Last revised: December 13, 2019
We collect three categories of personal information - personal information you give us; personal information automatically collected from your use of the Services; and personal information from third party sources.
We use, store and process your personal information to provide and improve our Services and ensure a secure, safe and trusted experience. For example, we may use your information:
To improve our Services: We may use the personal information you provide to analyze and improve the Service and to develop new products and services, including by studying our user demographics of the Service.
To send you marketing and promotional communications: We may send you Turo-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the ‘Opt out of marketing’ section below.
To comply with law: We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.
To create anonymous data: We may create aggregated, de-identified or other anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
With your consent: In some cases, we may specifically ask for your consent to process your personal information.
You may direct us to share your information or consent to it as described at the time of sharing.
Your public listing page on our Platform will always include some basic information, such as your user ID/name associated with your account, your public profile photo, and for hosts, the city where your car is located, your listing description, your calendar availability, transaction related information to allow our community to evaluate your reliability and responsiveness, and reviews/feedback. Your public listing page may also include aggregate demand information (such as number of page views over a period of time) and information about your cancellations. Our Services may also display the approximate geographic pick-up location of your vehicle.
Our Services allow your public profile and public listing pages to be included in search engines, in which case your public profile and public listing pages may be indexed by search engines and may be published as search results.
Turo enables car owners to offer and share their vehicles with other individuals. If you agree to a booking through the Services, we may provide your information to the other party in that transaction as reasonably necessary to facilitate the transaction. For example, Turo may provide your mobile phone number and/or driver’s license information to facilitate communication or your photograph to facilitate identification. We will provide the address of the vehicle and/or the proposed delivery location. We may also share user-uploaded “Trip Photos” with captions with the other party involved in the reservation if that feature is selected. Turo users engaged in a booking with you may send you text messages (such as to confirm pickup or delivery location). Standard telephone minute and text and data charges may apply.
We may share information with vendors and service providers who are engaged by, or working with, us in connection with the processing of payments, operation of our Services and customer support functions and who need access to such information to carry out their work for us (including, for example, web hosting, analytics, email delivery, marketing, insurance companies, claims administrators, and customer support services). In some cases, the service provider may be directly collecting the information from you on our behalf. For hosts who choose to use our photography program, your contact information will be shared with the photographer assigned to shoot your vehicle. These providers may use your personal information only as directed or authorized by us.
If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
As noted above, we may disclose your personal information to courts, law enforcement, governmental or tax authorities, or third parties. We will make such disclosure to the extent we are required or permitted to do so by applicable law or we consider such disclosure is reasonably necessary to comply with our legal obligations or legal process, to respond to claims asserted against us and for safety purposes described above. We may also disclose your information in response to valid legal requests relating to criminal investigations or alleged or suspected illegal activity or any other activity that may expose Turo, you, or any other user to legal liability or to protect the rights, property, or personal safety of Turo, our employees, our users, or members of the public.
You can control the methods by which we may contact you about your account, your booking and listing activities, promotions, and announcements in the Notifications section within your Turo account.
You can review, correct, update, and edit certain information that has been previously provided to us by you at any time by logging in to your account and reviewing your account settings and profile. You can also access or request a correction of your information by contacting us at support.turo.com. For your protection, we may need to verify your identity before implementing your request.
Please note that we may be unable to delete information needed to comply with applicable laws, detect or prevent fraud, collect any fees owed, resolve disputes, assist with or process claims, troubleshoot problems, assist with any investigation, comply with audits and investigation, to enforce our Terms of Service and Policies and take other actions reasonably necessary, permitted, or required by applicable law. There may also be residual information that will remain within our databases and other records, which will not be removed.
If we are legally required to offer this option, you may request a copy of your personal information provided to us by visiting your account page on the web. We will send you a copy of the personal information to the email address provided in your account as soon as reasonably practicable. We may request proof of identification or re-authentication to verify your access request.
You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text message from us by replying STOP to our marketing message or as described in the message.
Users of our mobile application can disable the application’s access to the device’s location within the device’s settings.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Users in the EEA may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link). Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that do not participate in the opt out mechanisms that we linked above. In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.
Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or we later delete it at your request), we may not be able to provide you with our Services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.
If you choose to connect to the Service via a third party platform or social media network, you may have the ability to limit the information that we may obtain from the third party at the time you login to the Service using the third party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third party’s platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third party platform or social media network, that choice will not apply to information that we have already received from that third party.
We employ a number of technical, physical, and organizational measures designed to protect information against unauthorized access, destruction, or alteration while it is under our control. However, no method of transmission over the Internet, and no method of storing information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your information that we store.
This section describes some additional important privacy information related to your use of our Services.
The Services are controlled and operated by us from the United States. Your information may be used, stored and processed in any country where we have facilities or in which we engage service providers. These locations may be outside of your state, province, or country of residence, and may have different and/or less protective data protection rules than those of your state, province, or country. As a result, this information may be subject to access requests from governments, courts, regulatory agencies, security authorities or law enforcement in those jurisdictions according to the laws in those jurisdictions. You can learn more about how we protect your data from government requests here.
We ask that you not send us, and you not disclose, any sensitive information unless specifically requested (e.g., Social Security numbers, social insurance numbers, passports, information related to racial or ethnic origin, or health), on or through the Services or otherwise to us.
Our websites are general audience websites, and our Services are not intended for anyone under the age of 18. We do not knowingly collect information from users under the age of 18. If a child under the age of 18 has already provided us with information, his or her parent or guardian may contact us for the purpose of deleting this information or closing an account.
We cannot guarantee the privacy or security of your information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner and any third parties you deal with or whose sites you visit before entering into a transaction and choosing to share your information.
If you sign in to our Platform using an email address and password, your session will expire after 30 days unless you log out but if you sign in through a social network login such as Facebook or Google, you will stay logged on/signed in until you explicitly sign out of your account or clear your Cookies. If you are using a public or shared computer you should sign out and/or clear your Cookies when you are done using our Platform in order to protect your account and your information. If you do not sign out, you or any other user of the computer/browser you signed in on will be able to view and access your account, including your social media accounts.
Turo welcomes your questions and comments about privacy, and what we do. Please feel free to contact us at our address in the United States.
You may also email us.
This information applies only to California residents and describes how we collect, use and share their Personal Information in operating our business, and their rights with respect to that Personal Information.
Only as used in this section only and at the linked information below, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (CCPA) but does not include information excluded from the scope of the CCPA.
As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Information. You can request the following information about how we have collected and used your Personal Information:
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as:
However, we may charge you a different price or vary the quality of the service you receive if that difference is reasonably related to the value to us of the Personal Information we are unable to use due to the exercise of your rights. We may also offer you financial incentives that result in different prices or service quality.
We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
The information in this section applies only to individuals in the European Union, the European Economic Area or the United Kingdom (collectively, “Europe”).
Retention. We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; or for fraud prevention). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
European data protection laws give you certain rights regarding your personal information. If you are located in Europe you may ask us to take the following actions in relation to your personal information that we hold:
We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us at email@example.com or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
If we transfer your personal information from Europe to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so, for example, by implementing the standard contractual clauses adopted by the European Commission. Please contact us at firstname.lastname@example.org for further information about any such transfers or the specific safeguards applied.
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