Last Updated: November 26, 2019
Thank you for doing business with Mobile Offer, Inc. dba “Freebird Rides”
“we,” “our,” or “us”).
We welcome you and hope you find our website and application (collectively, the
and useful. We have
our potential employees, and other business partners (“you” or
“your,”) understand what Data we
collect, store, share,
and use, how we do so, and what your rights are in regards to that Data.
We always seek to improve our Services to you, and that requires that we collect, store, share, and
about you and your usage preferences. As we do so, we are absolutely committed to protecting your
privacy and the
security of your personal information.
to you and your
use of our Services. “Data” is broken into different specific and general categories, which are
defined in the “Data We
separately, but when we use the word “Data,” we mean all the different categories described in this
portions of the
how we handle your
Data, please e-mail us at email@example.com.
Freebird provides a platform through which you can book rides from ride-sharing companies and
a discount or
other benefit from brands or the merchants whose businesses you visit using the Services
(“Merchant(s)”). The term Data,
Freebird is not
all the functions
made available by our tools, including the other services and professional services we provide
directly, are included in
the term “Services.” The term “Services” also includes any updates or additions to the current
Many jurisdictions require that we disclose to you the lawful basis for our processing of your Data.
We do that in the
based on either
your specific consent or your contract with us.
By accessing or using any of the Services or by otherwise interacting with us online or agreeing to
our Terms of
your Data is
based on your consent, you may withdraw your consent at any time, and we will cease collecting your
Data. However, in
some cases, this may result in your inability to receive partial or full access to the Services, and
your withdrawal of
consent does not limit our ability to use the Data that has been aggregated and anonymized for use
us in connection
with our legitimate business efforts in the future. In addition, your withdrawal of consent does not
prevent us from
retaining and processing Data if we are required or allowed to do so by applicable law or in order
claims. It also doesn’t prevent us from processing Data that has been gathered pursuant to a
lawful basis. For
example, if you give your consent for us to process your Data, but we are also required by law to
your Data, that
separate “lawful basis” will still apply, even if you withdraw your consent.
In all cases, we will comply with applicable law and we will cease processing your Data after the
obligation, or other lawful basis expires.
The Services are directed solely to persons 18 years of age or older or of children under 18 who are
supervised by a
parent, guardian, or other caregiver. Other than for Data collected for the specific purpose of
providing the Services
to users, we do not knowingly collect Data from users who are under 13. If we become aware that we
have gathered Data
from a person under 13, except to provide the Services to such person, then we will attempt to
such Data as soon
as possible, subject to our obligations under applicable law. If you believe that we have gathered
Data from a person
under 13 in contravention of this policy, please contact us at firstname.lastname@example.org. We never
the data of any
individual under the age of 16.
Listed below are the specific categories of Data we collect when you opt in to the Freebird Terms of
Service and Privacy
Policy, which are made available to you in the onboarding process when creating your Freebird
By onboarding in
Freebird you are agreeing to the collection and use of the below categories of information in order
use the Freebird
- Name (this data is provided by UBER/Lyft)
- Email (this data is provided by the user in onboarding and UBER/Lyft)
- Birthday (this data is optional for you, the user, to provide - the collection of this
information is required by a
particular brand partners due to federal regulations in place to be able to serve ad campaigns
ride offers to a
particular age group) Should you decide to not provide your date of birth you may not receive
of the offers you are
eligible for. When you make a request to transfer your accumulated funds in the Freebird app you
may be required to
provide your DOB to verify your identity with our banking partner.
for a full understanding
of the information they collect https://privacy.uber.com/policy/)
for a full understanding
of the information they collect https://www.lyft.com/privacy)
- Linked Card Transactions - if the user opts into linking a card or bank account via the Linked
Card screen to benefit
from our cash back offers we must provide the following data to the merchant providing the cash
back for a user’s ride:
Tokenized and anonymized transactions provided via Plaid
- Geo location - only accessed when in the app, we use your location to provide the best cash
offers in your area,
relevant to you.
- Device data (e.g. model, OS version)
These specific categories of Data are included in the general categories listed below and may be
depending on the general category in which the Data falls, as described below. We never sell your
data, and we always
have a lawful basis for gathering the Data, but that lawful basis might be different for different
Regardless, we never use the Data for any purpose other than the purpose for which we gathered the
Data in the first
place, unless we get your prior explicit consent.
Data Description: Registration Data consists of the following specific categories of
name, e-mail address, and
other contact information and onboarding data that you provide us using the Services, both when
account and thereafter. Registration Data also includes your username, date of birth, location,
client type (e.g.,
ad-supported or paid membership), and membership end date, if any.
Lawful Basis for Processing: Our lawful basis for processing Registration Data is our
contract with you. We can only provide certain of the Services
to you if we have the Registration Data, so we need to store and access that Registration Data
during the term of our
contract. Even when the Registration Data is not critically necessary to the provision of the
Services, we may still
process that Registration Data to facilitate our contractual interactions with you.
How We Use It and Who We Share It With: Registration Data is accessible only to us.
only to provide the Services to you. At times, we will share the
Registration Data with third parties at your request or to fulfill requests that you make of us.
may use your
Registration Data to offer goods or services to you, but only on an opt-in basis after getting
Data Description: Engagement Data consists of all the information you input or record
the Services, other than the Registration
Data, such as the following categories: Merchants visited, payment amounts, your communications
us regarding the
Services, credits offered by Merchants, offers provided by brands and similar items. Data that
qualifies as “Usage Data”
below is excluded from Engagement Data.
Lawful Basis for Processing: Our lawful basis for processing Engagement Data is (1)
contract with you and (2) our legitimate interest in
improving our Services based on the Engagement Data we receive from you.
How We Use It and Who We Share It With: Your Engagement Data is accessible only to
you, and where it relates directly to a party who either provides
services to you or receives services from you, such as a Merchant, to that party, in which case
party will be
obligated to protect the confidentiality of your Engagement Data. We do not share Engagement Data
with other third
parties, except at your specific request, but we may use Engagement Data to make inferences that
help us provide and
improve the Services. Both during the term of our agreement with you and thereafter, we may also
Engagement Data in
an anonymized and aggregated format that is not identifiable to any individual, and that
information belongs solely to us to use in our sole discretion (including to sell anonymized and
which is not Data). To the extent we are required to delete any Engagement Data about you, we may
aggregated and anonymized information that may have originated as your Engagement Data.
Data Description: Usage Data consists of the following and similar specific
Information about your interactions with the Services, most commonly our website, which
the date and time of
any requests you make. This also may include details of your use of Third-Party Applications
any advertising you
receive via the Services.
The timing of the information you post to the Services including messages you send and/or
receive via the Services and
your interactions with our customer service team, but not including the content of those
interactions and messages,
which would be included as Engagement Data.
Technical data which may include URL information, cookie data, your IP address, the types of
devices you are using to
access or connect to the Services, unique device IDs, device attributes, network connection
(e.g. WiFi, 4G, LTE,
Bluetooth) and provider, network and device performance, browser type, language, information
enabling digital rights
management, operating system, and application version.
Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or
if any, required for the
purposes of providing specific features of the Services to you.
Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our
with you and (2) our legitimate interest in improving our
Services based on the Usage Data we receive from you.
How We Use It and Who We Share It With: Usage Data is accessible to us and to you. We
not share it with third parties, except at your specific request, but we
may use Usage Data to make improvements to the Services. Both during the term of our agreement
with you and thereafter,
we may also use Usage Data in an anonymized and aggregated format that is not identifiable to any
individual, and that
anonymized and aggregated information belongs solely to us to use in our sole discretion
(including to sell anonymized
and aggregated information, which is not Data). To the extent we are required to delete any Usage
Data about you, we may
still retain aggregated and anonymized information that may have originated as your Usage Data.
Data Description: Payment Data is only collected when your use of the Services is
to the payment of a fee or other charge. Payment
Data is the information necessary for us to process your payments for premium Services. Payment
Data will vary depending
on the payment method you use (e.g. direct via your mobile phone carrier or by invoice) but will
categories of information such as:
Date of birth;
Credit or debit card type, expiration date, and certain digits of your card number;
Address and postal code; and
Mobile phone number
Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our
with you and (2) our legitimate interest in improving our
Services based on the Payment Data we receive from you.
How We Use It and Who We Share It With: We only use Payment Data to facilitate
we only communicate it to those parties who are strictly necessary
for that purpose.
In order to serve offers that are most relevant to you, Freebird will use the following
to serve ads to you:
The destination category the user is riding to and any past destination categories the rider has
shown interest in.
We often use the services of third parties to help us to recruit new employees and independent
contractors and to manage
our interactions with current employees and independent contractors. We do our best to contractually
ensure that these
third-party service providers comply with the policies we have adopted. However, we can’t guarantee
their compliance in
Our lawful basis for processing Data about potential and current employees and independent
contractors is our contract
with them and our legitimate interest in processing that Data, both to facilitate the formation of a
and to manage that relationship once it is formed. We only use employment Data for the direct
purpose of the employment
or independent contractor relationship, and we cease using it as soon as that relationship ends.
However, we may keep
and process that Data after the relationship ends when we are required to do so by applicable law or
to preserve legal
claims that may arise.
As part of the Engagement Data, we will also provide your transactional data, tokenized and
anonymized for your
protection, to the merchants to which you ride and with which you transact business, all in exchange
for ride cash back
provided by those merchants. Data provided to these merchants is intended for their sole use, and
we prohibit merchants
with whom we share your transactional data from sharing or selling your Data to any outside
Except where a specific limitation is noted above, we may share your Data as follows:
- At Your Instruction. If you request us to make your Data available to a third
party, and such request furthers the
purposes of our Services, we will do so.
- Sharing with Vendors and Service Providers. In certain cases, we use the
services of third-party vendors and service providers, such as Merchants and others, to
assist us in providing the Services. We may share your Data with such vendors and service
providers solely for that
purpose, and we will require those parties to abide by our privacy policies or privacy policies
consonance with ours.
- Third-Party Offers. We may allow other companies to offer you their products
and services, including offers through our Services, co-branded
pages hosted by the third parties, or via email. Whether or not you decide to participate in any
such offers is up to
you. If you purchase a product or service on a co-branded page, or via a third-party offer on
our Services that requires
you to submit financial and personal information, you are also consenting to our delivery of
this information to that
party. The offer will notify you if any financial or personally identifiable information will be
shared. Such third
party will be authorized to use this information in keeping with our contractual relationship
with them and in
third parties and you agree
that we are not liable for their acts, or any failure to act on their part.
- Third-Party Advertising. We may use aggregated, statistical information to
describe our membership and to establish advertising and other
business relationships with third parties. We may serve you with targeted advertisements based
on your personal or
profile information, but we do not provide any of this personal or profile information to an
advertiser or any third
party with the exception of those uses expressly disclosed in this policy. However, if you click
or view an ad on our
Services then you consent to the likelihood that the advertiser will assume that you meet the
targeting criteria, if
any, used to display such ad, and as described above, you will be subject to the advertiser's
information collection practices (if any).
- Third-Party Ad Servers. We may allow third-party ad servers or ad networks to
display advertisements on the Services. Some of these ad networks
web beacons. Doing this
allows them to recognize your computer each time they send you an online advertisement. In this
way, ad networks may
compile information about where you, or others who are using your computer, saw their
advertisements and determine which
ads are clicked on. This information allows an ad network to deliver targeted advertisements
that they believe will be
of most interest to you. We do not have access to or control over the cookies that may be placed
by these parties on
your computer, and we have no control over these parties' privacy policies or information
collection practices (if any).
- Service Providers. We may sometimes use a third party to provide specific
Services on our behalf, including sending e-mails to our members,
conducting member surveys, processing transactions or performing statistical analysis of our
Services. In these cases,
we may provide certain personal information, such as your name and e-mail address and other
necessary for the service to be provided. However, these third parties are required to maintain
the confidentiality of
this information and are prohibited from retaining, sharing, storing or using this information
for any other purposes.
- Internet Service Providers. We may provide certain portions of your Data,
such as your email address or name, back to your internet service provider
if we have an existing advertising relationship with them. This is done to allow them to target
or discontinue your
exposure to our advertisements, once you have become a participating member of our Services. As
part of our agreement
with your internet service provider, they will be required to maintain this information in a
confidential manner and use
- Business Transitions. In the event that we go through a business transition,
such as a merger, acquisition, liquidation or sale of all or a
portion of our assets, the information we have about you will, in most instances, be part of the
assets transferred. We
reserve the right to transfer that information in connection with such transactions without
notice to you. We will not
be required to obtain your consent for such a transfer.
- Legal Disclosure. We may disclose your Information if required to do so by
law or in the good faith belief that such action is necessary
to conform to applicable law, comply with a judicial proceeding, court order or legal process
served on us, protect and
defend our rights or property, or investigate, prevent or take action regarding illegal
activities, suspected fraud,
situations involving potential threats to the physical safety of any person, or violations of
our terms of service.
- Publicly Disclosed Data. Certain items of Data are always publicly available,
such as your username, people who follow your playlists, and the
playlists you follow.
If we ever plan to use any Data in the future for any other purposes not identified above and we
do not have a separate
lawful basis for that new purpose for processing, we will only do so after obtaining your specific
The technologies we use for automatic Data collection may include the following:
Cookies (or browser cookies). A cookie is a small file placed on the
hard drive of your computer. You may refuse to accept browser cookies by
activating the appropriate setting on your browser. However, if you select this setting you may
be unable to access
certain parts of our Services. Unless you have adjusted your browser setting so that it will
will issue cookies when you direct your browser to our Services.
Flash Cookies. Certain features of our Services may use local stored
objects (or Flash
cookies) to collect and store information about
your preferences and navigation to, from and on our Services. Flash cookies are not managed by
the same browser settings
as are used for browser cookies.
Web Beacons. Pages of the Services and our e-mails may contain small
electronic files known as web beacons (also referred to as clear
gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who
have visited those
pages or opened an e-mail and for other related website statistics (for example, recording the
popularity of certain
website content and verifying system and server integrity).
We only use your Data for marketing purposes if you give us your specific consent. If, after
giving your consent, you
wish to opt-out of our sharing of your information with third parties for the third parties’
or if you wish to stop receive marketing e-mails from us, please follow the instructions below.
(Note that if you are a
resident of the European Union, we will never use your personal data for third-party marketing
purposes unless you have
clicked on a box online to expressly give consent for such use.)
Receiving electronic communications from us: If you no longer want to
receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving
these marketing-related emails by sending a request for list removal to email@example.com.
Our sharing of your Data with unaffiliated third parties for their (or their
customers') direct marketing purposes: If you would prefer that we do not share your
information on a going-forward basis with unaffiliated third parties for
their direct marketing purposes, you may opt-out of this sharing by emailing firstname.lastname@example.org from the
email that you have signed up or used in receiving the Services.
Any other disclosure of your Data: Except as provided in this Privacy
Policy regarding anonymized and aggregated Data and except for Data that is processed
by us pursuant to a lawful basis based on our legitimate interests and contracts with you, you
may instruct us to cease
disclosure or use of your Data by requesting an account deletion at www.freebirdrides.com/optout/.
We will try to comply with your request(s) as soon as reasonably practicable. Please also note
if you do opt-out of
receiving marketing-related emails from us, we may still send you messages for administrative or
other purposes directly
relating to your use of the Services, and you cannot opt-out from receiving those messages.
The General Data Protection Regulation made effective in Europe on May 25, 2018 (“GDPR”) requires
that we clearly
that, and you may request a copy of your data by completing the data request form found at
The GDPR also requires that we have a lawful basis for our processing of any personal data about
an individual residing
in Europe. For an individual browsing our website or otherwise accessing our Services, our lawful
basis is our
legitimate interest in providing the Services to you in the manner that you desire, and all the
Data that we collect
For an individual
purchasing products from us, our lawful basis is the contract under which you purchase products,
and the Data we collect
from such individuals will be used only in connection with our contractual relationship with you
and only in a manner
For employees and other authorized users operating in their role as administrators or users of our
services, our lawful
basis is the legitimate interest we have in providing the services to their employer.
The GDPR also requires us to take appropriate technical and organizational measures to protect the
security of Data
relating to residents of Europe. We make commercially reasonable efforts to ensure the privacy and
security of the Data
of our European visitors and customers, and we are happy to give you a complete description of our
most current efforts,
if you will write us at email@example.com.
Pursuant to the GDPR, residents of Europe have the right to obtain our confirmation of whether we
information relating to them in the United States. If you are a resident of Europe, upon request
from you, we will
provide you with access to the Data that we hold about you. You may also correct, amend, or delete
the Data we hold
about you, subject to our rights and obligations under the GDPR, as described in this Privacy
Policy. Individuals who
seek access, or who seek to correct, amend, or delete Data transferred to the United States,
should direct their queries
If requested to remove Data, we will respond
within a reasonable timeframe.
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to
respond to requests from
California customers asking about businesses’ practices related to disclosing personal information
to third parties for
the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a
policy not to disclose
personal information of customers to third parties for the third parties’ direct marketing
purposes if the customer has
exercised an option to opt-out of such information-sharing. If you wish to opt-out of our sharing
of your information
with third parties for the third parties’ direct marketing purposes offline, please inform us by
writing us at
California has also adopted the California Consumer Privacy Act (“CCPA”), which will take effect
at the beginning of
2020. Freebird complies with the requirements of the CCPA to the extent they apply to us.
If you are a California resident, you have the following rights:
You have the right to request that we disclose the categories and the specific items of Data
about you that we collect,
use, disclose, and/or sell and that Data about you that we have collected, used, disclosed,
and/or sold during the 12
months prior to your request.
You also have the right to have the Data we collect about you deleted. We use a two-step
process to verify your identity
and to have the information deleted. Your rights to have Data deleted are subject to several
the Data that is necessary for us to:
complete your transaction;
provide you a good or service;
perform a contract between us and you;
protect your security and prosecute those responsible for breaching it;
fix our system in the case of a bug;
protect the free speech rights of you or other users;
comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546
engage in public or peer-reviewed scientific, historical, or statistical research in the
public interests that adheres
to all other applicable ethics and privacy laws;
comply with a legal obligation; or
make other internal and lawful uses of the information that are compatible with the
context in which you provided it.
To make any request under the CCPA, you must complete the Data Request Form found at www.FreebirdRides.com/optout.
will be asked to give us your name, e-mail address, telephone number, and any other
information we request to reasonably
verify your identity. We will respond to your request within 10 days after receipt of your
request, and we will then
take action to verify your identity and fulfill your request, as required by the CCPA.
We will provide you with a CSV copy of your stored data within 45 days of your request,
assuming we are able to verify
your identity in that period and so long as you provide a correct email address for successful
You have the right not to receive discriminatory treatment by us for the exercise of any
privacy rights conferred by the
CCPA, which means that we will not take any action to hurt or punish you for exercising your
rights under the CCPA.
You may designate an authorized agent to make a request under the CCPA on your behalf by
writing us at
firstname.lastname@example.org. Upon receipt of your request, we will provide you with the
information you will need to
designate that agent.
Note that we are not allowed by law to at any time disclose your Social Security number, driver’s
license number, or
other government-issued identification number, financial account number, any health insurance or
number, or any account password or security questions or answers.
We have listed the specific and general categories of information we have collected, disclosed, or
sold in the last 12
months in the section above entitled “Data We Collect and How We Use It.” That section also lists
the specific and
general categories of Data we have disclosed to third parties for our business purposes.
We do not sell your Data. However, we do disclose certain categories of Data to the merchants
whose businesses you visit
using the Services, all as described in the section entitled “Data We Collect and How We Use It”
We do not sell the personal information of minors under 16 years of age.
For more information, please direct your questions to us at email@example.com.
You can also direct questions
to our toll free number at 1-888-516-6697.
The security of your Data is important to us. We use commercially reasonable efforts to store and
maintain your Data in
a secure environment. We take technical, contractual, administrative, and physical security steps
designed to protect
Data that you provide to us. We have implemented procedures designed to limit the dissemination of
your Data to only
such designated staff as are reasonably necessary to carry out the stated purposes we have
communicated to you.
You may be able to access third-party websites and other tools and services or products via a link,
or via our other
tools. The privacy policies of these third parties are not under our control and may differ from
ours. The use of any
party or by your
independent agreement with such third party, as the case may be. If you have any doubts about the
privacy of the
information you are providing to a third party, we recommend that you contact that third party
directly for more
other practices of any
third parties, including any third party operating any offering, site or other products and Services
used in connection
with the Services. The inclusion of a link does not imply endorsement of the linked site or service
by us or by our
We will keep your information for as long as it remains necessary for the identified purpose or as
required by law,
which may extend beyond the termination of our relationship with you. We may retain certain data as
necessary to prevent
fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated,
data, account recovery, or if required by law. All retained information will remain subject to the
terms of this Privacy
Policy. Please note that if you request that your information be removed from our databases, it may
not be possible to
completely delete all of your information due to technological and legal constraints.
Policy in the
effective on the date
that is 30 days from their posting on the Services or sent via email to your listed email address.
The date on which the
latest update was made is indicated at the top of this document. We recommend that you print a copy
of this Privacy
Policy for your reference and revisit this policy from time to time to ensure you are aware of any
continued use of the Services signifies your acceptance of any changes.
You have the right to access the information we hold about you in order to verify the information we
have collected in
respect to you and to have a general account of our uses of that information. Upon receipt of your
written request, we
will provide you with a copy of your information, although in certain limited circumstances we may
not be able to make
all relevant information available to you, such as where that information also pertains to another
user. In such
circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal
with all requests for
access and modifications in a timely manner.
We will make every reasonable effort to keep your information accurate and up-to-date, and we will
provide you with
mechanisms to update, correct, delete or add to your information as appropriate. As appropriate,
information will be transmitted to those parties to which we are permitted to disclose your
information. Having accurate
information about you enables us to give you the best possible service.
You can help by keeping us informed of any changes such as a change of your personal contact
information. If you would
like to access your information, if you have any questions, comments or suggestions of if you find
any errors in our
information about you, please contact us at firstname.lastname@example.org. If you have a complaint concerning our
compliance with applicable privacy laws, we will investigate your complaint, and if it is justified,
we will take
All Rights Reserved.