unauthorized
access or disclosure, alteration and destruction of your personal data by aiming to
maintain appropriate physical, procedural and electronic safeguards to protect your
personal data, including:

– Restricting access to personal data to our employees on a “need to
know” basis;
– Destroying confidential personal data 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 help 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 use 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.


I hereby give FlexWheels consent to voice record, videotape, and photograph myself to
be used for internal purposes as well as utilize for mass marketing including but not
limited to newsletters, website, press distribution, social media as well as usage for other
media outlets as deemed appropriate by FlexWheels.
I further understand that no compensation will be provided to me for use of my image
and I may not be informed in advance of the specific use of my image.
Changes to Our Policy
We may change this policy from time to time, so it is advisable to review it
frequently. Changes to this policy will be announced on our website or through similar
means and all amended terms shall automatically be automatically effective when
posted (or as indicated in our posts).

Contact Us

FlexWheels, LLC
If you have questions about our handling of personal information, you may write to
us at or at the address below.
4839 SW 148th Ave, #459,
Davie, Florida 33330

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