Last updated: 12/18/2015

Smerle, Inc. ("Smerle") is committed to protecting your privacy and we encourage you to read and learn more about the terms of our privacy policy ("Privacy Policy"). By visiting and using Smerle's online website (collectively, including all content and functionality available through the [] domain name, the "Site"), or mobile application (the "App"), submitting information or using any of our services (the "Service"), you (the terms "you", "your" and "yours," shall refer to any and all users of the Site and App (the "User")) acknowledge that you accept the practices and policies outlined in this Privacy Policy. Terms not defined herein shall have the meaning as provided in Smerle's Terms of Service, found at [], and incorporated herein.


This Privacy Policy is effective as of December 19, 2015.

Information Covered in This Privacy Policy.This Privacy Policy covers Smerle's treatment of Personal Information (as defined herein) and General Information (as defined herein) that Smerle gathers when you access the Site and/or App and when you use any part of the Service.  Respective provisions of this Privacy Policy apply to you whether you use the Site, App and/or Services as a User, a Driver, or both. This Privacy Policy also covers information Smerle may share with Smerle's business partners. This Privacy Policy does not apply to the practices of companies that Smerle does not own or control, or to individuals that Smerle does not employ or manage.

Collection of Your Information. You may provide information to us in several ways: (i) in using the Site, you will be given the option to provide us with your Addresses, and your e-mail address in order to receive an Invite to register for an Account; (ii) if you would like to register to become a Driver, you may provide us with your name, e-mail address, phone number and zip code through the Site; (iii) if you are a company or employer and would like to learn more about our Services and/or partner with us, you may provide us with your name, e-mail address, phone number and company name through the Site; and (iv) in order to access the Services, and once you receive an Invite, you will be required to register for an Account through the App by providing your name, e-mail address, Addresses, telephone number, credit card information.  Any such information that personally identifies you and which you provide to us through the Site and App such as, and as applicable, your name, e-mail address, Addresses, telephone number, credit card information, and certain preferences is considered your “Personal Information”.  It is your responsibility to give us current, complete, truthful and accurate information, including Personal Information, and to keep such information up to date. Smerle will not be responsible for any problems or liability related to inaccurate or incomplete Personal Information, whether due to your failure to update such Personal Information or otherwise.

In addition to the Personal Information, we may collect general non-personal information from your use of the Services and/or which you provide to us (the “General Information”):

In using and/or accessing the Services, you expressly authorize us to collect and use your Personal Information and General Information in connection with the Services. You further acknowledge and agree that Smerle may, but is not obligated to, maintain copies of your Personal Information and General Information indefinitely, or delete any or all such information, at our sole discretion. When you receive promotional e-mails or newsletters from Smerle, if any, we may use customized links or similar technologies to determine whether such newsletters or e-mail has been opened and which links you click. This information is used to provide you more focused e-mail communications and/or other information.

Use of Your Information.Smerle collects and uses your Personal Information and General Information to operate and improve the Site and the App and better deliver the Services. These uses may include performing analysis aimed at improving the Service; making the Site, the App or Services more user friendly by reducing the need for you to repeatedly enter the same information; and displaying advertising and content that are tailored to your preferences and interests.  Smerle may support the Site, the App and the Service by advertising, and accordingly, Smerle may use some of the information collected in order to customize the advertisements to your interests and preferences. However, the process of selecting customized ads tailored to you will use data that does not personally identify you, such as using demographic data such as ZIP code.  Smerle may also use your Personal Information and General Information to communicate with you, such as providing you with mandatory notices or discretionary notices about the Service, and sending you notifications regarding your Ride.  From time to time, Smerle may also send you surveys or promotional mailings to inform you of other products or services available from Smerle and its affiliates.  Smerle is headquartered in the United States of America. Information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, or service providers elsewhere in the world. By providing us with your information, you consent to this transfer. We will protect the privacy and security of Personal Information and General Information according to our Privacy Policy, regardless of where it is processed or stored.

Disclosing of Your Personal Information to Third Parties.Smerle does not sell, rent, lease or disclose your Personal Information. Except as described in this Privacy Policy, your Personal Information will be used only by Smerle and its controlled subsidiaries and affiliates, and your Personal Information will not be disclosed to any other third party without your consent.  By accessing your Account, you may choose to share your Personal Information with select Smerle partners so that they can contact you about their respective products, services or offers.  We do not share your Personal Information with third parties for the third parties’ direct marketing purposes unless you provide us with consent to do so.

We may share your Personal Information and General Information with other Commuter only to the extent to enable easy identification and communication.  For example, Drivers will be provided with Commuters Name, Addresses and Phone number in order for them to pick-up and drop off.  Personal Information about you may also be provided to your employer if your employer has partnered with us and/or you require transportation to your Home Address in the event of an emergency.

Smerle may hire other companies to provide limited administrative and communication services on Smerle’ behalf, such as hosting Sites, the processing and delivery of mailings, providing customer support, or providing credit card processing services. Smerle has the right to disclose your Personal Information to these third party companies for the purpose of administering and maintaining the Site and App’s features, functions and operations. Those companies will be permitted to obtain only such Personal Information as necessary for them to deliver the respective services, and Smerle does not authorize these companies to use your Personal Information except for the sole purpose of providing those services requested by Smerle.

You understand and agree that Smerle may access and/or disclose Personal Information and General Information about you or your Account without your prior consent if Smerle has a good faith belief that such action is necessary to: (i) comply with legal process or other legal requirements of any governmental authority; (ii) protect and defend the rights or property of Smerle (including the enforcement of our agreements); (iii) enforce the Terms of Service, which can be accessed at []; (v) operate or conduct maintenance and repair of the Site, the App or equipment as authorized by law; (vi) act in urgent circumstances to protect the personal safety of Users or members of the public; or (v) comply with a bankruptcy, merger, acquisition, transfer of control, joint venture of other business combination. Smerle is not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that we receive. In some cases, we may choose to buy or sell assets. In these types of transactions, User information is typically one of the business assets that is transferred. Moreover, if Smerle, or substantially all of its assets, were acquired, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Smerle may continue to use your Personal Information and General Information as set forth in this Privacy Policy.

Security of Your Personal Information.The Personal Information is securely stored within our database, and we use standard, industry-wide practices such as firewalls, encryption, and (in certain areas) Secure Socket Layers (“SSL”) for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. Smerle cannot guarantee the security of our database, nor can we guarantee that information you supply won't be intercepted while being transmitted to Smerle over the Internet.  Smerle recommends that you not disclose your password to anyone.

Information Collected Automatically.We may receive and store certain types of information whenever you interact with the Site, the App and/or Service. Smerle may choose to automatically receive and record information on our server logs from your browser including your IP address, cookie information, and the page you requested. Smerle uses "cookies" to collect non-personal data and information. Cookies are small text files a Site uses to recognize repeat users, and is typically placed on your hard disk by a web page server.  Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. The way cookies function is by assigning a number to the user that has no meaning outside of the assigning Site. You should be aware that Smerle cannot control the use of cookies (or the resulting information) by Smerle's third-party partners or advertisers. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of the Site and Service that depend on cookies.

In addition, Smerle may use third party analytics providers and products to obtain, compile and analyze General Information about how Users are using and interacting with Smerle and/or the Services. Smerle may provide General Information to these analytics providers for the purpose of obtaining statistics and other information about how Users are using and interacting with Smerle. These analytics providers may use a variety of established or new tracking technologies or tools (including, without limitation, cookies, web beacons, HTTP cache, local shared objects and persistent identifiers) to recognize your computer or device and/or to collect or compile this information. Smerle has no control over the technologies, tools or practices of the third parties that providing analytics products and services to Smerle.

Location Information. From the permission system on your mobile operating system, we request permission for the App’s collection of your Location from your device. If you initially permit the collection of this information, you can later disable it by changing the location settings on your mobile device.  However, you understand that (i) your ability to use certain features of our Services will be limited if you do so, and (ii) disabling the App’s collection of your Location from your device will not limit our ability to collect your Ride information from a Driver's device or our ability to derive approximate location from your IP address.

Collection and Use of Children's Personal Information.The Site, the App and the Services are intended for general audiences, and Smerle does not knowingly collect any Personal Information from children. During the registration process for an Account, Smerle may collect age information, and if Users identify themselves as under 13 years of age, Smerle will block such Users from providing Personal Information.

E-mail Communications.Upon registration for an Account or using the Services provided by Smerle, we may send you daily or weekly e-mails. If you do not want to receive e-mail or other mail from us, please notify us by e-mail at [] and include sufficient information for us to identify your account, including your name, email address and the specifics of your request. However, after you unsubscribe to cease receiving e-mails, Smerle may still contact you via e-mail for administrative or informational purposes, including messages regarding the administration of your account and/or any services or events to which you have registered.

Advertisements Displayed by Third Parties. Smerle may allow third-party ad serving companies, including ad networks, to display advertisements on the Site. Ad serving companies may place a persistent cookie on your computer in order to recognize your computer each time they display an online advertisement to you, and as such, they may be able to compile information over time about whether you reviewed or clicked on advertisements they display. These companies may use this information to display targeted advertisements and may associate this information with your subsequent visits, purchases or other activities on participating advertiser’s Sites. Smerle has no access to or control over cookies of these links to other Sites and organizations, nor does Smerle have control over or access to cookies by Smerle’s third-party partners or advertisers. This Privacy Policy does not cover any use of Personal Information that a third-party advertiser or ad server may collect from you.

Questions or Comments Regarding this Privacy Policy. Smerle welcomes any questions or comments you may have regarding this Privacy Policy or if you do not understand any information about how we collect, maintain, use, or share your Personal Information. Any such questions or comments should be submitted via email to []. We will make every effort to resolve or answer your concern.

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