Vehya

Privacy Policy

Last Updated: 09.25.2023

Welcome to Vehya Inc.! This Privacy Notice describes how we collect, use, disclose, and protect the personal information (defined below) of Site Users (defined below) and other Site users (defined below) (“You,“ “Your”).

The types of information we may collect from You or that You may provide when You contact us or visit the Vehya Inc. Sites are defined below, as well as our practices for collecting, using, maintaining, protecting and disclosing that information.

If You do not agree with our policies and practices, Your choice is not to use our Vehya Inc. Sites, or any Vehya Inc. Services. By accessing or using the Vehya Inc. Sites or using the START AN ASSESSMENT Services, You indicate that You understand, accept, and consent to the practices described in this policy. We will from time to time update this Privacy Notice as necessary to ensure that it remains accurate and up to date. Your continued use of the Vehya Inc. Sites or Vehya Inc. Services after we make changes indicates that You accept and consent to those changes, so please check the Privacy Notice periodically for updates.

What Does Vehya Inc. Do?

Vehya Inc. is an innovative company that facilitates turnkey, home EV charging installations across North America and globally by connecting Site Users (or potential Site Users) of elective vehicles (“Site Users”) with qualified third-party EV charging station Service Providers (“Service Providers”) (the “Services”). We typically provide the Services on behalf of licensed electricians, EV manufacturers, auto dealers, fleet managers, and property owners, other businesses with EV interest (our “Customers”).

We connect with Site Users in the following ways:

Our customers connect us with Site Users so that we may reach out directly to Site Users to connect them with Service Providers;
Site Users contact us directly using phone, email, or through one of our Vehya Inc. Sites (defined below) to find qualified Service Providers;
When providing our Services for our Customers we process personal information about individuals on their behalf and at their direction, as outlined in this Privacy Notice. This Privacy Notice does not explain how our Customers, Service Providers, or other third parties may process Your personal information.

What this Privacy Notice Covers:

Personal Information Collected From Vehya Inc. Sites: This Privacy Notice applies to all users of Vehya Inc. websites www.vehya.com and apps (each a “Vehya Inc. Site” and collectively “Vehya Inc. Sites”);
Personal Information About Site Users: We collect personal information about Site Usersto provide our Service;
Personal Information About Our Service Providers: We may collect personal information about representatives from businesses interesting in becoming authorized Vehya Inc. Service Providers;
Personal Information About Our Customers: We may collect personal information about representatives from Customers as part of our normal business-to-business due diligence and communications;
This Privacy Notice does not apply to the processing of personal information in the context of working as an employee, agent, job applicant, contractor, or other member of Vehya Inc.’s workforce

What is Personal Information?

“Personal Information” is information about You which (i) can be used to identify, contact, or locate You; (ii) can be combined with other information that is linked You; or (iii) is defined as “personal data” or “personal information” by applicable laws or regulations relating to the collection, use, storage or disclosure of information about You. Personal information includes contact information (e.g. email address, mailing address, or telephone number), online information (e.g. IP addresses or other identifiers), and other data which can be used individually or in combination with other data to identify an individual (such as gender, age, or general location).

What Personal Information We Collect About You

Identifiers like Your name, address, telephone number, email address, unique personal identifier, IP address;
Internet activity on Vehya Inc. Sites;
General location data like Your street address, city, and zip code;
Other personal information that You voluntarily provide to us via forms, communications (phone calls, emails, messages, etc.).

How We Collect Your Personal Information

Personal Information You Provide Directly To Us;
Vehya Inc. collects personal information from You when You;
Provide it to us through one of our Vehya Inc. Sites;
Provide it to us using a technology integration on a third-party sites. When we do this, You will see the VEHYA or similar notice with a link to this Privacy Notice;
Contact us via email or phone to communicate with us;
Provide Your contact information on a form and submit it to us;
Connect with our social media pages;
Sign up for marketing, an event, a contest, or other offering we may present;
Volunteer personal information to us;
Personal Information We Collect Automatically

When You access a Vehya Inc. Site, we automatically collect personal information associated with Your access and use of the site. This information may include Your internet protocol (IP) address(es), the region or general location where Your computer or device is accessing the internet, the browser type, operating system and other usage information about the use of the Vehya Inc. Site(s), such as Your page-views, referral URLs, etc. Vehya Inc. collects and uses this type of information to help us understand how users interact with the Vehya Inc. Sites, to provide You with a more relevant experience, and to enhance our business offerings. We have a legitimate interest in learning how to improve our Vehya Inc. Sites, our Services, customer engagement, marketing, and advertising.

Vehya Inc. and its authorized partners may use cookies and other information gathering technologies on Vehya Inc. Sites for a variety of purposes. These technologies may provide us with personal information, information about devices and networks You utilize to access our Vehya Inc. Sites, and other information regarding Your interactions with our Vehya Inc. Sites. Please review our “Cookies” section below to learn more about how we use cookies.

Personal Information We Collect From Others

Site Users from our Customers when they provide it to us;
Site Users from our Service Providers when they confirm an installation, service request, or other interaction with Site Users;
Visitors to Vehya Inc. Sites from our advertising, analytics, and internet service provider partners related to a visitor’s interactions with our Vehya Inc. Sites or advertisements;
Company and Service Provider representatives from their respective organizations;
Other third parties on occasion when provided for legitimate business operational purposes
We don’t buy or sell personal information

Cookies and Other Tracking Technologies We Utilize

We use cookies, which are pieces of information that a website transfers to an individual’s computer hard drive for record keeping purposes, and similar tracking technologies on our website and when providing Vehya Inc. Sites. Some cookies are set by us and called first-party cookies. We also use third-party cookies (which are cookies from a domain different than the domain of the website You are visiting) for our advertising and marketing efforts.

You have a choice about the placement of cookies on Vehya Inc. Sites. You can use your web browser to directly block all cookies, or just third-party cookies, through Your browser settings. Using Your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation. Guidance on how to control cookies in popular browsers are contained in their privacy and/or security settings.

You can also find additional information on cookie controls and advertisement here:

Network Advertising Initiative

Google allows users to opt out of tracking by Google Analytics and Google Analytics Demographics and Interest Reporting services. You can adjust Your settings,download the Google Analytics Opt-Out Browser Add-on.

How We Use Personal Information We Collect

In addition to the uses described elsewhere in this Privacy Notice and in other notices at or before the point of collection from You, we may use Your personal information to:

Improve your browsing experience by personalizing the Vehya Inc. Sites;
Subject to any consent requirements, send information or contentterms to you which we think may be of interest to You by post, email, or other means and send you marketing communications relating to our business;
Develop and improve our Services;
Facilitating our business partnerships, customer assistance, quality assurance, and other operational purposes;
Subject to any consent requirements, send promote use of our services to You and share promotional and information contentterms with You in accordance with your communication preferences;
Provide other companies with statistical information about our individuals. When we do so, this information will not be used to identify any individual and will only be shared on an aggregate and de-identified basis;
Contact You about technical, operational, and administrative matters;
Send information to You regarding changes to our Terms of service, Privacy Policy, or other legal agreements;
Investigate and help prevent security issues and abuse; or
Meet legal requirements.

How We Share Information With Others

In addition to the uses described elsewhere in this Privacy Notice and in other notices at or before the point of collection from You, we may use Your personal information to:

With Service Providers in order to facilitate the installation of EV charging stations;
With our Customers to provide our Service to them;
With our service providers pursuant to a contract by which they are required to protect Your personal information, including:
Data processing contractors that provide computer services on our behalf;
Web hosting or web development firms that host or develop parts of Vehya Inc. Sites;
Distribution firms that will fulfill Your requests;
Billing firms that process Your orders;
Mailing firms that will assist us with our mailings;
Marketing firms that will assist us with direct marketing;
Data analytics firms that help us conduct customer research and analyze users’ interactions with Vehya Inc. Sites;
Service contractors that provide facilities engineering services on our behalf.

To facilitate a direct relationship with You, including in connection with any program we administer jointly or on behalf of the business partner;
With our Customers to provide our Service to them;
To enable electronic communications with You as part of a purchase, a program, or other activity in which You have elected to participate;
With a purchaser of Vehya Inc. or any of the Vehya Inc. affiliates (or their assets);
To comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions;
To combat fraud or criminal activity, and to protect our rights or those of our affiliates, users, and business partners, or as part of legal proceedings affecting Vehya Inc. or our business partners;
In response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate.

Sharing Information With Our Service Providers

We use a variety of service provider to provide our Services. For example, we use the following: Google Analytics to provide analytics services. For more information about how Google uses this data, You can visit: How Google uses data when You use our partners’ sites or apps. Additionally, You can use the Google Analytics opt-out browser add-on to opt-out of having Your activity on Vehya Inc. Owned Sites available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (gtag.js, analytics.js) that is running on websites from sharing information with Google Analytics about visit activity.

Some of our Vehya Inc. Owned Sites are hosted by Godaddy and Amazon Website Services. We share data including (i) information about Your browser, network and device; (ii) web pages You visited prior to coming to the Squarespace-hosted website; and (iii) Your IP address. Squarespace needs the data to run these sites, and to protect and improve its platform and services. Squarespace analyzes the data in a de-personalized form.

Some of our Vehya Inc. Owned Sites are hosted on HubSpot. Hubspot collects and processes Personal Information at our direction and is subject to our instructions on how to process Personal Information on our behalf.

Sharing Information With Our Remarketing Providers

Vehya Inc. uses Google’s remarketing services to advertise on third party websites to previous visitors to Vehya Inc. Owned Sites. Third-party vendors like Google use cookies to serve ads based on someone’s past visits to the Vehya Inc. Owned Sites. Any data collected will be used in accordance with our own privacy policy, as well as Google’s privacy policy. You can opt out of Google’s use of cookies or device identifiers by visiting Google’s Ads Settings. Alternatively, You can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using Your device’s settings. Canadian users can opt-out of interest-based advertising from certain companies using the tools located at: https://youradchoices.ca/en/tools

Data Security

The security of Your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure Your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect Your personal information, we cannot guarantee the security of Your personal information transmitted to the Vehya Inc. Sites. Any transmission of personal information is at Your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Vehya Inc. Sites.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Third Party Links

Vehya Inc. Sites may, from time to time, contain links to and from third party websites, such as partners, affiliates, and advertisers. If You follow a link to any external website, it will have its own privacy policy and we are not responsible for the content or practices of such third-party websites or their policies. We are also not responsible for any information that You might share with such linked websites. You should refer to each website’s respective privacy policy and practices before You submit any personal information.

International Users

Your personal information will be collected and stored in the United States, and subject to the laws of the United States. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of the United States may be able to obtain access to Your personal information through the laws of that country. If You reside in a country outside the United States, please note that the data protection and privacy laws of the United States may not be as protective as the laws in Your country.

Data Collected From Children

The Vehya Inc. Sites are not intended for children under Thirteen (13) years of age. No one under age 13 may provide any information to the Vehya Inc. Sites. We do not knowingly collect personal information from children under Thirteen (13). If You are under Thirteen (13), do not use or provide any information on the Vehya Inc. Sites. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If You believe we might have any information from or about a child under Thirteen (13), please contact us at eot@vehya.com.

Do Not Track Disclosure

Regulatory agencies such as the U.S. Federal Trade Commission have promoted the concept of Do Not Track as a mechanism to permit Internet users to control online tracking activity across websites through their browser settings. Since no industry standard has been adopted, we currently do not process or comply with any web browser’s “do-not-track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit Vehya Inc. Sites.

Changes to Our Privacy Notice

We may update this Privacy Notice to reflect changes to our data practices. If we make any material changes we will notify You by email (if applicable) or by means of a notice on our website or in the Vehya Inc. Sites prior to becoming effective. We encourage You to periodically review this page for the latest data on our privacy practices.

Contact Information for Complaints or Concerns

If You have any questions or comments about Vehya Inc.’s Privacy Notice please email Your questions or comments to eot@vehya.com.

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact us using the contact information listed above.

Vehya Inc. Privacy Policy for California Residents

Effective Date: 08.28.2023

Last Updated on: 09.26.2023

This Privacy Policy for California Residents supplements the information contained in Vehya's Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication ("B2B personal information") from some of its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device("personal information"). Personal information does not include: · Publicly available information from government records.

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Website.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Website, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures
A: Identifiers.	YES
B: California Customer Records personal information categories.	YES
C: Protected classification characteristics under California or federal law.	NO
D: Commercial information.	YES
E: Biometric information.	NO
F: Internet or other similar network activity.	YES
G: Geolocation data.	YES
H: Sensory data.	NO
I: Professional or employment-related information.	YES
J: Non-public education information.	NO
K: Inferences drawn from other personal information.	YES

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (seeExercising Your Rights to Know or Delete), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

Identifying the personal information categories that each category of recipient purchased; and
Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

The specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for B2B personal information

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Calling us at 1-866-VEHYA-21.
Emailing us at EOT@VEHYA.COM.
Visiting WWW.VEHYA.COM.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by emailing eot@vehya.com.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
Government issued identification.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact eot@vehya.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to eot@vehya.com.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Vehya collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-866-Vehya-21

Website: www.vehya.com

Email: eot@vehya.com

Postal Address: Vehya Inc.
Attn: Privacy
1420 Washington Blvd #301, Detroit, MI 48226

If you need to access this Policy in an alternative format due to having a disability, please contact eot@vehya.com and 1-866-Vehya-21.

Vehya Inc. Privacy Policy for Canadian Residents

Effective Date: June 12, 2023

Last Updated: June 12, 2023

If You are a resident of Canada, under Canadian law have the right to request access to and to correct the personal information that Vehya Inc. holds about You.

If You want to review, verify, correct, or withdraw consent to the use of Your personal information You may send us an email at eot@vehya.com to request access to, correct, or delete any personal information that You have provided to us. Please note that if You withdraw your consent, we may not be able to provide You with a particular product or service. We will explain the impact to You at the time to help you with your decision. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge You a fee to access your personal information, however, we will notify You of any fee in advance.

We may request specific information from you to help us confirm Your identity and Your right to access, and to provide You with the personal information that we hold about You or make your requested changes. Applicable law may allow or require us to refuse to provide You with access to some or all of the personal information that we hold about You, or we may have destroyed, erased, or made Your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide You with access to Your personal information, we will inform You of the reasons why, subject to any legal or regulatory restrictions.

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

Where You have provided Your consent to the collection, use, and transfer of Your personal information, You may have the legal right to withdraw Your consent under certain circumstances. To withdraw Your consent, if applicable, contact us at eot@vehya.com.

Please note that if you withdraw Your consent, we may not be able to provide You with the Services or Vehya Inc. Sites. We will explain the impact to You at the time to help You with Your decision.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by theDigital Advertising Alliance of Canadaor an opt-out tool created by theNetwork Advertising InitiativeYou can also access these websites to learn more about online behavioral advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

If You are concerned about our response or would like to correct the information provided, You may contact our privacy officer at eot@vehya.com.

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices.

Please contact us at:

Privacy Officer
1420 Washington Blvd #301, Detroit, MI 48226

For Residents of the European Economic Area (“EEA”) – General Data

Protection Regulation (“GDPR”)

Effective Date: 08.28.2023

Last Updated: 09.25.2023

If you are a resident of the EEA, you are subject to the GDPR, which became effective on May 25, 2018, and the following terms also apply to you. The Company is the Controller and responsible for your personal data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to our obligations under the GDPR. If you have any questions about your privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:

Contact Details

Our full details are:

Full name of legal entity: Vehya Inc.

Name or title of DPO: COUNSEL X

Email address: LEGAL@VEHYA.COM

Postal address: 1420 WASHINGTON BLVD #301, DETROIT, MI 48226

Telephone number: 313-241-6323

Lawful Bases to Process Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting our DPO. Specifically, we have a lawful basis for processing each type of personal data described in this Privacy Notice, which are as follows:

The lawful basis for collecting your Identity and Contact Data to register you as a new customer is the performance of a contract with you.
The lawful bases for collecting your Identity, Contact, Financial, Transaction and Marketing and Communications Data to process and deliver your purchases are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests.
The lawful bases for collecting your Identity, Contact, Profile, and Marketing and Communications Data to manage a relationship with you are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
The lawful bases for collecting your Identity, Contact, Profile, Usage, and Marketing and Communications Data to enable you to partake in a contest, competition or complete a survey are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business).
The lawful basis to collect your Identity, Contact, and Technical Data to administer and protect our business and the Service is that it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise).
The lawful basis to collect your Identity, Contact, Profile, Usage, Marketing and Communications, and Technical Data to deliver relevant Service content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you is that it is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
The lawful basis to collect Technical and Usage Data to use data analytics to improve our Service, marketing, customer relationships and experiences is that it is necessary for our legitimate interests (to define types of customers for our products and services, to keep our Service updated and relevant, to develop our business and to inform our marketing strategy).
8. The lawful basis to collect Identity, Contact, Profile, Usage, and Technical Data to make suggestions and recommendations to you about goods or services that may be of interest to you is that it is necessary for legitimate interests (to develop our products/services and grow our business).

We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact our DPO if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out forth in this Privacy Notice.

We may have to share your personal data with the parties set out below for the purposes described in this Notice.

For Residents of the European Economic Area (“EEA”) – General Data

Service providers acting as processors based in the United States who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United States and who provide consultancy, banking, legal, insurance and accounting services.
Specific third parties such as Google, Amazon, Intercom, Stripe, PayPal, Facebook, and Bluehost.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Processing

We are based in the United States, which is where all of your data will be processed.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

Your Legal Rights under the GDPR

Under certain circumstances, EEA residents have rights under data protection laws in relation to their personal data. If you are an EEA resident, you have the right to:

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any timewhere we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our DPO. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.