Last modified: January 9, 2023
Introduction
Iron Maintenance, LLC ("Company" or "We") respects your privacy and is committed to protecting it through its compliance with this policy. This policy describes:
This policy applies only to information we collect in the App or through the Website.
This policy DOES NOT apply to information that:
Our other websites and apps, and other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use the App or access, register with, or use the Website. By downloading, registering with, or using the App, or accessing, registering with, and using the Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of the App or the Website after we revise this policy means you accept those changes, so please check the policy periodically for updates.
Children Under the Age of 16
The App is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at Iron Maintenance, LLC, Attn: Legal Department, 2002 West Wahalla Lane, Phoenix, AZ 85027, or via our toll-free number: 1-800-777-0060.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Mobile App and Website Privacy Notice for California Residents, below, for more information.
Information We Collect and How We Collect It
We collect information from and about users of the App or the Website:
Information You Provide to Us
When you download, register with, or use this App, or access, register with, or use the Website, we may ask you provide information:
This information includes:
Automatic Information Collection and Tracking
When you download, access, and use the App or access and use the Website, it may use technology to automatically collect:
If you do not want us to collect this information, you may opt out at any time by notifying us. If you opt out, you will not be able to use the services provided through the App or the Website.
Information Collection Technologies
The technologies we use for automatic information collection may include:
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, to:
The usage information we collect helps us to improve the App and/or the Website and to deliver a better and more personalized experience by enabling us to:
On the App, if we collect and use location information we will do so to match your known location with electronic document submissions to verify your identity and the accuracy of the document submissions.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
In addition, we may disclose personal information that we collect or you provide:
Accessing and Correcting Your Personal Information
You can review and change your personal information by logging into the App or Website and visiting your driver profile page.
You may also send us an email at support@clutchcdl.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. 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. If we delete your personal information, you may not be able to use the functionality that the app provides and you may be unable to transact business through the App or the Website.
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the App or the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the App or the Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Changes to Our Privacy Policy
We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will post the new privacy policy on this page.
The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable phone number for you and for periodically visiting this privacy policy to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at:
Iron Maintenance, LLC
Attn: Legal Department
2002 West Wahalla Lane
Phoenix, Arizona 85027
or via email at: support@clutchcdl.com
or via our toll-free number: 1-800-777-0060
California residents may have additional personal information rights and choices. Please see the CLUTCH Driver Learning Mobile App Privacy Notice for California Residents, directly below, for more information.
CLUTCH Driver Learning Mobile App and Website Privacy Notice for California Residents
This Privacy Notice for California Residents supplements the information contained in the above CLUTCH Driver Learning Mobile App (the “App”) and Website (the “Website”) Privacy Policy and applies solely to all App or Website users 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 the California Privacy Rights Act of 2020 (CPRA), (collectively, the “Acts”) and any terms defined in the Acts have the same meaning when used in this Notice.
Information We Collect
The App and Website 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:
In particular, the App and Website have collected the following types of information from its consumers within the last twelve (12) months, some of which may be considered personal information:
|
Category |
Collected |
Criteria Used to Determine Retention Period |
Business Purpose |
Sold or Shared** |
|
A. Identifiers Examples*: Candidate Name (First, Last if available), and/or email address |
Yes |
Comply with federal transportation regulations, holds related to existing litigation matters, comply with insurance requirements, comply with regulations related to motor vehicle accidents, and/or to address tax, corporate, compliance, and other legal rights and obligations. |
- Adding drivers to driver roster index - Associating drivers to a truck, learning path, job application, instructor, class or learning group - Processing job applications, onboarding employees, administering employee benefits, payroll, and other Human Resources and operational functions |
No |
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples*: A name, Government identifiers (social security, driver’s license number), physical characteristics or description, telephone number, precise geolocation, mail/email/text message contents, education, employment. Some personal information included in this category may overlap with other categories. |
Yes |
Comply with federal transportation regulations, holds related to existing litigation matters, comply with insurance requirements, comply with regulations related to motor vehicle accidents, and/or to address tax, corporate, compliance, and other legal rights and obligations. |
- Adding drivers to driver roster index - Associating drivers to a truck, learning path, job application, instructor, class or learning group - Processing job applications, onboarding employees, administering employee benefits, payroll, other Human Resources and operational functions - Aiding in validating identity, data integrity, accuracy in submitted content - Improving efficiency by matching user/candidate with best suited opportunities |
No |
|
C. Protected classification characteristics under California or federal law.
Examples*: 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). |
Yes |
Comply with federal transportation regulations, holds related to existing litigation matters, comply with insurance requirements, comply with regulations related to motor vehicle accidents, and/or to address tax, corporate, compliance, and other legal rights and obligations. |
- Adding drivers to driver roster index - Associating drivers to a truck, learning path, job application, instructor, class or learning group |
No |
|
D. Biometric information
Examples*: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
Yes |
Comply with federal transportation regulations, holds related to existing litigation matters, comply with insurance requirements, comply with regulations related to motor vehicle accidents, and/or to address tax, corporate, compliance, and other legal rights and obligations. |
- To match drivers with training paths, operations groups, or other opportunities that are best suited to them. - For regulatory purposes - To enhance user/candidate experience |
No |
|
E. Internet or other similar network activity.
Examples*: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Answers to surveys or questionnaires, posts made to community chat, forum, feedback and the like. |
Yes |
Comply with federal transportation regulations, holds related to existing litigation matters, comply with insurance requirements, comply with regulations related to motor vehicle accidents, and/or to address tax, corporate, compliance, and other legal rights and obligations. |
- To match drivers with training paths, operations groups, or other opportunities that are best suited to them to analyze traffic - To enhance user/candidate experience |
No |
* - Examples represent the types of information that constitute the categories, but are not necessarily specifically collected by Company
** - For purposes of these charts, the term "Shared" is based on the definition found in the CPRA, section 1799.140(ah)(1): "“Share,” “shared,” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged."
|
Sensitive Personal Information Category |
Collected |
Criteria Used to Determine Retention Period |
Business Purpose |
Sold or Shared** |
|
Government identifiers (social security, driver's license, state identification card, or passport number) |
Yes |
Comply with federal transportation regulations, holds related to existing litigation matters, comply with insurance requirements, comply with regulations related to motor vehicle accidents, and/or to address tax, corporate, compliance, and other legal rights and obligations. |
Processing job applications, onboarding employees, administering employee benefits, payroll, other Human Resources and operational functions; confirming eligibility to operate a commercial vehicle |
No |
|
Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password) |
Yes |
Comply with federal transportation regulations, holds related to existing litigation matters, comply with insurance requirements, comply with regulations related to motor vehicle accidents, and/or to address tax, corporate, compliance, and other legal rights and obligations. |
To allow employees or contractors to access company systems |
No |
|
Precise geolocation |
Yes |
Comply with federal transportation regulations, holds related to existing litigation matters, comply with insurance requirements, comply with regulations related to motor vehicle accidents, and/or to address tax, corporate, compliance, and other legal rights and obligations. |
To match your known location with electronic document submissions to verify your identity and the accuracy of the document submissions |
No |
|
Racial or ethnic origin |
Yes |
Comply with federal transportation regulations, holds related to existing litigation matters, comply with insurance requirements, comply with regulations related to motor vehicle accidents, and/or to address tax, corporate, compliance, and other legal rights and obligations. |
To comply with Federal and state laws |
No |
|
Religious or philosophical beliefs |
No |
N/A |
N/A |
No |
|
Union membership |
No |
N/A |
N/A |
No |
|
Genetic data |
No |
N/A |
N/A |
No |
|
Mail, email, or text messages contents not directed to us |
No |
N/A |
N/A |
No |
|
Unique identifying biometric information |
No |
N/A |
N/A |
No |
|
Health, sex life, or sexual orientation information |
No |
N/A |
N/A |
No |
The App and Website obtain the information listed in the chart above:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
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 and Disclosure of Personal Information
The CPRA defines the term “Sharing” as follows”: "Shared" is based on the definition found in the CPRA, section 1799.140(ah)(1): "“Share,” “shared,” or “sharing” means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged."
Based on the above definition, we do not share your information collected through the App or the Website, because we do not do any cross-contextual behavioral advertising with that information.
We may disclose your personal information to the following categories of entities for a business purpose, including:
When we disclose personal information to a service provider or a contractor for a business purpose, we enter into a contract that requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We also may disclose personal information to our affiliates or, if required by law, to a governmental entity.
Sale of Personal Information
In the preceding twelve (12) months, we have not sold personal information.
Your Rights and Choices
The Acts provide consumers (California residents) with specific rights regarding their personal information. This section describes your rights under the Acts and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to know what personal information we have collected, used, or disclosed and can request a copy of that data in a portable format.
Deletion or Correction Request Rights
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. You also have the right to request that we update or correct any of your personal information that we collected from you and retained that is incorrect. Once we receive and confirm your verifiable consumer request, we will delete or correct (and, where applicable, direct our service providers to delete or correct) your personal information from our records, unless an exception applies.
We may deny your deletion or correction request if retaining the information is necessary for us or our service provider(s) to:
The CPRA specifically grants Consumers the right to limit the use and disclosure of your sensitive personal information to actions necessary to perform the specific purposes permitted under the Acts. We can continue using or disclosing your sensitive personal information after receiving a limitation request from you, for the following purposes:
Exercising Access, Data Portability, Correction, and Deletion Rights
To exercise the access, data portability, correction, deletion and limitation of use and disclosure of sensitive personal information rights described above, please submit a verifiable consumer request to us by either:
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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
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.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
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 an additional 45 days), we will inform you of the reason and extension period in writing.
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.
Cross-contextual behavioral advertising, commonly referred to as targeted advertising, is the tracking of a consumer’s activities across websites, applications, and services to identify and present advertisements tailored to their behavior. The Acts provide you the right to opt-out of sharing of personal information for cross-contextual behavioral advertising, however, at the present time, we do not share your information collected through the App or the Website for cross-contextual behavioral advertising.
Non-Discrimination
We will not discriminate against you for exercising any of your rights under the Acts. Unless permitted by the Acts, we will not:
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the App and update the notice's effective date. Your continued use of the App or the 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 the Company collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Postal Address:
Iron Maintenance, LLC
Attn: Legal Department
2002 West Wahalla Lane
Phoenix, Arizona 85027
Email Address: support@clutchcdl.com
Or Phone at: 1-800-777-0060