Este documento é publicado em inglês. O texto em inglês é a versão que vale juridicamente; uma tradução, quando houver, serve apenas para facilitar a leitura.
What this Privacy Policy covers
Chirp Software, Inc. ("Windshield Weather," "we", "us" or "our") provides a route weather service: you tell it where you are driving and when, and it plans the forecast along that route and reads you a briefing before you leave. This Privacy Policy describes how Windshield Weather processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website at windshieldweather.com, our mobile, desktop and in-car applications) as well as the other activities described in this Privacy Policy (collectively, the "Service").
California Notice at Collection / State Privacy Rights Notice: see the State privacy rights notice section below for important information about your rights under applicable state privacy laws.
Notice to European users: please see the section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as "Europe", and "European" should be understood accordingly) below.
Windshield Weather in ChatGPT and Claude
Assistant tools (MCP). Our public drive and highway forecasts need no account. We process named endpoints, departure time and units to answer a request. We do not retain tool inputs, geocodes, conversation, user or session identifiers in MCP analytics, logs or error reports. We count tool use, coarse distance bands, actual vendor calls and outcomes without a person profile. Each tool also offers an optional intent field: a short abstract purpose used to understand which planning tasks people need. Before recording it, we remove the request’s place and highway names, URLs, numbers and identifiers and limit it to 200 characters; when absent, we infer a generic purpose from the tool. It is never required and does not change the forecast. A host-supplied city or region can fill a missing origin; precise coordinates and street addresses are not accepted by these tools.
Trip links contain authenticated encrypted named endpoints, departure time and units, never coordinates. There is no stored trip-link record or expiry; anyone holding the link can open that drive, and a departure already passed becomes Now. We count link views and store clicks without an identifier. Continuing in the app uses the normal account and analytics controls. Android can recover a first-party drive link through Google Play’s install referrer independently of marketing consent; on iPhone you must tap the original link again after installing. Your assistant host processes your conversation under its own terms and privacy policy.
The assistant name and language help format the answer. A ChatGPT anonymous subject ID is held only in memory for a 20-call-per-hour limit and never stored or sent to analytics. Named places are geocoded and routed by Mapbox; weather comes from our forecast store. The shared route cache lasts an hour.
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes the categories below.
- CONTACT DATA
- Your email address. It is the address you sign in with and the address we send account mail to.
- PROFILE DATA
- The password you may set to establish an online account on the Service, your display name, and a profile picture where the sign-in provider supplies one.
- PREFERENCE DATA
- The settings your account carries: units, clock, map style and layers, how the route is drawn, language, and your choices for analytics and marketing email.
- COMMUNICATIONS DATA
- Based on our exchanges with you. If you write to us through the contact form on the website, that is your name, your email address, the topic you chose and the message you wrote. We also keep a record of the transactional emails we send you — the recipient address, the subject, which message it was and whether it was delivered — so that support can answer "did that code ever arrive".
- MARKETING DATA
- Your preferences for receiving our marketing communications.
- DRIVE DATA
- The places you search for, the start and end of a drive, the route between them, your departure time, and the forecast and briefing we produce for that drive. When you are signed in, the drives you save — their places, including a start taken from your device's position, the departure, any stops and a label — and your display settings are stored against your account so that your other devices can show them. If you enable drive alerts, we also keep your choices and time zone, derived forecast summaries, official warning identifiers and notification delivery receipts against your account to decide which updates to send. Alert summaries and receipts are removed within 24 hours after the planned arrival or after you turn alerts off; deleting the drive or account removes its alert data. Alerts use the planned departure and stops, and do not collect background location. We do not store route geometry or briefing audio with these alert records.
- OTHER DATA
- Not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Sources other than you, and data we collect automatically
Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as: service providers that provide services on our behalf or help us operate the Service or our business; business transaction partners, from whom we may receive personal information in connection with an actual or prospective business transaction, such as an entity we acquire or are acquired by, a successor, or an assignee or any party involved in a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership; and third-party services, such as Sign in with Apple and Sign in with Google, that you use to log into, or otherwise link to, your Service account. Data from those sign-in services may include your name and email address as that service makes them available to us based on your account settings there.
Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, such as the categories below.
- DEVICE DATA
- Your device's operating system type and version, application version, device type, browser type where you use the website, IP address, language settings and time zone. Your IP address and browser or app user agent are recorded against each sign-in session. When you are signed in, which of our apps you use (iPhone or iPad, Mac, Android, the car app or the website), its version and when you last used it are recorded against your account, so that we can tell you when an update is needed and support the versions in use. For notification-enabled accounts we also store the device's push token or browser push subscription, notification permission and language. Notifications pass through Apple Push Notification service, Firebase Cloud Messaging or your browser's push service. They may include the route's place names and weather conditions on the lock screen; you control notification previews in your device settings.
- ONLINE ACTIVITY DATA
- Access times, account actions such as sign-in and settings changes, app screen and lifecycle events, the requests your device makes to our servers in the course of planning a drive, and the identifier our analytics provider assigns to your app session. While Analytics is on, we also record session replays of how you move through our iPhone, iPad and Android apps and the web planner. In them, text is masked except weather readouts, so what you type and place, route, drive and account text are masked. In the phone and tablet apps the map, including your route line and its labels, is visible; in the web planner the map is not recorded. When you visit our website without being signed in, we count page views without cookies or local storage and without identifying you: PostHog estimates unique visitors from a daily hash it computes on its servers, and page addresses are sent without their query strings apart from campaign tags. On those pages we also record which links and buttons are clicked, without their text, where on the page people click, move the pointer and scroll, as positions without any text, how quickly pages load, and the country your connection comes from, which our hosting provider tells us; never a more precise location. Clicks and positions are not recorded on the sign-in and account pages. We do not send route coordinates, search text, email addresses or credentials as analytics event properties.
- ACQUISITION DATA
- If you choose to allow link attribution after opening a campaign link, we keep the link's Dub click identifier and the time you opened it. After sign-in, we associate that identifier with your account identifier to measure whether the link led to an account. The choice is optional and does not affect navigation or sign-in.
- LOCATION DATA
- Your device's position, when you authorize the application to access it, so that a drive can start from where you are. It is read only while you are using the app and only when you ask for it — the application does not request background location and does not track you between drives. You can decline and type a starting place instead. Coordinates along a planned route are sent to our servers to fetch the forecast for each part of it; those requests are not recorded against your account. When you save a drive that starts from your position, that starting point is stored with the drive as described under Drive data.
Tracking and other technologies
Cookies and other technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. The website uses them to keep you signed in and to remember the language you chose. If you allow link attribution, a first-party cookie temporarily carries the campaign click identifier through sign-in. We do not use cookies or similar technologies for advertising, and we have no advertising partners.
Artificial intelligence ("AI") technologies. The drive briefing is written by a large language model hosted on Microsoft Azure OpenAI Service and spoken by a synthetic voice from ElevenLabs. What reaches them is a description of the drive: the place names along the route, the times, and the forecast conditions at each one. Coordinates are not sent to either. Neither receives your name, your email address or your account identifier. We contractually require these providers to maintain appropriate data protection safeguards.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection.
Service delivery and operations. To provide the Service; to enable security features of the Service; to establish and maintain your user profile on the Service; to communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and to provide support for the Service, and respond to your requests, questions and feedback.
Service personalization. To understand your needs and interests; to personalize your experience with the Service and our Service-related communications; and to remember your selections and preferences as you navigate the Service.
Service improvement. To analyze usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, and to develop new products and services.
Direct marketing. We may send you direct marketing communications about the Service. These are off unless you turn them on, and you may opt out at any time as described in the Your choices section below. Account mail — the code that verifies your address, the code that signs you in, and a password reset link — is not marketing and is not governed by that switch.
Compliance and protection. To comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities; to protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); to audit our internal processes for compliance with legal and contractual requirements or our internal policies; to enforce the terms and conditions that govern the Service; and to prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events — for more information, see How we share your personal information, below.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and that of other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you, and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including analyzing and improving the Service and promoting our business.
Further uses. In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which the information was collected.
Retention
We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.
In practice, for this Service:
- ACCOUNT
- Kept until you delete your account. Deleting it takes effect immediately: every session and token is revoked, your saved credentials and linked sign-in providers are deleted, and your email address, name and profile picture are overwritten rather than merely hidden. Your settings and consents are deleted with them.
- ANALYTICS
- When you delete your account, our servers ask PostHog, our analytics provider, to delete everything it holds for your account: the profile with your account identifier, email address and settings, its events and its session replays. The request is sent within the hour and repeated until PostHog accepts it; PostHog then completes the deletion on its own systems. We also tell PostHog that an account was deleted, with how old it was and whether Analytics was on, without any identifier, so that it can count deletions.
- AFTER DELETION
- Two things outlive a deleted account, and neither identifies you by name: a record that an account once existed and when, so that the count of early users stays auditable after they leave; and the record of what that account was entitled to. Both carry an internal identifier rather than your email address or your name.
- DRIVES
- Saved drives, including their stops, and your display settings are kept against your account until you delete them or delete your account. Deleting a drive removes its contents from our servers and leaves only an internal identifier, so that your other devices remove it too. Each device you sign in on keeps its own copy, and erases it when you sign out or when it next connects after your account is deleted; the device you delete your account from erases its copy at once.
- FORECASTS AND BRIEFINGS
- The forecasts, routes and briefings we generate are cached by the drive itself — coordinates and a departure hour — so that two people driving the same road at the same hour are answered once. Those caches are not linked to any account, and they are not served after an hour for routes and forecasts, or after six hours for briefings. Our iPhone, iPad, Mac and Android apps keep a drive's latest forecast on your device so that it can be read without a connection; after a day it is shown as out of date, and it is removed when the drive or your account is deleted or when the app needs the space.
- SIGN-IN CODES
- Short-lived, and valid only for the minutes printed in the message that carries them.
- EMAIL RECORDS
- We keep a record of each transactional email we sent — the recipient address, the subject, which message it was and whether it was delivered, never the message body — so that a report of a code that never arrived can be investigated. This record is kept separately from your account and is not erased when you delete your account.
- SUPPORT MESSAGES
- A message you send us through the contact form reaches us as email and is kept in our mailbox so that we can answer you and follow up.
How we share your personal information
We may share your personal information with the parties below (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection). We do not sell it, we do not share it for targeted advertising, and we have no advertising partners.
- AFFILIATES
- Our corporate parent, subsidiaries, and affiliates.
- SERVICE PROVIDERS
- Third parties that provide services on our behalf or help us operate the Service or our business, such as hosting, information technology, customer support, email delivery, and the mapping, weather and AI providers named below.
- MAPBOX
- Maps, place search, geocoding and routing. Receives the places you search for and the coordinates of your route. The map itself is drawn on your device by Mapbox's own software, which requests map tiles directly from Mapbox; those requests carry your device's IP address and the part of the map you are looking at, and are subject to Mapbox's own privacy policy.
- XWEATHER
- Forecast data. Receives the coordinates and times of the sections along your route, snapped to a coarse grid. Not your name, email address or account. For some accounts, some or all sections are forecast instead by our own forecast service, from public weather-model data we hold: the coordinates and times of those sections stay on our infrastructure and are not sent to Xweather. Any section our service does not answer is still sent to Xweather. The weather layers drawn on the map come from our own radar service, not from Xweather.
- AZURE OPENAI
- Writes the drive briefing. Receives the place names along the route and the forecast conditions at each one, not coordinates. Not your name, email address or account.
- ELEVENLABS
- Speaks the drive briefing. Receives the text of the briefing.
- RESEND
- Delivers our transactional email. Receives your email address and the message.
- POSTHOG
- Feature flags, product analytics and session replay. When our servers decide which features your account sees, PostHog receives your account identifier and email address. While Analytics is on, it also receives your account identifier, email address and account settings as a profile, bounded app and server activity events, session identifiers and masked session replays. While Analytics is on, it also records which features our servers checked for your account. It does not receive drive routes, coordinates, search text or credentials as analytics event properties. Without identifying anyone, it receives counts of accounts deleted and of Analytics being turned off, and a daily total of accounts.
- DUB
- Measures campaign links and, only when you allow link attribution, whether a link led to account creation. A conversion receives the link click identifier and our account identifier, not your name, email address, drive, route or location.
- SENTRY
- Crash reporting, performance tracing and diagnostic logs, so that faults can be diagnosed. Receives device information and technical interaction state, such as which sheets open or close, their sizes, scroll positions and presentation identifiers. While Analytics is on, a crash report also carries the identifier of your analytics session, and in the web planner a link to its replay, so a fault can be matched to what happened. Sheet diagnostics exclude place names, route coordinates, account details and text you enter. When you are signed in, an error report carries our account identifier, so that a fault can be traced to the account it affected; it does not carry your name or email address. When a page on our website loads something its security policy does not expect, your browser sends Sentry a report naming the page, the address that was not expected and your browser's user agent; the sign-in and account pages send none.
- CLOUDFLARE · AWS
- Hosting, content delivery, and the database. They hold the data described in this policy in order to run the Service and for no other purpose. The radar and wind layers drawn on the map are served to your device from our own domain through Cloudflare; those requests carry your device's IP address and the part of the map you are looking at.
- APPLE · GOOGLE
- Sign in with Apple and Sign in with Google, where you choose to use them, and the app stores that distribute the applications. Their own terms and privacy policies govern your relationship with them.
- THIRD PARTIES YOU NAME
- We may share your personal information with third parties where you have instructed us or provided your consent to do so.
- PROFESSIONAL ADVISORS
- Professional advisors, such as lawyers, auditors, bankers and insurers, in the course of the professional services that they render to us.
- AUTHORITIES
- Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
- BUSINESS TRANSFEREES
- We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Windshield Weather, financing of Windshield Weather, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). We may also disclose your personal information to an acquirer, successor, or assignee as part of any such transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Your choices
In this section, we describe the rights and choices available to all users. Users who are located in certain U.S. states and in Europe can find additional information about their rights below.
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by signing in to the account.
Opt out of communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, by changing the setting on your account, or by contacting us. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Privacy settings. Product analytics is on by default. The Analytics switch controls collection in our iOS, Mac and Android apps and the web planner across devices where you are signed in. Turning it off stops everything we send PostHog about your account: app events, session replay, server-side activity such as sign-in, account changes and feature use, and updates to your analytics profile. Our servers still use your account identifier and email address to decide which features your account sees, and counts of server use that are not linked to your account continue. When you turn Analytics off, we count that it was turned off, without recording who. Automatic element interaction capture is off in the apps and the web planner; on the website, for visitors who are not signed in, we record which links and buttons are clicked, without their text, and where clicks, pointer movement and scrolling land on the page.
Link attribution. Opening a campaign link does not require you to allow account attribution. You may decline the prompt and still use the Service. If you allow it, the website keeps the click identifier in a first-party cookie for up to 30 days while you sign in. Link attribution requires an explicit affirmative choice; turning Analytics off removes pending attribution and prevents later conversion delivery.
Location data. You can decline the Service's access to your device's location in your device settings, and plan a drive by typing a starting place instead.
Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through your account with Apple, Google or another third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
Delete your account. You can delete your account from within the application, or at https://windshieldweather.com/delete if you no longer have it installed. Deletion is immediate and cannot be undone.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Users in Europe should read the important information provided in the Data processing outside Europe section below.
Children
The Service is intended for people aged 15 and older and is not intended for anyone under 15. Users under 18 or the age of legal majority where they live must have permission from a parent or legal guardian who has reviewed our Terms of Use and this Privacy Policy. Any higher minimum age or consent requirements imposed by applicable law also apply. If you are a parent or guardian who believes we have collected personal information from someone under 15, or from a minor in a manner prohibited by law, please contact us at [email protected]. If we learn that we have collected personal information from someone under 15 or without consent required by applicable law, we will take appropriate steps to delete the information in accordance with applicable legal requirements.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
How to contact us
If you have questions about our practices or if you would like to exercise any privacy related right that may be available to you, please contact us by email at [email protected], or by post at 2261 Market Street STE 86781, San Francisco, California 94114. For help with the Service itself, write to [email protected].
State privacy rights notice
Except as otherwise provided, this section applies to residents of U.S. states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the "State Privacy Laws").
This section describes how we collect, use, and share Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it. We authenticate a request against the account it concerns: signing in to the Service requires either a password, a six-digit single-use code sent to the account's email address, or Sign in with Apple or Sign in with Google, and a request made from a signed-in session is treated as verified on that basis. Where a request arrives by email, we may ask you to confirm control of the address on the account before acting on it.
For purposes of this section, the term "Personal Information" has the meaning given to "personal data", "personal information" or other similar terms and "Sensitive Personal Information" has the meaning given to "sensitive personal information," "sensitive data", or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws.
Your privacy rights. The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.
Information. You can request the following information about how we have collected and used your Personal Information: the categories of Personal Information that we have collected; the categories of sources from which we collected Personal Information; the business or commercial purpose for collecting Personal Information; the categories of third parties with which we share Personal Information; and the categories of Personal Information that we disclosed for a business purpose, and the categories of third parties to whom it was disclosed.
Access. You can request a copy of the Personal Information that we have collected about you.
Appeal. You can appeal our denial of any request validly submitted.
Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-out of certain processing for targeted advertising purposes. We do not process your personal information for targeted advertising purposes.
Opt-out of or appeal profiling/automated decision making. We do not use your Personal Information to engage in profiling or to perform automated decision-making that results in significant financial impacts, significant impacts on housing, education, employment, health care, or criminal justice, or similarly significant impacts.
Opt-out of other sales of personal data. We do not sell your Personal Information within the meaning of State Privacy Laws.
Consumers under 16. As described above, the Service is intended for people aged 15 and older, so we may collect personal information from 15-year-old users. We do not sell personal information or share it for cross-context behavioral advertising, including the personal information of consumers under 16.
Sensitive Personal Information. While we process certain categories of Sensitive Personal Information as described in this Privacy Policy — specifically, the precise location you allow the application to read, and the coordinates of a route you ask us to plan — we do not process Sensitive Personal Information for the purpose of inferring characteristics about consumers under the CCPA.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.
Exercising your state privacy rights. You may submit a request to exercise any of the state privacy rights listed above by email to [email protected]. You can delete your account, and with it the personal information described in the Retention section, at https://windshieldweather.com/delete or from within the application.
Verification of identity; authorized agents. We may need to verify your identity in order to process your information, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require a declaration under penalty of perjury or other information, where permitted by law. Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent's identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
Information practices. The following describes our practices currently and during the past 12 months. Sources and purposes: we collect the categories of personal information from the sources and use them for the business and commercial purposes described above in this Privacy Policy. Retention: the criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations. Deidentification: we do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.
Personal information we collect, use and disclose
We have summarized below the Personal Information we collect, the purposes for which we collect it and the third parties to whom we may disclose it, by reference to both the categories used in the Personal information we collect section of this Privacy Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). This chart describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us may contain other categories of personal information not described below. We do not "sell" or "share" any category of Personal Information.
- CONTACT DATA
- CCPA category: identifiers. Purposes: service delivery and operations, direct marketing, compliance and protection. Disclosed for a business purpose to: service providers (email delivery, hosting), professional advisors, authorities, business transferees. Sold or shared: none.
- PROFILE DATA
- CCPA category: identifiers; customer records information. Purposes: service delivery and operations, service personalization, compliance and protection. Disclosed for a business purpose to: service providers (hosting), professional advisors, authorities, business transferees. Sold or shared: none.
- PREFERENCE DATA
- CCPA category: customer records information. Purposes: service delivery and operations, service personalization. Disclosed for a business purpose to: service providers (hosting). Sold or shared: none.
- COMMUNICATIONS DATA
- CCPA category: customer records information; electronic mail information. Purposes: service delivery and operations, compliance and protection. Disclosed for a business purpose to: service providers (email delivery, hosting), professional advisors, authorities. Sold or shared: none.
- MARKETING DATA
- CCPA category: commercial information. Purposes: direct marketing. Disclosed for a business purpose to: service providers (email delivery, hosting). Sold or shared: none.
- DRIVE DATA
- CCPA category: internet or other electronic network activity information; precise geolocation data. Purposes: service delivery and operations, service improvement, creation of aggregated and de-identified data. Disclosed for a business purpose to: service providers (mapping and routing, weather data, AI briefing and text-to-speech, hosting). Sold or shared: none.
- DEVICE DATA
- CCPA category: identifiers; internet or other electronic network activity information. Purposes: service delivery and operations, security, service improvement, compliance and protection. Disclosed for a business purpose to: service providers (hosting, error reporting). Sold or shared: none.
- ONLINE ACTIVITY DATA
- CCPA category: internet or other electronic network activity information. Purposes: service delivery and operations, security, service improvement. Disclosed for a business purpose to: service providers (hosting, error reporting). Sold or shared: none.
- LOCATION DATA
- CCPA category: precise geolocation data, which is Sensitive Personal Information. Purposes: service delivery and operations only — to start a drive from where you are and to fetch the forecast along it. Not used to infer characteristics about you. Disclosed for a business purpose to: service providers (mapping and routing, weather data, hosting). Sold or shared: none.
Additional information for California and Nevada residents
Shine the Light law. Under California's Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to [email protected]. In your request, you must include the statement "Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Additional information for Nevada residents. Nevada residents have the right to opt out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email [email protected].
Notice to European users
Where this notice applies. The information provided in this "Notice to European users" section applies only to individuals in the United Kingdom and the European Economic Area (i.e., "Europe" as defined at the top of this Privacy Policy).
Personal information. References to "personal information" in this Privacy Policy should be understood to include a reference to "personal data" (as defined in the GDPR) — i.e., information about individuals from which they are either directly identified or can be identified.
Controller. Chirp Software, Inc. is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (that is, the EU General Data Protection Regulation and the UK General Data Protection Regulation, as and where applicable, the "GDPR"). See the How to contact us section above for our contact details.
Our legal bases for processing. In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a "legal basis" for that use. Ours are: where we need to perform a contract we are about to enter into or have entered into with you ("Contractual Necessity"); where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests"); where we need to comply with a legal or regulatory obligation ("Compliance with Law"); and where we have your specific consent to carry out the processing for the purpose in question ("Consent"). The legal bases we rely on for each purpose are set out below.
- SERVICE DELIVERY
- Contact data, Profile data, Preference data, Communications data, Drive data, Location data, Device data. Legal basis: Contractual Necessity.
- SECURITY
- Contact data, Device data, Online activity data. Legal basis: Compliance with Law; and Legitimate Interests — we have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks.
- IMPROVEMENT
- Preference data, Device data, Online activity data, Drive data. Legal basis: Legitimate Interests — we have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences. Consent, in respect of any optional cookies used for this purpose.
- DIRECT MARKETING
- Contact data, Profile data, Marketing data. Legal basis: Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications; and otherwise Legitimate Interests — we have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose.
- COMPLIANCE
- Contact data, Device data. Legal basis: Compliance with Law. Legitimate Interests — where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities, and in ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
- CORPORATE EVENTS
- Any and all data types relevant in the circumstances. Legal basis: Legitimate Interests — we and any relevant third parties have a legitimate interest in providing information to relevant third parties who are involved in an actual or prospective corporate event. We would always look to take steps to minimize the amount and sensitivity of any personal information shared in these contexts where possible and appropriate.
- AGGREGATED DATA
- Any and all data types relevant in the circumstances. Legal basis: Legitimate Interests — we have a legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Service operates as intended.
- FURTHER USES
- Any and all data types relevant in the circumstances. Legal basis: the original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected; Consent, if it is not.
Retention and your rights in Europe
Retention. We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for Compliance and protection purposes. To determine the appropriate retention period we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information so that it can no longer be associated with you, we may use this information indefinitely without further notice to you.
No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. If you provide us with any such information when you use the Service, you must consent to our processing and use of it in accordance with this Privacy Policy. If you do not consent, you must not submit it through our Service.
No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling which produces legal or similarly significant effects.
General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold: Access — provide you with information about our processing of your personal information and give you access to it. Correct — update or correct inaccuracies in your personal information. Delete — delete your personal information where there is no good reason for us continuing to process it; you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing. Transfer — transfer a machine-readable copy of your personal information to you or a third party of your choice. Restrict — restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it. Object — object to our processing of your personal information where we are relying on Legitimate Interests; you also have the right to object where we are processing your personal information for direct marketing purposes. Withdraw Consent — when we use your personal information based on your consent, you have the right to withdraw that consent at any time.
Exercising these rights. You may submit these requests by email to [email protected] or to our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information); if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.
Your right to lodge a complaint with your supervisory authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence. For users in the European Economic Area, contact details for each national data protection authority are published by the European Data Protection Board. For users in the UK, the regulator is the Information Commissioner's Office, Water Lane, Wycliffe House, Wilmslow, Cheshire SK9 5AF, telephone +44 303 123 1113.
Data processing outside Europe
We are a U.S.-based company and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
It is important to note that the US is not the subject of an "adequacy decision" under the GDPR — this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information equivalent to that provided by relevant European laws.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented. Transfers to territories with an adequacy decision: we may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) from time to time. Transfers to territories without an adequacy decision: we may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above). However, in these cases we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe — for example, standard-form contracts approved by relevant authorities for this purpose; or, in limited circumstances, we may rely on an exception, or "derogation", which permits us to transfer your personal information to such country despite the absence of an "adequacy decision" or "appropriate safeguards" — for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at [email protected].