Legal matters

Additional policies

The various policies on this page are important additional policies that govern your relationship with Turo.

Biometric data privacy policy

Cookies, web beacons, and similar technologies

Copyright policy

Insurance license disclosures

Payment plan terms

Privacy policy supplements

Biometric data privacy policy

Last revised: October 24, 2024

In connection with the identity and driver’s license verification features on the Services (as defined in the Turo terms of service), Turo Inc. and its subsidiaries (together, "Turo") and/or our third-party service provider(s) may process, derive, or otherwise possess biometric data, as defined below. This biometric data privacy policy applies to Turo’s processing of such biometric data.

Biometric data defined

As used in this biometric data privacy policy, biometric data includes both “biometric identifiers” and, where applicable, “biometric information,” as such term(s) are defined under the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. (“BIPA”), the Texas Capture or Use of Biometric Identifiers Act, Tex. Bus. & Com. Code Ann. § 503.001 (“CUBI”), or the Washington H.B. 1493, RCW 19.375 (“WA HB 1493”), where applicable based on the user’s state of residency (the “Applicable Biometric Data Privacy Law”).

For example, under BIPA, “biometric identifier” includes a retina or iris scan, or face geometry, but does not include photographs, demographic data, or physical descriptions such as height, weight, hair color, or eye color. “Biometric information” under BIPA means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual, but does not include information derived from items or procedures excluded under BIPA’s definition of biometric identifiers.

Purpose for collection of biometric data

Turo and/or our third-party service provider(s) may derive, generate, collect, store, and use biometric data, which may include certain scans of facial geometry, in order to provide certain features of the Services to our users. For example, Turo may use our third-party service provider(s) to generate biometric data in connection with the scanning of a user-provided photograph and driver’s license. Turo and/or our third-party service provider(s) will only use this biometric data for the purposes of identity and driver’s license verification and for legal compliance purposes.

Before collecting, deriving or generating any biometric data from or regarding you, Turo will obtain your consent where and as required by Applicable Biometric Data Privacy Law.

Disclosure of biometric data

Turo and/or our third-party service provider(s) may disclose biometric data only as necessary to facilitate the provision of the Services to the applicable user.

Turo does not share biometric data with anyone other than authorized third-party service provider(s) unless:

• The user or the user’s legally authorized representative consents to the disclosure;
• The disclosure is required by applicable law or regulation or otherwise permitted by Applicable Biometric Data Privacy Law;
• The disclosure is required to complete a financial transaction requested or authorized by the user; or
• The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

Retention and storage of biometric data

Turo and/or our third-party service providers generally retain biometric data for only as long as necessary to satisfy the purposes for collection and processing identified above. Notwithstanding the foregoing, except to the extent required by applicable law, in no event will Turo retain a user’s biometric data beyond the date that is three years following the user’s last interaction with Turo.

Cookies, web beacons, and similar technologies

Turo uses “Cookies”, web beacons, and similar technologies in connection with our Platform to obtain information. A Cookie is a small data file that is transferred to your device (e.g., your phone or your computer) for record-keeping purposes. Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser or device you use will need to be set separately and different browsers and devices offer different functionality and options. Please note that some parts of our Services may not work as intended or may not work at all without Cookies.

Turo Cookies and third party Cookies

Turo, or our service providers, may place our Cookies on your device via our Platform. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our Cookies. There are two types of Cookies — “persistent Cookies” and “session Cookies” — used in connection with our Services. Session Cookies will normally expire when you close your browser, while persistent Cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.

Turo uses of Cookies

Turo uses Cookies for a number of purposes, such as:

• Operationally necessary. We, and third party companies and individuals we engage to provide services to us, may use Cookies, web beacons, or other similar technologies (collectively “Cookies”) that are necessary to the operation of our sites, services, applications, and tools (“Platform”). This includes technologies that allow you access to our Platform that are required to identify irregular site behavior, prevent fraudulent activity, and improve security or similar functions.
• Performance-related. We may use Cookies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our Platform, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Platform.
• Functionality-related. We may use Cookies that allow us to offer you enhanced functionality when accessing or using our Platform. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites.
• Advertising or targeting-related. We may use first-party or third-party Cookies to deliver content on our Platform or on third-party websites and applications. This includes using technologies to understand the usefulness to you of content that has been delivered to you, such as whether you have clicked on an advertisement.
• Google Analytics. We also use Google Analytics, which uses Cookies and other, similar technologies to collect information about use of the Services anonymously and reports website trends, without identifying individual visitors. You can learn about Google's practices by going to www.google.com/‌policies/privacy/?partners/, and opt out of them by downloading the opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout.
• Disabling Cookies. Most browsers automatically accept Cookies, but you can modify your browser setting to decline Cookies by following the instructions provided in your browser. If you choose to decline Cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform.

Changes to this Cookie Policy

We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Platform or by sending you an email. It's important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide our Services to you, and your only option is to stop accessing our Services.

Copyright policy

Last revised: June 16, 2021

Turo respects the intellectual property rights of others and takes claims of copyright infringement seriously. Turo will respond to notices of alleged copyright infringement that comply with applicable law. In responding, Turo will take all actions that Turo, in its sole discretion, deems appropriate and necessary, up to and including the removal of the challenged material and/or disabling/terminating the accounts of users who are repeat infringers.

Reporting claims of copyright infringement

If you believe any materials accessible on or from the Services (as defined in our Terms of service Terms of service) infringe your copyright, you may request removal of those materials (or access to them) from the Services by submitting written notification to our copyright agent designated below. In accordance with the Online Copyright Infringement Liability Limitation Act of the Digital Millennium Copyright Act (17 U.S.C. § 512) ("DMCA"), the written notice (the "DMCA Notice") must include the following:

• Your physical or electronic signature
• Identification of the copyrighted work you believe to have been infringed or, if the claim involves multiple works on the Services, a representative list of such works
• Identification of the material you believe to be infringing in a manner sufficient enough to allow us to locate that material, including, at minimum, the URL of the page/account where the allegedly infringing material can be found
• Adequate information that we may use to contact you (including your name, postal address, telephone number, and email address)
• A statement that you have a good faith belief that use of the copyrighted material is not authorized by the copyright owner, its agent, or the law
• Each of the following statements:
• "I hereby state that I have a good faith belief that the disputed use of the copyrighted material is not authorized by the copyright owner, its agent, or the law (e.g., as a fair use)."
• "I hereby state that the information in this Notice is accurate and, under penalty of perjury, that I am the owner, or authorized to act on behalf of the owner, of the copyright or of an exclusive right under the copyright that is allegedly infringed."

Designated copyright agent

Our designated copyright agent to receive DMCA Notices is:

Michelle R. Fang

Turo Inc.

111 Sutter Street

San Francisco, CA 94104

Tel: 415-965-4525

Email: copyright@turo.com

Turo's contact information

Turo's contact information is:

111 Sutter Street, San Francisco, CA 94104

Insurance license disclosures

Last revised: November 22, 2024

Turo Insurance Agency, LLC is licensed as a resident insurance producer for property and casualty and surplus lines in the following jurisdictions:

Turo Insurance Agency, LLC is licensed as a non-resident insurance producer for property and casualty and (where noted) surplus lines in the following jurisdictions:

Payment plan terms

Last revised: November 6, 2024

Turo may offer guests the opportunity to pay balances owed for incidentals and/or damage claims through a payment plan. If you elect to pay balances owed to Turo through a payment plans, these terms apply. In addition to these terms, the Turo terms of service (“TOS”) also apply.

Payment plans offered by Turo are not a loan or other financing. Turo is not collecting any fees or interest for your participation in a payment plan. You acknowledge owing Turo a balance by agreeing to a payment plan.

By agreeing to a payment plan in the Services (as defined in the TOS), you agree to make the payments outlined in the plan and confirmed with you in an email from Turo. The number of payments and payment amounts vary based on the balance you owe and the plan you selected in the Services.

Any payment not received by Turo on its due date may result in the balance owed to Turo being assigned to a private collection firm. The payment plan terms will remain in effect until you no longer owe any balance to Turo under the payment plan or Turo sends your balance to collections due to non-payment.

These terms do not constitute a waiver by Turo to any rights and remedies under law. Any dispute under the payment plan terms is subject to the dispute resolution provisions of the TOS.

Privacy policy supplements

California residents | Personal information we collect, use, and share

The chart below summarizes the Personal Information we collected, used, and shared during the 12 months before the “last revised” date of Turo’s Privacy Policy. The Policy section "Personal information we collect " describes the sources through which we collect your Personal Information. The Policy section "How we use your personal information" describes the business and commercial purposes for which we collect, use, and share this information.

Personal information

Glossary

Commercial information means records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Financial information means bank account number, debit or credit card numbers, insurance policy number, and other financial information

Geolocation data means, for example, your precise location derived from GPS coordinates or telemetry data

Identifiers means real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers

Inferences means the derivation of information, data, assumptions, or conclusions from any of the above categories of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes

Internet or network information means browsing history, search history, and information regarding a person's interaction with an Internet website, application, or advertisement

Medical information means personal information about an individual's health or healthcare, including health insurance information

Online identifiers means an online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device

Physical description means an individual's physical characteristics or description

Professional or employment information is not defined in the CCPA but likely includes any information relating to a person's current, past or prospective employment or professional experience (e.g., job history, performance evaluations)

Protected classification characteristics means 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)