I. Introduction

When you use Tow Track LLC, you entrust us with your personal data. Our foremost commitment is to uphold that trust. This begins with ensuring you comprehend our privacy practices.

This notice elucidates the personal data (“data”) we gather, its utilization and dissemination, and the choices available to you regarding this data. We advise you to read this in conjunction with our privacy overview, which underlines the essential aspects of our privacy measures.

II. Overview

A. Scope

This notice is applicable to users of Tow Track LLC’s services globally. This encompasses users of Tow Track LLC's apps, websites, features, or any other provided services.

This notice outlines how Tow Track LLC and its associated entities gather and utilize data. This notice is relevant to all Tow Track LLC users worldwide unless they use a service with its dedicated privacy notice. Specifically, this notice caters to:

• Customers: Individuals who request or receive towing or related services via their Tow Track LLC account.
• Drivers: Individuals or entities that provide towing services to customers.
• Enterprise Users: Companies or organizations that avail of Tow Track LLC's services for their fleets or vehicles.
• Guest Users: Individuals who receive towing services arranged by other Tow Track LLC account holders, including services set up by Enterprise Users.

II. Additional Provisions

This notice also directs Tow Track LLC’s collection of data in association with its services. For instance, we might collect the contact details of owners or employees of auto repair shops or other partners associated with the Tow Track LLC platform. This also includes contact details of individuals managing and using accounts owned by larger organizational clients or data from individuals who initiate but do not complete the sign-up process to become drivers.

All individuals and entities outlined in this notice are addressed as “users” for the purpose of this documentation.

Our privacy procedures adhere to applicable regulations in the regions where we operate. This implies we engage in the practices discussed in this documentation in specific countries or areas only when allowed by local regulations. Further, consider the subsequent provisions:

• For users in the United States: Detailed information about Tow Track LLC's privacy practices under U.S. state privacy regulations, including the California Consumer Privacy Act (CCPA), can be found here.
• For users in [Another Country]: Specific clauses for privacy practices under [Country's Privacy Law]. Additional details can be found here.

If you have inquiries about our operations in a particular region, please contact us or refer to the addresses provided.

B. Data Controller and Transfer

Tow Track LLC is the primary data controller for the information collected in connection with the use of its services. For services provided in specific jurisdictions or regions, local branches or entities of Tow Track LLC might act as the data controller, adhering to the regulations of that region.

While Tow Track LLC mainly operates and processes personal data globally, the data's jurisdiction remains crucial. Wherever you travel with Tow Track LLC, your data is with you, ensuring a seamless experience. We respect your data protection rights, regardless of your current location.

This means we might transfer personal data to countries other than your home country to provide our services in a different country per your request. Such transfers might also occur if we need to respond to a support request you submitted outside your region. As our services can involve multiple users simultaneously, some personal data may be accessible to other users in different countries.

These transfers are done to fulfill our agreements with all our users, based on users’ explicit instructions or prior consent, established international agreements, or other transfer mechanisms as may be available as per applicable law.

We might also transfer data to meet requests from law enforcement agencies. For these transfers, Tow Track LLC employs a stringent internal protocol to process these requests. We only disclose personal data to law enforcement agencies in a manner consistent with the legal requirements of applicable laws.

To ensure consistent data protection wherever you use our services, Tow Track LLC has implemented several measures globally, including:

• Policies and procedures to restrict access to and the processing of personal data for specific purposes.
• Training for personnel responsible for managing personal data.
• A government data access policy that declines government access to data, except when mandated by applicable laws, facing imminent risk to individuals, or upon obtaining consent.
• Robust protection of data during transit between Tow Track LLC apps and our servers, including encryption and the use of pseudonymized data to safeguard users' full identity against unauthorized disclosure.

If you have any questions, comments, or concerns about Tow Track LLC’s data practices, please reach out to us through our designated channels. Your data protection rights can be directed to Tow Track LLC, and we handle them centrally for the relevant controller.

III. Data Collections and Uses

A. The Data We Collect

TOW TRACK LLC collects data:

• Provided by users to TOW TRACK LLC, such as during account creation.
• Created during the use of our services, like location, app usage, and device data.
• From other sources, including other users or account owners, business partners, vendors, insurance providers, and governmental authorities.

For clarity, we've provided a summary of the data we collect and how we use it below.

TOW TRACK LLC collects the following data:

1. Data Provided by Users: This includes:
   • User Profile Information: We collect data when users create or update their TOW TRACK LLC accounts. This may include name, email, phone number, address, profile picture, payment or banking information, and government-issued documents. It also includes vehicle or insurance information for transporters and emergency contact details.
   • Background Check Information: This encompasses information submitted during the transporter application process, such as driving history and right to work. This data might be collected by an authorized vendor on TOW TRACK LLC's behalf.
   • Identity Verification Photos: Photos of users and/or their government-issued IDs. These photos might be utilized to validate a user's identity for safety and security purposes, including facial verification technologies.
   • Demographic Data: We might collect data such as birth date, gender, or occupation, when necessary for specific TOW TRACK LLC services, like our VIP Transport. We could also infer demographic data based on other collected data.
   • User Content: We gather data users submit when they reach out to TOW TRACK LLC's support, provide ratings, or otherwise contact TOW TRACK LLC. This could encompass photos or recordings associated with customer support requests.
   • Travel Information: Though the specifics are undecided, there might be features in the future related to travel or itinerary that could require collecting additional user information.

We emphasize that user trust is central to our mission. As we conduct our beta in Las Vegas, NV, and prepare for wider US operations, we commit to transparency and the highest standards of data protection.

2. Data Created During Use of Our Services

1. Location Data (Driver and Delivery Person): We collect precise or approximate location data from drivers’ and delivery persons’ mobile devices when the TOW TRACK LLC app is running either in the foreground or background.
2. Location Data (Clients and Order Recipients): We collect location details from clients’ mobile devices, given they permit this through device settings. Precise location data is accumulated from the moment an order is placed until it is completed. Clients can use TOW TRACK LLC without providing location access, but some features, like auto-detecting pickup points, might be affected. Even if a client has not enabled location services, the driver’s location data during a service is linked to the client's account for various purposes, including receipt generation and customer support.
3. Transaction Information: Details related to transactions made using our services are stored. This encompasses the kind of service availed, service specifics like date, time, addresses involved, distance covered, items ordered, and payment details.
4. Usage Data: Data on user interactions with our services, such as access times, viewed features or pages, browser type, app crashes, and system activities, are collected.
5. Device Data: We gather details about devices used to access our services. This includes hardware models, unique device identifiers, operating systems, languages, advertising identifiers, motion data, and mobile network data.
6. Communications Data: Information related to phone, text, or in-app communications between users via the TOW TRACK LLC app is collected. This encompasses the date, time, and content of text or in-app messages. If phone calls are recorded, users are informed in advance.

3. Data From Other Sources

We also obtain data from a range of other sources. These include:

• Users who participate in our referral programs. For instance, if a user refers another individual, we acquire the referred person's details from the referrer.
• TOW TRACK LLC account owners who request services for others or enable others to avail services through their business accounts.
• Individuals providing information regarding claims or disputes.
• Business partners associated with TOW TRACK LLC, such as those through which users access their TOW TRACK LLC account. This includes payment providers, social media services, and platforms utilizing our APIs.
• Partners collaborating on financial products, especially in situations where a debit or credit card is issued in alliance with TOW TRACK LLC, as outlined in the specific card's terms.
• Vendors assisting with user identity verification, background checks, and employment eligibility. This also covers checks for sanctions, anti-money laundering measures, and user screening.
• Insurance, vehicle, or financial service providers catering to drivers.
• Transport companies partnering with TOW TRACK LLC for drivers who use our services via an account linked to such a company.
• Publicly accessible data sources.
• Providers offering marketing services or data resellers, which TOW TRACK LLC employs for marketing or research.
• Governmental entities, including law enforcement and public health officials.

B. How We Use Personal Data

TOW TRACK LLC leverages user data to facilitate efficient and trustworthy auto transportation services. Additionally, the collected data assists us in:

• Enhancing the safety and security of our users and services.
• Providing customer support.
• Conducting research and development.
• Enabling user communications.
• Marketing and advertising.
• Disseminating non-marketing communications to users.
• Engaging in legal proceedings.

We've summarized below how we utilize the data:

1. Service Provision: TOW TRACK LLC uses data to offer, customize, maintain, and enhance our services. This encompasses:
   • Account creation and updates.
   • Enabling transportation and related services or features, for instance:
     • Utilizing location data for transportation coordination, calculating ETAs, and monitoring transportation progress.
     • Features that share data, such as sharing transporter details with clients to facilitate coordination.
     • Matching transporters to users based on various criteria like location and user preferences.
     • Supporting users with disabilities.
   • Dynamic pricing considerations.
   • Personalizing user experiences.
   • Facilitating insurance and vehicle solutions.
   • Communicating important updates and policy changes.
   • Conducting essential operations, including troubleshooting and software maintenance.

We undertake the aforementioned activities rooted in our commitment to serving our users' best interests and ensuring adherence to our agreements.

2. Safety and Security

We prioritize the safety, security, and integrity of our services and users. To this end, we use data in the following ways:

• Verifying users' identity and their eligibility to provide transportation services. This includes background checks to prevent engagement by unsafe drivers.
• Implementing features such as the Real-Time ID Check. This prompts transporters to share a selfie before they can offer their services, ensuring the individual matches the account on file.
• Employing facial recognition to process user profile photographs and other user-submitted images to combat identity borrowing or unauthorized service provision.
• Utilizing selfies to verify users are adhering to certain safety protocols or wearing specific safety equipment.
• Enforcing verification for specific payment methods or service types, such as age verification for specific deliveries.
• Monitoring transporter behavior to encourage safe driving practices.
• Identifying and combating various types of fraud, including account misuse and unauthorized access.
• Encouraging compliance with our Community Guidelines, deactivating users who violate them, and providing necessary feedback mechanisms.
• Utilizing data-driven approaches to reduce the risk of conflicts between users.
• Sharing essential user information with third-party companies that assist in managing and de-escalating conflicts that may arise during service provision.

We undertake these activities with the goal of ensuring the safety and security of all stakeholders involved. Upholding our agreements with users and protecting the interests of TOW TRACK LLC, our users, and the public are of paramount importance to us.

3. Customer Support

TOW TRACK LLC uses the information we collect, potentially including call recordings, to deliver customer support. This encompasses investigating user concerns and optimizing our support processes and responses.

We undertake these activities based on our commitment to fulfilling user agreements and improving our customer support services.

4. Research and Development

We utilize data for testing, research, product development, and enhancing the user experience. This enables us to optimize our services, bolster security measures, and innovate with new features and services.

These efforts align with TOW TRACK LLC's genuine interest in refining and unveiling new services and functionalities.

5. Enabling User Communications

As an example, transporters might communicate with clients to clarify details related to the transportation service or to resolve any queries. The facilitation of such interactions is integral to our user agreements.

6. Marketing and Advertising

We employ the data we acquire to market TOW TRACK LLC services and offerings from our partners. Examples of our marketing methods include:

• Sending out emails, texts, app notifications, and other communications with information on our products, services, and promotions.
• Using data like location, transportation history, and device info to send tailored marketing messages aligned with users' preferences and behaviors.
• Exhibiting TOW TRACK LLC ads on third-party platforms. This may involve sharing data with advertising collaborators to create personalized ads.
• Showcasing third-party ads within our app or in conjunction with our services. These ads are personalized based on user data and activity.
• Assessing the effectiveness of our marketing strategies and the resonance of third-party ads presented within our app or services.

Our marketing and advertising endeavors arise from TOW TRACK LLC's genuine interest in enlightening users about our services and related opportunities. Users have the freedom to make choices regarding our use of their data for marketing and advertising.

7. Non-marketing Communications

TOW TRACK LLC may use collected data to dispatch surveys and other non-marketing related communications. This might include updates on relevant legislative or regulatory changes that could impact our services. For instance, we might notify users of potential policy shifts or legislative actions concerning the transportation sector in their regions.

We undertake these activities based on our commitment to fulfilling user agreements and informing our users about events or changes that could influence their utilization of TOW TRACK LLC services.

8. Legal Proceedings and Requirements

We utilize collected data to delve into or address claims or disputes linked to the use of TOW TRACK LLC's services. Additionally, we ensure compliance with applicable laws, regulations, and other obligatory mandates. This might also encompass responding to legal processes or governmental requests, including from law enforcement agencies.

These endeavors stem from TOW TRACK LLC's genuine interest in addressing claims and disputes related to our services, as well as our dedication to adhering to all necessary legal and regulatory requirements.

C. Cookies and Third-party Technologies

TOW TRACK LLC, in partnership with third parties, employs cookies and other identification technologies on our apps, websites, emails, and online ads, aligned with the purposes detailed in this notice and TOW TRACK LLC’s Cookie Notice.

Cookies are minuscule text files saved on browsers or devices by websites, apps, online media, and advertisements. TOW TRACK LLC leverages cookies and analogous technologies for purposes like:

• Authenticating users.
• Recalling user preferences and settings.
• Assessing content popularity.
• Executing and gauging the impact of advertising campaigns.
• Analyzing website traffic and patterns, and generally fathoming the online behaviors and inclinations of individuals interacting with our services.

We might also authorize third-party entities to gauge audience size, run analytics services for us, manage advertisements on our behalf across the web, and monitor and report on the efficacy of these ads. These parties might employ cookies, web beacons, SDKs, and other tech tools to recognize the devices users employ to access our websites, as well as during visits to other online sites and services.

For an expansive explanation regarding the usage of cookies and other technologies covered in this segment, kindly refer to TOW TRACK LLC’s Cookie Notice.

D. Data Sharing and Disclosure

Some of TOW TRACK LLC’s services necessitate the sharing of data with other users or upon a user's request. We might also share this data with our associated entities, subsidiaries, and partners for legal reasons or in relation to claims or disputes.

TOW TRACK LLC may disseminate data:

1. With Other Users:
   • For customers, we share details such as the first name and pickup and/or drop-off locations with transporters.
   • Transporters will be privy to data, including name, vehicle details, location (pre and during service), average rating from users, total number of transports, duration since they registered, contact details, and profile data, including feedback from previous users.
   • We furnish customers with invoices that detail amounts, transporter's first name, and route map. Additionally, other legally mandated details may appear on these receipts.
   • In the context of TOW TRACK LLC’s referral program, referral-related data of the referred users, such as transport count, may be shared with the referrer to decide the referral bonus.
2. At the User's Request:
   • Data can be shared with others upon a user's request. As an example, we share user's location and estimated arrival time with a friend upon the user’s behest.
   • Partners of TOW TRACK LLC: If a user requests a service via a promotional or partnership deal initiated by a third party, TOW TRACK LLC might share certain data with those third parties. This encompasses platforms or other services that integrate with our APIs, partners related to promotions, or other specialized services.
   • Emergency Services: We have features that empower users to share their data with emergency services during emergencies or post incidents. For a more in-depth understanding, please refer to the sections titled "Choice and Transparency" and "Emergency Data Sharing".

E. Data Sharing and Public Disclosure

1. With the General Public:
   • User inputs or remarks made through public platforms, like TOW TRACK LLC blogs or TOW TRACK LLC's social media, might be accessible to the broader public. This includes any data within the user's submissions.
2. With the TOW TRACK LLC Account Owner:
   • If services are accessed via an account governed by another entity, we may share the service details, including location data, with the account's proprietor. This might be the case when:
     • A customer uses an employer-linked TOW TRACK LLC profile.
     • A transporter utilizes an account linked to a TOW TRACK LLC partner company.
     • Service details are organized by a friend or under a family profile.
   • If an account is initiated using an email linked to a TOW TRACK LLC business account owner (potentially an employer), we might share profile details (like name and email) to help the user attribute services to the business account.
3. With TOW TRACK LLC Subsidiaries and Affiliates:
   • We collaborate with our subsidiaries and affiliated entities to offer our services or for them to process data on our behalf. For instance, data might be processed and stored in the US on behalf of our global branches. Detailed policies related to specific subsidiaries or services will be available for users.

F. Partnerships and Third-Party Providers

TOW TRACK LLC may collaborate with various service providers and partners, which include:

1. Payment Systems and Facilitators: Platforms that handle payments or financial transactions related to our services.
2. Background Checks and Identity Verifications: Entities responsible for ensuring the authenticity and eligibility of our transporters.
3. Cloud Storage Solutions: Companies that offer secure data storage and backup services.
4. Map and Location Services: For example, Google Maps, to enhance our app's user experience. Always consult third-party privacy policies for further details.
5. Social Media and Marketing Platforms: Partners like Facebook or other online platforms that we might use for advertising or promotional purposes. We encourage users to familiarize themselves with the respective privacy policies of these platforms.
6. Advertising Mediators: Organizations facilitating personalized ads for products within the TOW TRACK LLC app or platform, using data to optimize user experience and advertising strategies.
7. Research Affiliates: Groups that collaborate with TOW TRACK LLC for surveys, data collection, and analytical projects.
8. Safety and Security Vendors: Partners that help bolster the safety and security aspects of our platform and services.
9. Professional Consultation: This encompasses consultants, legal advisors, auditors, and other professional entities.
10. Insurance and Financing Affiliates: Entities that provide insurance solutions or financial assistance related to our services.
11. Vehicle Providers: Third-party vehicle suppliers, including fleets or rental partners, supporting our operations.

We believe in maintaining transparency, and we prioritize user data protection in all our affiliations and partnerships. Any data sharing is executed with user consent and in alignment with our commitment to privacy.

G. Legal Provisions and Dispute Resolution

TOW TRACK LLC may disclose user data for legal reasons or during dispute resolutions:

1. Legal Obligations and Safety Concerns: We may share user information if we deem it necessary as per applicable laws, regulations, licenses, legal procedures, or governmental requests. This can also be the case if we feel it's imperative for safety or similar paramount concerns.
2. Collaboration with Law Enforcement and Other Authorities: This involves sharing data with law enforcement agencies, public health organizations, other governmental bodies, airports (especially when mandated by airport officials), or other third parties. Such sharing ensures we uphold our User Agreements, Terms of Service, and other policies. It also allows us to safeguard our rights and assets, as well as those of other users.
   For detailed guidelines, users are advised to refer to our Guidelines for Law Enforcement and Third Party Data Requests.
3. Business Mergers and Transactions: We may share user data in connection with business-related activities like mergers, sales of company assets, restructuring, financing, or any acquisition endeavors.
4. User Consent: Beyond the scenarios mentioned above, TOW TRACK LLC might share user data in cases where we provide clear notification to the user and obtain their explicit consent.

We're committed to upholding the highest standards of integrity and transparency. All data sharing practices are anchored in our dedication to user privacy and compliance with legal provisions.

H. Data Retention and Deletion

TOW TRACK LLC stores user data for durations determined by the type of data, user category, and the purpose for data collection. We are dedicated to ensuring utmost transparency and adhering to legal obligations regarding data storage and deletion.

1. Duration of Data Retention: We retain data for time periods based on its relevance to our services, legal necessities, safety concerns, and other factors. Examples of our retention practices include:
   • Retaining user profile data for the entire duration of the user's account for service facilitation.
   • Storing trip or delivery location details of drivers and delivery persons for 7 years to adhere to tax regulations.
   • Maintaining incomplete driver applications for a year and rejected applications for 7 years for safety and fraud prevention purposes.
   • Preserving data after account deletion requests if there are outstanding issues related to the user's account, like unsettled credits or unresolved claims.
2. Account Deletion: Users possess the right to request account deletion at their discretion. Upon receiving a deletion request, TOW TRACK LLC ensures the account and associated data are deleted unless we need to retain them due to regulatory, safety, or security reasons, or existing issues like unresolved disputes.
   For driver and delivery personnel data, the general practice is to retain the data for the statutorily prescribed period after a deletion request. However, for riders, the typical deletion timeline post-request is within 90 days, barring the exceptions mentioned above.
3. How to Request Account Deletion: Users can initiate the account deletion process via:
   • Accessing the Settings > Privacy menus in the TOW TRACK LLC app.
   • Utilizing our website's dedicated portals for riders, drivers, delivery personnel, and guest users.

We consistently strive to align our data retention practices with our commitment to user privacy, transparency, and compliance with prevailing regulations.

IV. Choice and Transparency

TOW TRACK LLC prioritizes user autonomy when it comes to accessing and controlling data we collect. We provide mechanisms for users to:

• Adjust privacy settings
• Manage device permissions
• Access in-app ratings pages
• Make marketing choices
• Request data access, corrections, or deletion

A. Privacy Settings

The Settings > Privacy menu in our app offers riders the ability to tailor their data-sharing preferences. We also offer a web version of our Privacy Center for enhanced accessibility.

1. Location Data Collection (Riders): Riders can enable or disable TOW TRACK LLC's access to location data via their mobile device settings, accessible through Settings > Privacy > Location.
2. Share Live Location (Riders): Riders have the option to let TOW TRACK LLC share their real-time location with their drivers. This preference can be modified via Settings > Privacy > Location.
3. Emergency Data Sharing: For safety purposes, riders can permit TOW TRACK LLC to relay real-time location data to emergency services, which might include details such as current location, vehicle information, rider details, and driver information. This feature can be toggled on/off via the Settings > Privacy > Location menu or the Safety Center.
4. Notifications - Account and Trip Updates: We send notifications concerning trip status and account-related activities. These are essential for the optimal user experience and cannot be turned off. However, the notification method can be adjusted via Settings > Privacy.
5. Notifications - Discounts and News: Users can opt to receive push notifications about promotions and news from TOW TRACK LLC. This can be managed in the Settings > Privacy section of the app.

We are committed to keeping our users informed while also respecting their choices and preferences regarding data collection and communications.

B. Device Permissions

Most mobile platforms (iOS, Android, etc.) have certain device data that apps cannot access without the device owner’s permission. These platforms offer various methods to obtain such permissions. We advise checking the settings of your device or consulting with your device provider for more information.

C. In-app Ratings Pages

Following every trip, both drivers and riders can rate each other on a 1 to 5 scale. This rating average is linked to a user's account and is visible to other users when services are being provided or received. For instance, drivers can see the ratings of riders requesting transportation, and riders can view the ratings of their drivers.

This bilateral rating system ensures accountability, fostering a respectful and safe environment for all users.

Riders can view their average rating within the main menu of the app. They can also access a detailed breakdown of their rating within the app's Privacy Center.

Drivers can view their average rating by tapping on their profile picture in the app. More information here.

D. Marketing and Advertising Choices

TOW TRACK LLC offers users choices regarding how their data is used for marketing and advertising:

• Personalized Marketing Communications: Users can decide if TOW TRACK LLC can use their data to send tailored communications (such as emails, push notifications, or in-app messages) about TOW TRACK LLC services and offers. Users can also choose to receive any marketing emails or push notifications from TOW TRACK LLC. Adjust preferences here.
• TOW TRACK LLC Ads: Users can decide if their data is shared with advertising partners to deliver tailored ads about TOW TRACK LLC services on third-party platforms or to gauge the effectiveness of such ads. Modify preferences here.
• Third Party Ads: Users can decide if TOW TRACK LLC can use their data to display ads for third-party products or services based on their observed or inferred preferences and characteristics. Adjust settings here.
• Cookies and Related Technologies: For information on controlling TOW TRACK LLC's use of cookies and similar technologies, especially for ad personalization, refer to our Cookie Notice.

E. User Data Requests

Tow Track LLC offers users several methods to understand, control, and inquire about our management of their data.

• Accessing Data: Users can access their profile data and towing history through the Tow Track LLC apps or via our website. Our "Explore Your Data" feature provides an online summary of user account details, such as the number of tows, user rating, and the duration of their association with Tow Track LLC. Users can also request access to their data using the relevant links for customers and tow operators.
• Data Portability: The "Download Your Data" tool enables users to request a copy of their data. For a comprehensive list of data available through this tool, click here. Users can also request copies of their data through links for customers and tow operators.
• Changing or Updating Data: Within the Settings menu of Tow Track LLC’s apps or the tow operator portal, users can modify their name, phone number, email address, and payment method. They can also request updates or corrections to their data through links for customers and tow operators.
• Deleting Data: Through Tow Track LLC’s Privacy Center or the Settings > Privacy menu in the app, users can request account deletion at any time.
• Objections, Restrictions, and Complaints: Users can request limitations on our use of their data or ask us to cease using certain parts of it through the appropriate links for customers and tow operators. This encompasses objections to our data use based on Tow Track LLC’s legitimate interests. In certain circumstances, even after such objections or requests, Tow Track LLC may continue processing data as mandated or permitted by law.
• Appeals: Customers have the option to request a review if Tow Track LLC cannot fulfill or declines a user’s data request. Appeals for our decision can be made here.

Furthermore, depending on their geographical location, users might possess the right to file complaints related to Tow Track LLC’s data management with the relevant data protection authority in their nation. For instance, users in regions like the European Union can address their complaints to the local data protection authorities.