Privacy Policy

This Privacy Policy is incorporated by reference into the PUDO Private LLC Terms of Use. The term “PUDO Private LLC,” “Company,” “we,” and “us” includes PUDO Private LLC and our affiliates and subsidiaries. PUDO Private LLC and its domestic subsidiaries, including Newbell Car Service U.S. Department of Commerce regarding the collection, use, and retention of personal information. PUDO Private LLC has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

This Privacy Policy explains how PUDO Private LLC may: collect, use, and disclose information we obtain through the “Service.”

The “Service” means any website, mobile application, or Internet service under PUDO Private LLC control, whether partial or otherwise, in connection with providing PUDO's online platform that connects users with vehicle-sharing transportation providers in major cities. Each reservation a user makes with such vehicle-sharing transportation providers on the Service is a “Reservation,” and each ride taken through a Reservation is a “Ride.” “Member” means any such individual who uses the Service to make Reservations and take Rides. “Driver Partner” means any such independent contractor partner who registers with the Service as a third-party transportation provider to provide Rides to Members.

Private Jet Charter Broker Service

PUDO Private LLC offers a private jet charter brokers service. In the course of providing this service, we may collect additional personal information from you, such as your travel preferences, destination, and other related information. This information is used to facilitate your booking, customize your travel experience, and provide you with relevant information and updates.

We may also collect information about your travel documents, including passport or other identification details, where necessary to complete your travel booking. This information will be shared with relevant authorities as required by law or for the purpose of facilitating your travel.

We may share your personal information with our trusted third-party service providers, including aircraft operators and other service providers involved in fulfilling your travel arrangements. We require all third-party service providers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We understand the importance of privacy in the context of private jet travel. We are committed to maintaining the confidentiality and security of your personal information and implementing appropriate technical and organizational measures to protect your information against any unauthorized or unlawful processing and against any accidental loss, destruction, or damage.

If you have any questions about this section of our privacy policy, or if you would like to access, update, or correct any information that you have provided to us through your use of the private jet charter brokers service, please send an email to [email protected].

Please note that this section should be read in conjunction with the rest of our privacy policy, including our provisions on the security of your information, your rights to access, update, or delete your information, and the resolution of complaints.

This is a general suggestion and may need to be adjusted to fit the specific practices of your company. It's always a good idea to consult with a legal professional when drafting or updating a privacy policy.

“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, email address, or phone number. We do not consider Personal Information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual.

THE SERVICE COLLECTS YOUR INFORMATION

We collect Personal Information when you:

use the Service; and

communicate with us.

We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Service.

Two kinds of users may use the Service, Members and Driver Partners. We collect different types of information from these two types of users.

Personal Information Collection – Members. You must register to make a Reservation through the Service. To register, you may need to provide Personal Information, such as your name, phone number, email address, billing address, and credit card information. You may also provide other optional information.

Personal Information Collection – Driver Partners. To register as a Driver Partner, you may need to provide Personal Information such as your name, email address, phone number, date of birth, vehicle information, driver’s license information, insurance information, banking information and social security number (SSN) in the United States or National ID Number in the European Union. This type information is collected from Driver Partners to enable our compliance with local and state laws and regulatory requirements applicable to the Service, compliance with tax laws, and to process payments to Driver Partners. Information collected from Driver Partners may be shared with federal and state tax agencies or local regulators as required by law.

Using the Service. We collect information you post through the Service. For example, when you make a Reservation, the Service will collect the information you provide in such submissions, including any Personal Information. We will also store your transaction history.

Making Payments. When you make payments through the Service, you may need to provide Personal Information to our third-party service providers, such as your credit card number. We (or our service providers on our behalf) may store this information for your convenience.

Customer Support. We may collect Personal Information through your communications with our customer-support team.

Location and Other Information from Your Mobile Device. We collect and store your location information if you enable your mobile device to send it to us. We may also collect information that identifies the mobile device you are using. Collection of this information improves the provision of the Service. You may opt-out of location-based services at any time by editing the setting at the device level.

Promotions and Co-Branded Services. We or our advertisers and other business partners may conduct or sponsor special contests, sweepstakes, and other promotions (“Promotions”) that users may enter, register for or otherwise participate in through the Service. Certain of these Promotions may be co-branded with one of our advertisers, business partners, charities, sponsors or other third parties (“Third-Party Partners”). Such co-branded services will identify the Third-Party Partner. In these instances, the Third-Party Partner may collect your Personal Information directly on its website or another online service may collect your Personal Information and share it with us and/or the Third-Party Partner. If you enter a Promotion, your Personal Information may be disclosed to Third-Party Partners or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and publication of a list of winners, as required by law or permitted by the Promotion’s rules.

Information You Provide About a Third Party. If you use our referral program to tell a friend, relative or someone you know about our Service (a “Referred Person”), we will ask you to provide the Referred Person’s name and e-mail address. We will automatically send the Referred Person an e-mail inviting them to try our Service. We may also send a follow-up e-mail or e-mails, at our discretion. If a Referred Person no longer wants to receive communications from us, they can email us at [email protected] with their request and we will discontinue further communications.

Cookies, Automatic Data Collection, and Related Technologies.

The Service and our third party partners collect and store information that is generated automatically as you use it, including your preferences and anonymous usage statistics. When you visit the Service, we and our third-party service providers receive and record information on our server logs from your browser, including your unique device ID, IP address, and from cookies and similar technology. Cookies are small text files placed in visitors’ computer browsers to store their preferences. We may use information collected through these tracking technologies to remember information so that you won’t have to re-enter it on subsequent visits, to provide and monitor the effectiveness of the Service, to provide custom, personalized content including targeted advertising, to automatically update the Service on your mobile devices and for other purposes. Most browsers allow you to block and delete cookies, though depending on your mobile device you may not be able to delete tracking technologies from your device. Deleting or blocking cookies and other tracking technology may cause the Service to not work properly. Although we do our best to honor the privacy preferences of our members, we are not able to respond to Do Not Track signals from your browser at this time. Please see the Online Advertising section below to learn more about how tracking technologies may be used to serve advertising that is relevant to your interests.

By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.

HOW PUDO USES YOUR INFORMATION

We use Personal Information to facilitate and improve our services; and communicate with you.

We may use aggregate information for any purpose, including for marketing purposes.

Internal and Service-Related Usage. We use information, including Personal Information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Service. We may use and retain any data we collect to provide and improve our services.

Communications. We may send email or text messages to the email address or phone number you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.

Marketing. We may use information, including Personal Information, to facilitate transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you, and to serve you personalized advertising content that may be relevant to your interests.

Aggregate Data. We may anonymize and aggregate data collected through the Service and use it for any purpose.

PUDO MAY DISCLOSE YOUR INFORMATION We may share your information:

with our Driver Partners or Members only to facilitate your Rides;

with our third-party service providers;

in the context of a Driver Partner referral;

with insurance companies, government agencies or law enforcement;

to comply with legal obligations;

to protect and defend our rights and property; and with your permission.

We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission.

Driver Partners and Members. When a Member requests a Ride, we may share your first name and last initial and location with a Driver Partner in order to provide the Service. We will not share your e-mail address, phone number or other information with Driver Partners without your permission. With respect to Driver Partners, we may share your name, location and a masked phone number with a Member in order to provide the Service. In connection with a Member’s request to retrieve a lost and found item from a vehicle, we may share your phone number with a Member. Otherwise, we will not share your e-mail address, phone number or other information with Members without your permission.

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Service. We will share information, including Personal Information, with our third-party transportation providers as necessary to provide the Service. If we transfer personal information to a third party, we will take reasonable and appropriate steps to ensure that the third party collects, processes and discloses personal information only for limited and specified purposes. Under PUDO Private LLC Privacy Shield obligations, we may be liable if such third parties fail to meet those obligations.

Driver Partner Referrals. If you are a Driver Partner who has been referred to PUDO Private LLC by another Driver Partner, we may share with your referrer certain information relating to your activity during the applicable referral promotion period, if any (such as your status in the PUDO system and the number of rides you completed during the promotion period).

Marketing. We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission. We may share or allow access to data collected through tracking technologies to serve you personalized advertising content that may be relevant to your interests. Please see the Online Advertising section below to learn more.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena or to meet national security requirements; respond to your requests; or protect yours’, ours’ or others’ rights, property, or safety.

**Merger, Sale, or Other Asset Transfers.If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

Consent. We may also disclose your Personal Information with your permission.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you.

CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at [email protected]. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

INTERNATIONAL USERS

By using the Service, you will transfer data to the United States.

By choosing to visit the Service or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of California and the adjudication of any disputes arising in connection with the Company or the Service will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Policy.

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

If you would like to update or correct any information that you have provided to us through your use of the Service or otherwise, or if you have suggestions for improving this Privacy Policy, please send an email to [email protected].

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

We may revise this Privacy Policy, so review it periodically.

Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted.

New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

Contact Information

PUDO Private LLC

[email protected]