Wejo Privacy Notice for California Residents

Effective Date: 16th November 2020

Last Reviewed on: 19th April 2022

This Privacy Notice is issued by Wejo Limited and its subsidiaries, and trade names including Wejo California Corp., Wejo, Inc., Wejo Data Services, Inc., and Wejo Services, Inc. (collectively referred to as "Wejo", "we", "us" and "our" in this Privacy Notice).

This Privacy Notice for California Residents supplements the information contained in Wejo's general privacy notice available at https://www.wejo.com/privacy/terms-privacy-cookies and applies only to personal information (defined below) concerning our website visitors, users, and others who reside in the State of California ("consumers" or "you") in connection with their visit to our website or our commercial operations. We provide this notice in accordance with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used in this Notice.

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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, or household ("personal information"). Personal information does not include:

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) or clinical trial 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.

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In particular, we may collect the following categories of personal information from or about consumers:

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A. Identifiers.
A real name, alias, unique personal identifier, online identifier, IP address, email address, account name, driver's license number, or other similar identifiers.

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B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code ß 1798.80(e)).
A name, signature, telephone number,, driver's license or state identification card number, insurance policy number.Some personal information included in this category may overlap with other categories.

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C. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
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D. Geolocation data.
Physical location or movements*.
* We receive this category of data only when acting as a service provider pursuant to our contracts with our business partners. Under the CCPA, a service provider is a business that processes information on behalf of another business and that is contractually prohibited from retaining, using, or disclosing the personal information for any purpose outside of its contract with the other business. We act consistent with our service provider contractual obligations, and use the data only as set forth in those contracts.

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

Directly from you. Directly from you. For example, from forms you complete or services you request or through your direct commercial or business interactions with us.
Indirectly from you. For example, from observing your interactions with our website.
From other sources. For example, in certain instances, where we act as service providers (as noted above) in connection with our data product and service offerings.

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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 ask a question about our products or services, we will use that personal information to respond to your inquiry. We may also save and use your information to market or promote our service offerings.
To provide, support, and develop our data product and service offerings.
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.
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, which includes developing and improving our data service and product offerings.
To comply with 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.

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.

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Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

with Software/IT service providers we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

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Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Wejo has disclosed the following categories of personal information for a business purpose:

Category F: Internet or other similar network activity.

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‍Sales of Personal Information

In the preceding twelve (12) months, Wejo has not sold personal information nor has it sold personal information of minors under the age of 16.

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Your Rights and Choices

The CCPA provides you with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

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Access to Specific Information and Data Portability Rights

You have the right to (i) request access to your personal information; (ii) request that we disclose certain information to you about our collection and use of your personal information over the past 12 months; and (iii) request deletion of your personal information. Once we receive and confirm your verifiable consumer request, 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 or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, 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.

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Deletion Request Rights

You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. 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.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code ß 1546 et. seq.).

6. 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.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

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Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at Freephone 0800 046 5370
United States toll-free +1 888 746 2450
Emailing us at privacy@wejo.com
Visiting wejo.com

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us through the methods noted above. Only the consumer or authorized agent may make a verifiable consumer request related to their personal information. An ìauthorized agentî is a person (or a business entity registered with the California Secretary of State) that consumers have authorized to act on their behalf or an individual granted authority under a written power of attorney issued pursuant to California Probate Code sections 4000 to 4465.

If you are an authorized agent who wishes to submit a request to know, a request to delete, or a request to opt-out on behalf of another consumer, please submit to us sufficient information to allow us to verify your identity to a reasonably high degree of certainty and either:

proof of authorization to submit the request, written and signed by the consumer; or
a power of attorney pursuant to Probate Code sections 4000 to 4465.

We may deny a request from an authorized agent who does not submit adequate proof that they have been authorized by the consumer to act on the consumer's behalf. We may also contact the consumer directly to confirm their identity and that they provided you permission to submit the request on the consumer's behalf.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
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.

Making a verifiable consumer request does not require you to create an account with us. However, where applicable, 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 a verifiable consumer request to verify the requestor's identity or authority to make the request.

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Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 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 the verifiable consumer request's receipt. 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.

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Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

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.

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Changes to Our Privacy Notice

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

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Contact Information

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