Last updated: December 2021
Motional AD Inc. (“Motional”), a Delaware Corporation with a place of business at 100 Northern Avenue, Boston, Massachusetts 02210 is committed to protecting the privacy and security of your personal data. This privacy statement applies when you visit Motional.com (“Site”) or any other sites affiliated with Motional or its affiliates (sites), or when you contact us with a comment, inquiry or customer support request through this Site.If you are a passenger in a Motional vehicle, or would like more information about the information we receive with respect to vehicles, please review our Vehicle User Privacy Statement.
By using or accessing this Site, or contacting us, you agree, where permissible by law, that we may process your personal data in the manner described in this statement. Changes to this statement will be reflected on this page and noted with the “Last updated” date at the top. Please check our privacy statement periodically for changes.
It is important that you read this statement so that you are aware of how and why we are collecting and processing your information. If you have any questions about this statement or how we handle your personal data, please contact Motional by emailing firstname.lastname@example.org.
Personal data we receive
Personal data, or personal information, means any information from or about an identified or identifiable person, including information that Motional can associate with an individual person. Depending on local law, it may not include de-identified or aggregate information, or public information lawfully available from governmental records.
When you visit or use our Site or services, we may collect, store, process, and/or use the following categories of personal data about you:
Customer account information – identity data (such as first name, last name, title, company/organization name); contact data (such as name, title, addresses, telephone numbers, and email); profile data (such as username and password, purchases or orders made by you); and transaction data
Marketing, promotions, and communications data – data on your preferences in receiving marketing from us and our third parties and your communication preferences. This also may include information you provide us in the context of promotions or surveys.
Communications with Motional and our partners – when you interact with us we will record details of those interactions (for example, phone calls, e-mail correspondence, and online form submissions).
Information from partners – Motional obtains information about customers and their users from third-party companies, such as market data enrichment services, including information about an account owner’s company size or industry, contact information, or activity of certain enterprise domains. Motional may also obtain information from third-party advertising partners who deliver ads displayed on Motional’s sites, such as whether you clicked on an ad.
If you apply for a job with Motional, we will collect and have collected additional information in connection with your application. Specifically, your:
·Name and contact information;
·Work authorization status;
·Voluntary U.S. Equal Opportunity employment information and self-identification of disability;
·Resume, CV, cover letter, work experience, skills, and education information;
·Professional and work-related licenses, permits, and certifications held
·Reference-related information; and
·Any other information related to your professional experience that is publicly available on LinkedIn or that you elect to provide to us (e.g., current salary, expected salary).
Such information may be collected from you directly, from your references, from a recruiter, from your prior employers, from background checking firms, and from your places of education. We will only use this information to evaluate your candidacy, including by processing your application, assessing your qualifications, corresponding with you, and complying with legal obligations. We will only collect, use, process and disclose any sensitive personal data in accordance with applicable laws.
How your personal data is received
How we use your personal data
We may use the personal data we receive for purposes that include:
Providing Motional products, services and transactions – We may use your personal data to provide products, features, and services to customers and/or users, or carry out transactions you have requested, including, but not limited to, providing information on products or services you have purchased or otherwise use, answering customer service requests and facilitating the use of our sites.
Administering and protecting our business and sites – We may use your personal data to administer and protect our business and our sites, including troubleshooting, system maintenance, support, reporting and hosting of data.
Improving our business, sites, products and services – We may use your personal data to perform business analyses or for other purposes that help us to develop and improve the quality of our business, sites, products and services (including new products and services), for example, by customizing our sites to your particular preferences or interests.
Marketing, promotions and surveys – In accordance with applicable laws and regulations, we may use your personal data to inform you of products or services which may be of interest to you, and to otherwise communicate with you about offerings, events and news, surveys, special offers, and related topics. You are able to opt-out from marketing communications sent via e-mail at any time, free of charge by using the “unsubscribe” link in any e-mail marketing materials you receive from us, or by contacting us email@example.com.
Research and analysis – We may use your personal data to conduct research and analysis to help us analyze your purchasing preferences, identify the products and services that best meet your requirements and measure the effectiveness of the advertising we serve you. We also may use your data for future product innovation, and product research and development.
Communicating with you – We use personal data (including contact information) to communicate with you about our products, features, and services, including product updates, and changes to our policies and terms. We also use your information to respond to you when you contact us.
Enforcement, integrity, security, and safety – To detect, investigate, and prevent malicious conduct, intellectual property infringement, misuse of our sites, or unsafe experiences, address security threats, protect public safety, and secure Motional products.
Legal reasons – To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our Terms of Service or policies.
Where permitted by law, we may combine the information that we collect via our Site with other information we hold about you (such as information about your use of our products and services) in order to offer you an improved and consistent customer experience when interacting with us or for other purposes set forth in this statement. Motional uses third-party marketing and advertising providers to provide statistics and analysis about how people are using our website and to provide advertising and marketing, including targeted advertising based on your use of our website.
You will not be subject to decisions based on your personal data that will have a significant impact on you based solely on automated decision-making (i.e., without human intervention), as regulated by applicable privacy laws, unless we have a lawful basis for doing so and we have notified you.
How we share your data
We will share your personal data with third parties in the following circumstances:
Service providers – We will share your data with trusted third-party service providers. All our third-party service providers are required to take appropriate measures to protect your personal data based on the associated risks, including proper security and access controls, and to treat it in accordance with the law. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
Legal reasons – where required by law; as needed to respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; where it is necessary to perform our contract with you; to enforce or investigate potential violations of its Terms of Service or policies; detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; meet our corporate and social responsibility commitments; protect our and our customers’ rights and property; and to resolve disputes and enforce agreements.
Third party marketing partners – Motional uses third-party marketing and advertising providers to provide statistics and analysis about how people are using our website and to provide advertising and marketing, including targeted advertising based on your use of our website. These third-party partners may receive information about your activities on the Site through third-party cookies placed on the Site. To opt out of our use of third-party cookies that share data with these partners, visit our cookie management tool. Where required by law, Motional will first obtain your consent before engaging in the activities described here.
Changes in control – Motional may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Motional’s business or assets, including in connection with bankruptcy or similar proceedings.In these instances also, we will ensure appropriate measures to protect the use, retention, sharing, storing, and other processing of your personal data.
We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, which are identified in this Privacy Statement, unless a longer retention period is required by applicable law. The criteria used to determine our retention periods include the following:
The length of time we have an ongoing relationship with you and provide Motional products to you;
Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).
If we anonymize your personal data so that it can no longer be associated with you, we may use such information without further notice to you.
If you applied for a job, Motional will keep your personal data for two years after your last correspondence with us.
This Site is not designed for children and is not intended to appeal to children. Motional does not knowingly collect data from children. If you are under 16 years of age, please do not use this Site. If we learn that we have collected the personally identifying information of an individual under the age of 16 without obtaining the prior consent of the holder of parental responsibility over him/her, we will take steps to delete the concerned information. If you are a parent and you think we have inadvertently collected and processed personal data from your child who is under 16 (or under the age of majority where you live), you may contact us by sending an email to firstname.lastname@example.org to request that we delete their information from our records.
Our website contains hyperlinks to other websites, including sites, some third parties who manage our application process. This statement only applies to this Site, and when you click links to other websites, you should read their own privacy statement. The change in the URL amongst other factors will help you to recognize the website of other providers.
If you would like to exercise rights, or if you have any other questions about our use of your personal data, please send a request to email@example.com.
Privacy rights and choices
If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California, please refer to the respective dedicated sections below.
If you would like to exercise any rights as to personal data controlled by Motional, or if you have any other questions about our use of your personal data, please send a request to firstname.lastname@example.org. Please identify yourself and, for information relating to Motional products, specify your account and/or user information and other information to enable us to authenticate and respond to your request.
European data protection specific information
Data subjects rights
If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:
Right of access and/or portability – You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
Right of erasure – In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
Right to object to processing – In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
Right to rectification – You have the right to require us to correct any inaccurate or incomplete personal data;
Right to withdraw consent previously provided – You have the right to withdraw consent previously provided. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally consented to, unless we have another legitimate basis for doing so in law. Withdrawal, however, does not affect the lawfulness of processing your personal data that occurred prior to the date of withdrawal;
Right to restrict processing – You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
In order to exercise any of your rights as to personal data controlled by Motional, or if you have any other questions about our use of your personal data, please send a request to email@example.com. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data. Motional will respond to your request in a reasonable timeframe, and in any event within one month from receipt thereof.
If you are a resident of the European Economic Area (EEA), you have the right to make a complaint at any time to an EEA Data Protection Authority (DPA) about our management of your personal data. You can find your local DPAhere.
The legal basis on which we process information
Where required by law, we will ensure there is a legal basis for the processing of your personal data. Depending on the specific personal data concerned and the factual context, when Motional processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:
As necessary for our contract – When we enter into a contract directly with customers, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Motional products, features and services to customers and their users, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all products, features, and services;
As necessary to comply with our legal obligations – The processing is necessary to comply with our legal obligations, including compliance with applicable laws, regulations, governmental and quasi-governmental requests, court orders or subpoenas;
Consistent with specific revocable consents – The processing is based on your consent to the processing of your personal data for one or more specified purposes (e.g. marketing). You have the right to withdraw your consent to certain cookies at any time by visiting our cookie management tool;
To protect your vital interests or those of others – We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety; and
As necessary for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data – We process your personal data based on such legitimate interests, for example to develop and improve our sites, products and/or services for the benefit of our customers; develop, test, and improve our products and troubleshoot products and features; send marketing communications, advertising, and promotions related to the products; and comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.
International data transfer
Motional operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside your city, province, state, or country where it was initially collected, where Motional or its partners and service providers have customers or facilities. Data storage venues include, without limitation, the United States, Singapore, South Korea, and the European Union. These and other data storage jurisdictions may operate under privacy and data protection laws different and less protective from those of your home jurisdiction. Your submission of data to our Site and your consent to this Privacy Statement include consent to such storage and processing outside of your jurisdiction.
We protect your personal data in accordance with this Privacy Statement wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws. Where personal data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission’s standard contractual clauses. Please contact us if you would like further information in that respect.
California privacy rights
California Consumer Privacy Act
Under the California Consumer Privacy Act of 2018 (CCPA), California residents may have a right to:
Access the categories and specific pieces of personal data Motional has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Motional has shared personal data;
Delete personal data under certain circumstances; and
Motional will not discriminate against you for exercising any of these rights, which is further in line with your rights under the CCPA.
We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to 90 days) in writing.
Under the CCPA, only you or an authorized agent may make a request related to your personal data. Note that to respond to your requests to access or delete personal data under the CCPA, we must verify your identity. We may do so by requiring you to give a declaration as to your identity under penalty of perjury, and/or provide additional information. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.
California’s Shine the Light Law
California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your personal data (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share personal data with third parties for the third parties’ direct marketing purposes.
Changes to this Privacy Statement
We reserve the right to update this statement at any time and will notify you of the updated Privacy Statement by posting it on our website, with a “Last Updated” date at the top. We recommend that you review this Privacy Statement whenever you visit the Site. We reserve the right, at our sole discretion, to change, modify, add or remove portions of the privacy statement at any time by posting such changes to this page. Your continued use of the Site or services following the posting of changes constitutes your understanding of such changes.
If you have any questions about this statement, please submit it to firstname.lastname@example.org.