GroundSpan - Privacy Policy

Effective: June 2019

1. Introduction

Ground Management Holdings, LLC, dba GroundSpan (referred herein as "Groundspan" or "We"), is a technology company headquartered in Paramus, NJ that provides tools and technology for managing ground transportation. GroundSpan works with travel management agencies and companies for business travel needs and provides technology-based solution and services (hereinafter collectively, the "Services").

We respect your privacy and are committed to complying with this Privacy Policy ("Policy"), which sets forth the principles and practices that apply to our collection and use of information that you, our clients and prospective clients (hereinafter referred to as "you" and "your") provide to us, whether in person, by telephone, mail or e-mail, or through our website https://groundspan.com/, including all web products hosted under groundspan.com and applications that display or link to this Policy. But once you leave such Site and applications for others, the privacy policies of the other websites or applications shall apply.

2. Accepting the Privacy Policy

We need to collect, use and disclose personal information in order to perform our Services, business functions and activities, including ground transportation booking tools and processing and forwarding bookings on behalf of our customers. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.

By using the Services, you acknowledge that GroundSpan will use your information in the United States, and any other country where GroundSpan operates or GroundSpan services are used. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside.

3. What information is collected or received?

Depending on how you interact with us either directly or through your authorized agent/booker, we process different kinds of data and in different ways. Some data are automatically processed if you submitted to us through your use of our Products or through Partners (i.e. Channels). Data are only processed if you or your authorized agent/booker submit it to us (e.g., using our desktop tool to create/update a reservation or use our mobile application ("App") or website). We need to process your personal information in order to provide the service and run our business.

In the course of providing our Services, we collect or receive your personal information in a few different ways.

Registration, Profile Setup: In order to set up login profile, you need to provide a valid email address, full name, phone number and password. In order to book a ride, you need to provide a pick-up address, and credit card information. We may need to store encrypted credit card information and passing it to a ground transportation service provider ("Service Provider") for billing and payment purposes.

Website usage data/Automated Information: GroundSpan automatically receives and collects information presented through your browser or your mobile device when you visit the Site or use the App (e.g., your IP address, or cookies). This information is stored in log files. We may combine this information from your browser or your mobile device with other information that we collect about you. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for users and provide more personalized experience for users.

We may also automatically collect device-specific information when you install, access, or use our Services. This information may include the hardware model, operating system information, app version, app usage and debugging information, browser information, and device identifiers, including the following:

  • Date and time of the visit and the duration of use of the Site;
  • The IP address of your device as well as your internet service provider (ISP);
  • The referral/exit URL;
  • The visited subsites of the Site;
  • Clickstream data; and
  • Information about your device (type of device, browser type and version, as well as settings, installed plug-ins, operating system).

Cookies: We use the following types of cookies (and you may adjust the cookie settings in your browser at any time):

Permanent Cookies - These cookies are required to enable our core site functionality.

  • Remember login details
  • Provide secure login
  • Remember your task or transaction progress
  • Remember progress on ordering process

Session/Functional Cookies - These cookies enable additional functionality such as remembering your preferences, allowing social interactions, and analyzing usage for site optimization.

  • Analyze site usage to provide custom content
  • Remember your login details for duration of web session
  • Conduct analytics to optimize site functionality
  • Remember information submitted on multi-step booking process
  • Enhance site usage and booking experience

Location Information: When you use the Site or App, you may consent to share your geo-location details with GroundSpan in order to automatically use your pick-up location during booking process. We may use and store information about your location to provide features to improve and customize the Services. We will only share your geo-location details with third parties in order to provide you with the Services.

Analytics Information: We use data analytics to ensure site functionality and improve the Services. We use a mobile analytics software to allow us to understand the functionality of the App on your phone. This software may record information such as how often you use the App, what happens within the App, aggregated usage, performance data, app errors and debugging information, and where the App was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.

SSO Information from Companies or Third Parties: Some visitors may choose, at their discretion, to connect to GroundSpan using a Single Sign-On managed by their company or external third-party. GroundSpan may receive information from that connected third-party application.

Transaction Data: In relation to your transportation request you may make online or through partners, we will process your contact and billing information, such as your name, address, and credit card information. You can view the exact information required in the form provided at point of purchase. We will only use this data to provide the Services, for billing purposes, and for internal accounting.

Email/Direct Mail Campaign Data: From time to time, we may contact our customers directly by mail, email, or telephone to inform you about upgrades, new products, promotions, or special offers that you told us you were interested in receiving (including our newsletters). However, we will not contact you with any commercial communications that are unrelated to the Products that you have purchased from us unless you have given us your prior consent to receiving such information. When responding to one of these campaigns, you may have the option to provide us with personal information, which we will use for the purpose indicated.

Service Providers: A Service Provider may collaborate with another affiliated transportation company to provide you with transportation services outside their local market. Our use of your Personal Data is limited to the specific transportation request in a different market that you have requested or elected to use and we will only share specific Personal Data that is required for completion of transportation request. Most service providers do not share email address or credit card information with any affiliate transportation provider.

Non-Member Information: GroundSpan may receive or obtain information (e.g., an email address) about a person who is not a registered GroundSpan member (referred herein as, a "Non-member") in connection with certain GroundSpan features (e.g., when a member adds a non-member guest to the ride s/he is booking). Non-member information is used only for the purposes disclosed when it was submitted to GroundSpan.

4. How do we use your personal information?

Providing and improving our Services: We may use customer, passenger or bookers’ information as it is necessary to improve our Services for our users and to understand how our Services are being used.

Service Providers: It is also necessary for GroundSpan to engage third-party companies in order to operate and provide the Services. These third parties have only limited access to your information, may use your information only to perform these tasks, and are obligated to GroundSpan not to disclose or use your information for purposes other than providing ground transportation services. Only Service Providers who are in direct contract with and selected by a corporate client are available to its employees and bookers (booking on behalf of the company).

Keeping our Services secure: We may also use customer information in order to ensure the security of our Services.

Legal and Safety: GroundSpan may also retain, preserve, or release your personal information to a third party in the following limited circumstances:

  • In response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
  • To protect, establish, or exercise our legal rights or defend against legal claims;
  • To comply with a subpoena, court order, legal process, or other legal requirement; or
  • When we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of GroundSpan's Terms & Conditions.

Business Reorganization: In some cases, GroundSpan may choose to buy or sell assets or reorganize its business. In these types of transactions (such as a sale, merger, liquidation, receivership, or transfer of all or substantially all of GroundSpan's assets), member information is typically one of the business assets that is transferred. If GroundSpan intends to transfer information about you, GroundSpan will notify you by email or by putting a prominent notice on the Site and the App, and you will be afforded an opportunity to opt out before information about you becomes subject to a different privacy policy.

5. Security

The security of your personal information is important to us. Your account information is protected by a password. It is important that you protect against unauthorized access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services.

GroundSpan follows the industry standards or best practices to protect the personal information submitted to us, both during transmission and after it is received. Some of these standards are:

  • Encryption of certain information (such as credit card numbers) using secure socket layer technology (SSL);
  • Protection of the confidentiality, integrity, and availability of all customer information systems;
  • Definition and monitoring of IT security standards consistent with industry regulations;
  • Regular third-party external scan of our websites for identifying vulnerabilities and remediating any identified issues duly;
  • Implementation of vulnerability management techniques according to which we scan and map our network, prioritize areas of importance and apply recommended fixes and safeguards;
  • Application of safeguard firewalls and anti-virus tools to detect/prevent online attacks;
  • Continuous monitoring for security risks and maintenance of patch updated infrastructure;
  • Security awareness trainings to our personnel.

With regard to credit card information, we comply with the Payment Card Industry Data Security Standard ("PCI DSS") by (but not limited to) designing, implementing, and maintaining a coherent set of standards and procedures to manage risks to cardholder data – in an effort to minimize and ensure an acceptable level of Information Security risk – and by conducting regular PCI DSS checks.

We regularly review, test and update our security policies and systems in order to meet the highest standards of data security. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security.

6. What are my rights with respect to my personal data?

You may choose what personal data (if any) you wish to provide to us. However, if you choose not to provide certain details, your experience with some or all of our Services may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveler’s full name and must include contact details. We cannot make bookings for you without that information.

To the extent required by applicable law, you have the right to access your personal data and confirm the processing of your personal data. Also, where applicable, you have the right to rectify inaccuracies or errors, erase, restrict the processing, object to processing, and withdraw consent to processing of your personal data, and where applicable, the right to data portability of your personal data. GroundSpan will handle such requests in the time specified by applicable law and where permitted by applicable law, may charge a reasonable administrative fee to cover the costs of responding to any such request.

In some jurisdictions, in addition to you agreeing to this Policy, data privacy or protection laws may require us to obtain a separate express consent for processing of your personal data. Your consent may also be implied in some circumstances, as permitted by applicable law, such as when communications are required to fulfill your requests.

You must always provide accurate information and you agree to update it whenever necessary. You also agree that, in the absence of any update, we can assume that the information submitted to us is correct, unless we subsequently become aware that it is not correct.

In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorized disclosure of personal information.

You may opt out of any future contacts from us at any time. You can do the following by contacting our customer service via the email address or phone number given on our website:

  • See what data we have about you, if any
  • Change/correct any data we have about you
  • Have us delete any data we have about you
  • Express any concern you have about our use of your data

You also have the following additional rights with respect to your information:

  • You may request that your account be deactivated and no longer be visible. However, GroundSpan must maintain your information in order to comply with legal obligations.
  • You can object to data processing in certain limited circumstances. In such cases, we will cease processing your information upon reasonable advance written notice, unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Personal, payment and ride information are required to provide your rides, receipts, cancellation notices, etc. GroundSpan and providers cannot offer or fulfill the Services without processing this information.

GroundSpan strives to meet its customers' inquiries. If you have a concern about your service or the processing of your information, please contact our customer service.

7. Information for EU Residents:

If You are an EU resident, you are not legally required to provide GroundSpan with the Personal Data described in this Privacy Statement. Further, the contractual relationship that you might have entered with us by making a reservation for our Services does not imply any obligation to provide your Personal Data. However, you might not be able to use our Services to the full extent if you do not provide us with certain data or object to the use of these data in order to complete the transportation request.

Our Legal Basis for Processing your Personal Data
When processing your Personal Data, we rely on the General Data Protection Regulation ("GDPR"), an EU-wide legal framework for the standardization of data protection. GroundSpan primarily processes data as a controller, for the purposes explained above under Sections 1 and 2 of this Privacy Statement. These purposes represent our legitimate interests for the purposes of Article 6 (1) f) GDPR. At the same time, some of the Personal Data we process is necessary for us to perform a contract with you or in order to take steps at your request prior to entering into a contract with you. For example, if you express your interest in transportation services, such as by filling out a web form, we will process the Personal Data submitted to comply with your request. This may include sharing your Personal Data with one of our service partners or their affiliates, who will then use your Personal Data to complete the transportation request. In addition, we are legally obliged to provide certain information to criminal prosecution or tax authorities in individual cases upon request. In these cases, the legal basis for the processing is either legal requirements (Article 6 (1) c) GDPR) or reasons of public interest (Article 6 (1) e) GDPR).

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en

Transferring your Data outside the EU or the EEA
GroundSpan's principal place of business is in United States, which is a "Third Country" under the GDPR. Third Countries are generally not considered to afford the same level of protection that you enjoy in the EU, but GroundSpan still provides an adequate level of protection for your Personal Data - decision 2002/2/EC of the EU Commission states that Canada is deemed to provide an adequate level of data protection regarding commercial organizations such as GroundSpan. We have ensured that our service providers and affiliates have either follows the EU-U.S. Privacy Shield Framework and will process all Personal Data received from EU member states in reliance on the Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee that an adequate level of data protection for your data is guaranteed.

Information about your Right of Objection under Article 21 GDPR
We acknowledge that customers within the Member States of the European Union or other signatories of the Agreement on the European Economic Area have the right to access and receive a copy of personal data we hold about you. Upon request and within one month we will provide You with access to your information, including making reasonable effort to provide you with online access and the opportunity to change or delete inaccuracies or modify your information. To protect your privacy and security, we will also take reasonable steps to verify your identity, such as a password and user ID, before granting access to your data. To exercise these rights please contact Groundspan at privacy@groundspan.com

8. Retention

GroundSpan will retain your information only for as long as it is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your GroundSpan member account), as described in this policy, or as needed to provide the Services to you. If you no longer want GroundSpan to use your information to provide the Services to you, you may close your account. GroundSpan will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, GroundSpan's service providers may also be required to retain and use your information in order to comply with their legal obligations.

9. Policy Changes

GroundSpan reserves the right to change this Privacy Statement. We will provide notification of the material changes to this Privacy Statement through our website at least 30 days prior to the change taking effect. If we believe that the changes are material, we'll do one of (or both) the following: (i) post notice of the changes on the website before the changes become effective, (ii) send you an email about the changes before the changes become effective. We encourage you to check back regularly and review any updates.

10. Privacy Shield

GroundSpan complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. GroundSpan has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, GroundSpan is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@groundspan.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@groundspan.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

GroundSpan's accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, GroundSpan remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless GroundSpan proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, GroundSpan commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact GroundSpan. For contact information check contact section. GroundSpan has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you. If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

11. Contact

If you have any questions, you can contact GroundSpan's Support Team at privacy@groundspan.com and/or write to us at the following address:

Ground Management Holdings LLC
210 Route 4 East
Paramus, NJ 07652
USA