Privacy Policy
(Draft under review by TxDOT July 19, 2022)
At Houston TxDOT ("Application Owner", "we", or "us"), we take your trust and your privacy seriously, and our goal is to help safeguard your privacy while providing you with the best possible experience using our ConnectSmart services. This Privacy Policy describes the collection, use, disclosure, and protection of personal and other information about you received or generated by us when you use or interact with our website at www.houstonconnectsmart.com (the "Site") and our other websites, as well as all applications and other services (collectively, the "Services") offered or made available by us at the Site or through corresponding sites on social media outlets (such as through a Facebook page) or through corresponding applications on mobile devices. By using or accessing the Services, or otherwise by submitting information to the Application Owner, you consent to this Privacy Policy including to data monitoring and recording as set forth in this agreement.
Background: TxDOT has contracted Metropia, Inc., 3040 Post Oak Blvd. Suite 1800-136 Houston, TX 77056, to administer the ConnectSmart application. Their duties as Administrator include, but are not limited to, enrolling users, gathering and safeguarding data, selecting third-party providers, and operating the ConnectSmart application. In this capacity, the “we”, “us”, or “our” may refer to Metropia, Inc.
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What Information Do We Collect?
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We collect all information you submit through forms and similar methods in the Services, including: your user registration account information, email address, location address, route, trajectory, origin, destination of planned trip, your favorite contacts, your favorite lifestyle, and saved route for arrival time and location-based service notifications (collectively, “Personal Information”). The information we collect including system usage may be monitored and recorded.
We collect all user feedback you submit to improve our Services and provide customer support.
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We collect the real-time geographic location (GPS), time, speed, and heading of your device. We collect this information while you have our app open or running in the background to validate your trip prior to giving out the rewards, and also as an element to our overall traffic data that benefits our entire user community. However, the application will not permanently store raw trajectory data integration with social networks: Through the settings of your ConnectSmart account, you may choose to login using your social network account and/or share information between your ConnectSmart account and your social network account. Through this option, you may choose to have personal information and other content about you available from social networks transmitted and shared through the Services. Similarly, you may choose to have personal information and other content about you available from ConnectSmart transmitted to and shared through your social network account. With the location services being enabled in our mobile applications, we collect location data from your device, including latitude, longitude, altitude, speed, and heading (collectively, "Location Information").
With the calendar integration services being enabled in our applications and websites, we may collect events data from your calendar, which includes, without limitation, the time and location of the event (collectively, "Calendar Information"). The Application may collect device-related information for better service purposes, such as the Operating System (OS), OS version, brand and model, screen size, device ID, browser info, etc. on smartphone and computer devices. The Application may access your phone contact list when you use the "Shared ETA" feature to notify your friends about your trip. We may also access any other data users generated by using the application, such as reserving a route, validating a route, earning points, redeeming for rewards, etc. For more information on points and rewards, please see Terms of Service.
We collect any other information your app store provider lawfully shares with us. Please review your app store provider’s privacy policy for more information.
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How We Use the Information?
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At Houston TxDOT, your privacy matters to us. Our aim for you is to use ConnectSmart smartly and securely. The Application Owner does not share, sell, lease, or rent the personal information you provide to third parties unless absolutely necessary, except for the following purposes:
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To enable customization of your user experience when using the Services;
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To enable you to share information (including Location Information) with other users of the Services and on other platforms—such as authorized digital loyalty and reward service partner, Tango—and other integrated social networks, such as Twitter and Facebook;
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To communicate with you and to assist you with any questions you have about the Services;
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To offer you other products or services that may be of interest to you;
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To ease use of our Services by eliminating the need to re-enter information;
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To display content and advertising customized to your interests and preferences; and
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To create a higher quality of service.
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If you are participating in an employer-sponsored program, your employer may have access to your information. If you select to use a third party, we may share your information with such third party to the extent they need it to provide their services and they agree to protect it from disclosure or other unauthorized use. Please review the third party’s Privacy Policy to understand how they collect, use and share your personal information.
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Except as otherwise indicated, Application Owner uses Location Information:
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To provide content relevant to your locations and routes;
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To enable you to store your trip information in our Trip Log feature;
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To enable you to share location information with contacts (“Shared ETA” feature in ConnectSmart Mobile app); and
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To enable carpooling and vanpooling services.
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Authorized Application Owner service providers and contractors may have access to your information to facilitate its use consistent with this Policy. Personal Information and Location Information may be used to assist us in the development of new features and services, and/or the improvement of our existing Services.
To cooperate with government officials or parties in litigation under process of law or regulation, or as otherwise required or permitted by law; to protect the security or integrity of the Services, and/or to enforce the terms governing its use; to protect against a threat of safety or destruction of property; and/or to protect against legal liability. These purposes may include, but are not limited to, generating reporting, conducting research and analysis, and improving the design and content of our Services, and the Application Owner may share this data with contractors, partners, and other third parties. By agreeing to this Privacy Policy, you are consenting to this sharing.
The Application Owner may disclose Personal Information and/or Location Information we maintain about you to non-affiliated third parties under the following types of circumstances: to comply with the law, or when we respond to a subpoena or other process, legal order, or official request; as otherwise required by law; to establish or exercise our legal rights or defend against legal claims; or, as permitted by applicable law, or violations of the legal terms that govern your use of the Services. In addition, the Application Owner may transfer Personal Information, Location Information, and non-personally identifiable information if the Application Owner is acquired by or merged with another entity in the Application Owner’s good-faith discretion.
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Advertising Campaigns
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The Application Owner may permit, solicit, or contract certain other companies to conduct advertising campaigns on the Services. The advertisements that you see when accessing the Services are redirected from the servers of those advertising companies and may be geographically or contextually targeted. Some advertisers may use cookies on your computer. The cookies enable them to collect information about sections and features that you have accessed, advertisements posted on those sites, and the advertisements that you have viewed. The advertisers' use of cookies is subject to their own privacy policies and not to this Policy. If you wish to study the privacy policies of those advertisers, you should visit their services or contact them directly.
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Information Security
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The Application Owner has implemented security measures to help protect against the risk of loss, misuse, and alteration of any information under our control. We cannot, however, ensure or warrant the security of any information you transmit to us or store on the Services, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
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IP Addresses and Cookies
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Like other websites, the ConnectSmart website uses your domain, IP address, and browser information to help diagnose problems with our Services and equipment, to administer the Services, and for security purposes. "Cookies" are pieces of data sent from a Web server to a Web browser that enable a Web server to identify users that visit a site hosted by that server. The Application Owner may use Cookies and other similar technologies in order to identify you so that we can provide more customized information and services to you. In addition, advertisers on our Services may place their own Cookies. In general, if you choose, you can disable the use of Cookies by reviewing your browser's preferences and options.
How to Opt Out
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You can opt out of location information services from the settings of your mobile device’s operating system, or by uninstalling the Application. At any time, you may uninstall the Application by using the removal feature of your operating system. Following the uninstallation process, the Application Owner will not be able to collect any further location-based information from you or provide you with location-based information about sites, shops, and other places and attractions in your immediate vicinity.
In the event you opt out, any data collected on your usage that is in anonymized form (redacted to not be identified with you as an individual) may be retained by the Application Owner for use in its algorithms and related platforms.
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Changing, Viewing, or Updating Your Information
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If you wish to access or amend any other personal information we hold about you, or request that we delete any information about you that we have obtained from an integrated social media service, please contact us via our website at http://www.houstonconnectsmart.com or directly through our application. We will use reasonable efforts to process any change you make; provided, however, that requests to delete information are subject to our internal reporting and retention policies and all applicable legal obligations.
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Children’s Privacy
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Protecting the privacy of young children is especially important. Our Services are NOT PERMITTED for use by minors, except for those 16 and over who have written parental permissions. If you are under 16 years of age or are 16 or 17 years of age and do not have parental permissions, then please do not use or access the Services at any time or in any manner. If you are a parent or guardian and discover that your child under 16 years of age has obtained an account on the Services, then you may alert us at support@houstonconnectsmart.com and request that we delete that child's personally identifiable information from our systems.
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Privacy Settings
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Although we may allow you to adjust your privacy settings to limit our access to certain personal information, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Services. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information collected by the Services is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Services. We cannot and do not guarantee that information you post on or transmit to the Services will not be viewed by unauthorized persons.
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International Visitors
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The Services are hosted in the United States and are intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing.
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Updates to this Privacy Policy
This Privacy Policy may be updated or modified from time to time. We will provide notice of any changes by posting the new Privacy Policy on the Services. You are advised to consult this Privacy Policy regularly for any changes. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Services for the first time after such material changes are made. Your use of the Site or other portions of the Services after such update or modification constitutes your acceptance of such changes to this Privacy Policy. This Privacy Policy and you are also subject to the Company's Terms of Use (the "TOU") and the applicable terms and conditions of the TOU (including limitations on damages, jurisdiction of disputes, and application of law) shall apply to this Privacy Policy and any disputes relating to privacy of information issues hereunder.
We use Google’s Services
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Our website may use Google Analytics, which are web analytics services provided by Google LLC. These services use cookies to analyze your use of our website. The information collected by these cookies about your use of our website is transmitted to and stored on Google Servers.
Google uses this information to assess your use of our website and provides reports on data. This data may include how often you visit our website, what pages you view when you visit the website, and what other websites you have visited prior to visiting our website. Google may transfer this information to third-parties, if required by law or if third-parties process the information on behalf of Google.
You may review Google’s data privacy practices for Google Analytics. You may also review Google’s Privacy Policy and Terms of Service for more information. To opt out of being tracked by Google Analytics, you may download and install the Google Analytics Opt0out Browser Add-on.
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Questions
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If you have questions about this Policy, or about how information we collect is used by the Application Owner, please visit our website at http://www.houstonconnectsmart.com/ or mail us at C/O Metropia, Inc. 3040 Post Oak Blvd. Suite 1800-136 Houston, TX 77056.