NextPass Privacy Policy

Last Updated: December 7, 2023

Cintra Digital Business Ventures LLC (“CDBV”, “we”, “us”, or “our”) respects your privacy. We are excited to engage with you through your use of the NextPass website and mobile application offered on iOS and Android mobile device platforms, including all related documentation (collectively, the “App”). This policy (this “Privacy Policy”) is meant to help you understand our practices regarding the collection, use, and disclosure of Personal Information (as defined below) in connection with the App as well as inform you of your rights and choices about the use of your Personal Information. We will not use, disclose, or share your Personal Information except as described in this Privacy Policy.

This Privacy Policy applies to all users of the App. Please remember that you are agreeing to the practices and procedures described in this Privacy Policy and the Terms of Use when you use the App. If you provide Personal Information, you also agree that that information may be transferred from your current location to the offices and servers of CDBV and its authorized third parties, which may be in a country that is different than yours.

If you do not agree with this Privacy Policy, please do not download, install, or use the App and delete it from your device if you have already downloaded it.

TABLE OF CONTENTS

1. Types of Information We Collect
2. How We Collect Your Information
3. How We Use Your Information
4. How We May Share Your Information
5. Short Message Service Communication Services
6. All Users: Your Rights, Choices and Controls
7. California Residents: Your California Privacy Rights
8. Security Practices
9. Links to Other Services
10. U.S. Operations, Non-Discrimination, and Making a Complaint
11. Changes to this Privacy Policy
12. Children’s Data
13. Exclusions
14. Contact Us

1. Types of Information We Collect

When you interact with us through the App, we collect the information you provide, usage information, and information about your device. We also collect information about you from other sources like service providers, and optional programs in which you participate, which we may combine with other information we have about you. Here are the types of information we collect about you:

(A) Personal Information

“Personal Information” is information that identifies, relates to, describes, or can be reasonably linked to, directly or indirectly, a particular individual or household. Personal Information does not include we collect from publicly available sources. We may collect Personal Information from you on or through the App in a variety of ways, including when you register or use the App. We also may, from time to time, receive Personal Information about you from third-party sources to improve the App, and for the various purposes outlined in this Privacy Policy.

We have grouped together the following categories of Personal Information to explain how we use this type of information. These terms are used throughout this Privacy Policy:

(i) Personal Identifiers, including your first and last name, and username.

(ii) Contact Information, including your email address, phone number, and mailing address.

(iii) Vehicle Information, including your license plate number, vehicle make and model, and toll road transaction information (e.g., travel date, tolling agency, entry plaza, entry lane, exit plaza, exit lane, entry date, entry time, exit date, exit time, plaza facility, and toll incurred).

(iv) Financial Information, including your purchasing/toll history, credit card information or other payment account information.

(B) Device Identifiable Information

We may collect information that may not reasonably identify you or a household personally, but is linked to your mobile device (“Device Identifiable Information”). We collect Device Identifiable Information from you in the normal course of providing the App, such as the type and model, operating system (e.g., iOS or Android), carrier name, and identifiers assigned to your device, such as its iOS Identifier for Advertising (“IDFA”), Android Advertising ID (“AAID”), or unique device identifier (a number uniquely given to your device by your device manufacturer), sometimes referred to as a mobile carrier ID. We may use Device Identifiable Information to analyze trends, help administer the App, to learn about and determine how users use the App, and to gather broad demographic information for aggregate use.

We may also collect your location information, such as your zip code or the approximate geographic area provided by your location positioning information provided by the location services and GPS features of your mobile device when location services have been enabled.

(C) Aggregated and De-identified Information

We may also receive or create information that cannot reasonably be linked to an identified or identifiable natural person, or a device linked to such person (“De-identified Information”). Sometimes, we collect or create information that relates to a group or category of natural persons, from which individual natural persons’ identities have been removed, and that are not linked or reasonably linkable to any person or household, including via a device (“Aggregate Information). Neither De-identified Information nor Aggregate Information are considered Personal Information subject to this Privacy Policy. For example, information about your usage of the App that is not connected to you or your household is not considered Personal information subject to this Privacy Policy. We publicly commit to maintain, use and otherwise process De-identified Information only in a de-identified fashion and will not attempt to re-identify such information.

2. How We Collect Your Information

(A) Direct Interactions with You

You give us your information in your direct interactions with us. We collect information you provide to us when you create an account or register vehicles on our App; request any other products, services, or information from us; respond to surveys; or otherwise interact with us. This information includes Personal Identifiers, Contact Information, Biographical Information, Vehicle Information, Financial Information, and Device Identifiable Information, which you give us from time to time.

We may match Device Identifiable Information with Personal Information that we may have from or about you, which would allow us to identify you. We may use this information to provide you with offers that are available where you are physically located.

(B) Other Third Party Sources

We may also receive other information from Service Providers (as defined below) in connection with the operation of our App. We may also receive information from Service Providers through marketing and demographic studies that we use to supplement Personal Information provided directly by you.

(C) Cookies and Web Beacons

To help us serve you better, we may collect Device Identifiable Information from you through technologies such as “cookies” and “web beacons” (which are also called clear GIFs, pixel tags, or pixels) or by tracking internet protocol (“IP”) addresses.

“Cookies” are small data files that are stored by your web browser when you interact with a website. When you visit a webpage, the cookie sends back Device Identifiable Information.
“Web Beacons” are small graphic images (usually invisible) that can be embedded in content and ads on a webpage that track usage of the App, our websites and effectiveness of communication. These web beacons can then be used to recognize our cookies and to monitor certain user interactions with a website.

Cookies operate in the background and you can turn them off by adjusting your device and/or web browser settings, but doing so may make it difficult to use some of the features on the App or the features may not be available to you. We may use Cookies to make your experience with the App and our webpages easier by, for example, remembering your preferences or keeping track of your login name and password.

We may also use Cookies, Web Beacons and other activity tracking tools on the App or our websites and through other services to collect your engagement metrics, including your Personal Identifiers and Device Identifiable Information, related to your activity on the App or our websites.

For more information on your choices regarding cookies, you can review the FTC’s guide to opting out of online tracking for computers and mobile devices. You can also see the “All Users: Your Choices and Controls” section below for ways to opt-out.

Your device and/or browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. The App and our website do not currently support Do Not Track requests.

3. How We Use Your Information

For the Purpose Collected: If you provide Personal Information for a certain reason, we will use the Personal Information in connection with the reason for which it was provided. For example, if you create an account for the App, the Personal Information you provide may be used to maintain your account and provide you access to certain features of our App.

Support from Service Providers: In addition, Personal Information and Device Identifiable Information we collect may be used by us and by third-party service providers, such as hosting providers, data management companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies, and payment processors (collectively, “Service Providers”) for a variety of purposes, including to:

provide or contact you about the App and/or services you have requested;
confirm or fulfill an order you have made;
administer your participation in a promotion, survey, or voting poll;
facilitate the operation, maintenance and improvement of the App, our business operations, and internal record keeping; and
with your permission, send you promotional material or special offers from CDBV. If you no longer wish to receive promotional in-app and e-mail messages from us, you may change your mind and/or your preferences by following the directions in the “All Users: Your Rights, Choices and Controls” section of the Privacy Policy below.

Our Service Providers are given the information they need to perform their designated functions in connection with the App, and we do not authorize them to use or disclose your Personal Information for their own marketing or other purposes.

If you decide to pay directly through a third party payment provider (e.g., PayPal), please note that this Privacy Policy does not apply to information provided to that Service Provider. We encourage you to read the privacy policy of each third party payment provider before deciding to use their services.

We use Google Analytics to track how you and others use the App in order to manage and improve our App or website. Google Analytics uses Cookies and collects information such as how often users visit our App or website, what pages they visit when they do so, and what other apps or sites they used prior to coming to our App or websites. Google Analytics collects only the IP address assigned to you on the date you use the App or visit our website, rather than your name or other identifying Personal Information. The information generated and collected by the cookies about your use of App or our website will be transmitted to and stored by Google on servers in the United States. We do not combine the information collected through the use of Google Analytics with Personal Information that we collect from you from other sources in an attempt to associate such information with you as an identifiable individual. Google’s ability to use and share information collected by Google Analytics about your use of the App is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to our App or our website by disabling cookies on your browser, or you can opt out by downloading a browser add-on here. For additional information please see “How Google uses data when you use our partners’ sites or apps,” located here.

We use the various Google AdWords features to advertise on third party websites, including Google, to previous visitors to our App. With remarketing, third-party vendors use cookies (including third-party cookies such as those from DoubleClick) to provide our advertisements on the Internet based upon your past visits to our App or websites, and with demographics and interest reporting, we use aggregate data provided (such as age, gender, and interests) to understand and communicate better with visitors to our App or website. You may opt-out of Google’s use of AdWords by adjusting your advertising settings or by downloading the browser add-on discussed above. To opt out of a third-party vendor’s use of cookies you may visit the Network Advertising Initiative opt-out page, or to opt out of DoubleClick’s use of cookies you may visit the DoubleClick opt-out page.

Identity Verification and Security: We may request that you provide certain Contact Information as part of our multi-factor authentication procedures to verify authorization to create or access your account or add a vehicle. We also may obtain information about you from other businesses to verify your identity so we can properly process your requests and prevent fraud. By accessing and using our App, you agree that we may use your submitted and obtained Personal Information and Device Identifiable Information for such purposes and to maintain the security of the App.

Product Improvement and Marketing: CDBV may also use your Personal Information and Device Identifiable Information, and other information collected through the App to:

help us improve the content and functionality of the App;
better understand our users and their preferences;
provide customer support; and
personalize experiences and offerings on our App.

CDBV may also use this information to communicate with you regarding the App and, to the extent permitted by law, to tell you about services or promotions we believe will be of interest to you.

Enforcement and Legal Obligations: CDBV may use your Personal Information to enforce our Terms of Use, or investigate and prevent activities that may violate our policies or be illegal, and to respond to legal proceedings and obligations.

(A) Business Transfers

As we develop our business, we might sell or buy businesses or assets, such as the sale of all or most of CDBV’s or an affiliates assets or equity to another company. In the event of a corporate sale, merger, reorganization, dissolution, or similar event in which a third party assumes control of all or part of our business, Personal Information may be part of the transferred assets or business.

(B) Sale of Personal Information

A “sale” of Personal Information under the Virginia Consumer Data Protection Act and similar data protection laws is defined as the exchange of Personal Information with a third party for monetary consideration. A “sale” of Personal Information under the California Consumer Privacy Act (“CCPA”) and similar data protection laws includes an exchange of Personal Information with a third party for monetary or any other valuable consideration. We do not and will not sell your Personal Information and do not have actual knowledge that we have sold the Personal Information of consumers we know are less than 16 years of age.

(C) Service Providers and Third Parties

We share Personal Information and Device Identifiable Information with Service Providers, as described above in “How We Use Your Information”.

We also share your Personal Information with departments of transportation and toll authorities, agencies or operators (collectively, “Transportation Authorities”); automotive manufacturers; sellers or distributors of gasoline; and other third parties to provide services or offer promotions in connection with the App. You expressly consent to the relevant Transportation Authorities collecting and otherwise processing your Vehicle Information in order to facilitate payment and reconciliation of toll charges resulting from usage of the App.

In addition to the information sharing described in Section (B) above, we may share with third parties aggregated demographic information collected on or through the App for various purposes. Aggregated demographic information does not include and is not linked to any Personal Information that can identify you or another individual or household but we may use IP addresses to verify users’ locations for various purposes.

(D) User Referrals

Users may send information about our App, products, or services, to their friends and family members by using an “E-mail to Friend” or similar feature in the App or in an e-mail that we have sent them. We do not further contact those individuals without the referred individual’s consent to do so.

(E) Legal Requirements

We may also share Personal Information and Device Identifiable Information under the following circumstances:

if required by law, such as by a court order, statute, regulation or rule, through legal process, or for law enforcement purposes;
in the event of a bankruptcy, insolvency, reorganization, receivership or assignment for the benefit of our creditors;
if we determine it necessary in connection with an investigation or in order to protect our legal rights; or
in response to requests from federal, state, local or foreign law and civil enforcement agencies, such as a search warrant, subpoena or court order

5. Short Message Service Communication Services

We may make available a service through which you can receive messages via short message service (“SMS Service”), but only with your express written consent. We may also retain evidence of your prior written consent for the SMS Service in the event you elect to receive such messages. You understand that your wireless carrier’s rates apply to these messages.

We may also collect the date, time, and content of your messages in the course of your use of the SMS Service. We will use the information we obtain in connection with our SMS Service for the purpose of sending the SMS messages. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information to facilitate the transaction in connection that invoice. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies. We may also contact your carrier, which may access the content of your wireless account, for the purpose of identifying and resolving technical problems and/or SMS Service-related complaints. You may change your mind and opt-out of SMS Services at any time by following the instructions in the “All Users: Your Rights, Choices and Controls” section below or following the instructions within the SMS Service.

6. All Users: Your Rights, Choices and Controls

(A) Your Rights

(i) Right to Opt-Out/Opt-in

You have the right to direct us not to process your Personal Information for the purpose of (a) target advertising, (b) the sale of Personal Information, or (c) profiling in furtherance of decision that produce legal or similarly significant effects concerning you. Please note that CDBV does not conduct any targeted advertising through the app, does not sell any Personal Information of users, including users under the age of 16, and does not use Personal Information collected through the App for profiling in furtherance of decision that produce legal or similarly significant effects concerning you. You may opt-out of receiving marketing emails by clicking “unsubscribe” at the bottom of such an email or, if you have an account with us, by changing your preferences in the “Account” section of the App. You may opt-out of participating in our SMS Service by texting “STOP” to our last message, or, if you have an account with us, by changing your preferences in the “Account” section of the App. If you have opted-in to the processing of your Personal Information for these reasons, you may opt-out at any time.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize the processing of your Personal Information for the above purposes. You may change your mind and opt back into the processing of your Personal Information at any time by changing your preferences or contact us at legal@nextpass.zendesk.com.

We will only use the Personal Information provided in an opt-out request to review and comply with the request. You do not need to create an account with us to exercise your opt-out rights.

If you are a resident of the Commonwealth of Virginia (and beginning on July 1, 2023, Colorado or Connecticut), applicable law requires us to receive your opt-in consent before processing any “sensitive data”, which includes (1) Personal Information revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, or citizenship or immigration status; (2) the processing of genetic or biometric data for the purpose of uniquely identifying a natural person; (3) Personal Information collected from a known child; or (4) precise geolocation data. We may process some of your sensitive data (e.g., precise geolocation data) in connection with the App and will ask for your opt-in consent before doing so. If you opt-in to this process and change your mind, you may opt-out by changing your preferences or contacting us at legal@nextpass.zendesk.com.

(ii) Right to Know

You have the right to know and confirm that we are processing your Personal Information. You also have a right to access to see what data and Personal information we have collected about you. To the extent feasible, you may request for us to also provide a copy of your Personal Information that you previously provided in readily usable format to permit you to transfer your data to another entity.

(iii) Right to Modify

You have the right to correct any inaccuracies in the data and Personal Information you provide to us.

(iv) Right to Delete

You have the right to request that we delete the Personal Information we have collected from you (and direct our Service Providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

Comply with a federal, state or local laws, rules, regulations or other legal obligations;
Investigate, establish, exercise, prepare for, or defend any legal claims
Provide you a good or service;
Perform a contract between us and you;
Protecting an interest that is essential for your or another natural person’s life or physical safety;
Prevent, detect, protect against, or response to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any illegal activity; or prosecute those responsible for any such action;
Preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action;
Protect the free speech rights of you or other users;
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws; or
Conduct internal research to develop, improve or repair our products, services or technology.

(B) Exercising Your Rights

To exercise your rights under this Privacy Policy, please submit a verifiable consumer request to us as indicated in the “Contact Us” section of this Privacy Policy. 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 request to know or delete on behalf of your child by providing proof of identity. You may only make a verifiable consumer request to exercise your right to know twice within a 12-month period at no additional cost to you. 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.

We will not discriminate against you for exercising any of your rights described above. Unless permitted by the law, we will not deny you goods or services; charge you different prices or rates for goods or services; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

(C) Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within such timeframe, please contact us as indicated in the “Contact Us” section of this Privacy Policy.

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 forty-five (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, or to the email address associated with the 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 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. Subsection (D) below describes how you can appeal our refusal to take action on a request to exercise your rights.

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.

(D) Right to Appeal

If we refuse to take action on your request to exercise your rights, you may appeal our refusal. To appeal a refusal, please submit a copy of your request for an appeal and the original request to us as indicated in the “Contact Us” section of this Privacy Policy. Unless otherwise indicated in this Privacy Policy, within sixty (60) days of our receipt of your request for an appeal, we will inform you, in writing, of any action taken or not taken in response to your appeal. We will include a written explanation of the reasons for the decisions. If we deny your appeal, you may contact your local privacy enforcement authority to submit a complaint based on the below information.

(i) Virginia

If you are a resident of the Commonwealth of Virginia, you can file a complaint with the Consumer Protection Section of the Office of the Attorney General of Virginia at:

Mailing address:
202 North Ninth Street
Richmond, VA 23219

Toll Free: 800-552-9963
Phone number: 804-786-2042
Fax number: 804-225-4378

Online:https://www.oag.state.va.us/consumercomplaintform/form/start

(ii) Colorado

Effective July 1, 2023, if you are a resident of Colorado, we will inform you, in writing, of any action taken or not taken in response to your appeal within forty-five (45) days of receipt of your appeal. If we require more time (up to another sixty (60) days), we will inform you of the reason and extension period in writing. If we deny your appeal, you can file a complaint with the Office of the Attorney General of Colorado at:

Mailing address:
Ralph L. Carr Judicial Building
1300 Broadway, 10th Floor
Denver, CO 80203
Phone number: 720-508-6000

Online:https://coag.gov/file-complaint/

(iii) Connecticut

Effective July 1, 2023, if you are a resident of Connecticut, you can file a complaint with the Office of the Attorney General of Connecticut at:

Mailing address:
165 Capitol Avenue
Hartford, CT 06106
Phone number: 860-808-5420

Online:https://www.dir.ct.gov/ag/complaint/

7. CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS

Residents of California also have certain rights under the CCPA regarding Personal Information. These rights include

(A) Right to Limit Use of Sensitive Personal Information

Under the CCPA, some Personal Information you may provide to us is considered “sensitive” Personal Information, such as your financial information and geolocation. You may, at any time, direct us (and our service providers) to limit our use and disclosure of your “sensitive” Personal Information to only those uses which are necessary to perform our services or provide you with goods in connection with the App, or for any other lawful purpose. Once you exercise this right, we will not use or disclose your sensitive Personal Information for any other purposes without your express consent unless permitted by the CCPA or applicable law. However, we may continue to use or disclose your Personal Information that is not considered “sensitive” as set forth in this Privacy Policy.

(B) Right to Know

You have the right to know and see what data we have collected about you over the past twelve months, including:

The categories of Personal Information we have collected about you,
The categories of sources from which the Personal Information is collected,
The business or commercial purpose for collecting your Personal Information,
The categories of third parties with whom we have shared your Personal Information, and
The specific pieces of Personal Information we have collected about you

(C) Right to Delete

You have the right to request that we delete the Personal Information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

Complete your transaction,
Provide you a good or service,
Perform a contract between us and you,
Protect your security and prosecute those responsible for breaching it,
Fix our system in the case of a bug,
Protect the free speech rights of you or other users,
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.),
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws,
Comply with a legal obligation, or
Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

(D) Right to Modify

You have the right to correct any inaccuracies in the data and Personal Information you provide to us.

(E) Exercising Your Rights

You may exercise your right to limit our use, right to know or your right to delete Personal Information collected in connection with the App at any time by logging in to your account profile and reviewing or indicating that you would like to limit, access or delete all provided Personal Information. However, please note that we may retain certain Personal Information as permitted by law and will maintain a record of the request as required by § 999.317(b) of the CCPA regulations.

Using your credentials to log in to your account profile will serve as our means of verifying your identity and your request. Please safeguard your username and password.

If you have questions or require assistance in exercising your rights under the CCPA, please contact us at +1 888 814 7766, or by mailing us at:

Cintra Digital Business Ventures LLC
9600 Great Hills Trail
Austin, TX 78759
Attention: Legal Department

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. To have an authorized agent make a request under the CCPA on your behalf, please ask the authorized agent to contact us using the contact information above.

Please note that we may require the agent to provide us with proof that you have given them signed permission to submit the request. We may also require that you either verify your identity directly or directly confirm that you provided permission to your authorized agent. We cannot respond to your request or provide your agent with Personal Information if we cannot verify your identity or authority to make the request.

The requirements above do not apply if you have provided the authorized agent with power of attorney under the California Probate Code sections 4121 to 4130.

You have a right not to receive discriminatory treatment from a business for the exercise of your privacy rights under the CCPA. We will not discriminate against you for exercising any of your CCPA rights described above.

8. Security Practices

We use reasonable security efforts to protect the Personal Information in our possession. However, no method of transmission or storage of data is 100% secure and we will not be responsible for any damage that results from a security breach of data or the unauthorized access to or use of information, whether Personal Information or Device Identifiable Information. To the extent we provide your Personal Information to any third parties, we will request that they use reasonable security measures to protect your information.

9. Links to Other Services

The App may contain links to other websites and online services. When you click third-party links to such other sites and services (including by means of clicking on hyperlinks, logos, widgets, banners or advertisements), you become subject to their terms of use and privacy policies posted thereon and/or applicable thereto. Because we cannot control the activities of third parties, please note that we are not responsible for the privacy practices of third-party websites. We encourage you to be aware of this when you click on a link and leave the App, and to read the privacy policies of every website that collects Personal Information from you.

10. U.S. Operations, Non-Discrimination, and Making a Complaint

We make no assurances or representations of any kind that the App are suitable for use outside the United States or in the country in which you reside. The information we collect is kept on servers in the United States and may be transferred to servers in other countries, subject to the terms of this Privacy Policy. We retain the Personal Information that we collect for so long as we continue to have a business purpose for it.

By accessing and using the App, establishing an account, or registering vehicles, you consent to the processing of your Personal Information as provided in this Privacy Policy. You may withdraw that consent by contacting us at legal@nextpass.zendesk.com or through the “Account” section of the App. Please know that when you withdraw your consent, we may still use your information to the extent necessary to complete a transaction with you or as otherwise permitted by law. You are required to provide certain Personal Information in order to use the App, to pay tolls or to take advantage of certain features available through the App. Your choice not to provide this information may prevent you from using the App or may result in a need to terminate your account or an inability for you to use certain App features. It is not our intent to discriminate against you for exercising your rights or the choices available to you. But, without certain information, the App and our services may not work as designed.

If you wish to object to or raise a complaint on how we have handled your Personal Information, you may contact us at legal@nextpass.zendesk.com.

If you are not satisfied with our response or believe our processing of your Personal Information is not in accordance with law, you may register a complaint with the appropriate privacy enforcement authority. We control the Personal Information collected via the App.

11. Changes to this Privacy Policy

This Privacy Policy replaces any earlier version. You should review this Privacy Policy periodically as we may modify it from time to time. If we change our Privacy Policy in the future, we will post the changed Privacy Policy on the App and other locations where this policy was previously posted. You will be able to determine what version of the Privacy Policy applies by the “Effective Date” placed under the title. Where consistent with applicable law, your continued use of the App after we have changed the Privacy Policy signifies your acceptance of the revised terms. Under certain circumstances (e.g., with respect to certain material changes to this Privacy Policy, including the way we share Personal Information previously collected from you through the App), we may also elect to notify you through additional means, such as posting a notice on the App or by means of an e-mail.

12. Children’s Data

The App is not directed to or intended for children under eighteen (18) years of age. We will not collect Personal Information from children under eighteen (18) years of age. If we learn we have collected or received Personal Information from a child under eighteen (18), we will endeavor to delete that information.

13. Exclusions

This Privacy Policy does not apply to any Personal Information collected by CDBV other than Personal Information collected through the App. This Privacy Policy also does not apply to information about businesses or other non-individual users. CDBV reserves the right to use and disclose Aggregate Information or De-identified Information for any commercially reasonable purpose.

14. Contact Us

Please feel free to contact us if you have questions or concerns about this Privacy Policy or if you would like to exercise your applicable data protection rights via email at legal@nextpass.zendesk.com, or by mailing us at:

Cintra Digital Business Ventures LLC
9600 Great Hills Trail
Austin, TX 78759
Attention: Legal Department

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