I. Introduction

TowMe Privacy Notice Updated June 9, 2024

When you use the TowMe service, you trust (“TowMe”) with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices. This notice describes the personal data (“data”) we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights information about our privacy practices and provides summaries of the data we collect and how we use it.

II. Overview

This notice applies to users of TowMe’s apps, websites and other services globally. This notice specifically applies to:

1. Customers: those who request or receive towing and related services.

2. Service Providers: those who provide towing or related services to Customers.

3. Guest users: those without a TowMe account who receive services, including those

   ordered by other TowMe account owners and gift card recipients.

This notice also governs TowMe’s other collections of data in connection with its services. For example, we may collect contact information of owners or employees of Service Providers. All those subject to this notice are referred to as “users” in this notice.

Our privacy practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

Please contact us at [email protected] with any questions regarding our practices. III. Data collections and uses
A. The data we collect

TowMe collects data provided by users to TowMe, created during use of our services and from other sources. This data includes account information, background check information (drivers), identity verification documents and photos, demographic data, user content, travel information, location data, transaction information, usage data, device data, communications data and data from other sources.

Our other sources include users participating in our referral programs, TowMe account owners who request services for or on behalf of other users, users or others providing information in

connection with claims or disputes, TowMe business partners through which users create or access their TowMe account, such as payment providers, social media services, or apps or websites that use TowMe’s APIs or whose APIs TowMe uses, TowMe business partners in connection with debit or credit cards issued by a financial institution in partnership with TowMe to the extent disclosed in the terms and conditions for the card, service providers who help us verify users’ identity, background information, and eligibility to work, detect fraud, and screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements, insurance, vehicle or financial services providers for drivers and/or delivery persons, partner transportation companies (for drivers or delivery persons who use our services through an account associated with such a company), publicly available sources, marketing partners and service providers, including banks in connection with cash back programs and data resellers, and law enforcement officials, public health officials, and other government authorities.

We collect precise and/or approximate location information from users’ mobile devices to the extent that they enable us to do so via their device settings. TowMe collects such data from the time an order is requested until it is finished, any time the app is running in the foreground (app open and on-screen).

B. How we use data

TowMe uses data to enable reliable and convenient transportation, delivery and other products and services. More specifically, we collect this information to help us to provide our services, for safety, fraud protection and security, for customer support, for research and development, to enable communications between users, for marketing and advertising, for non-marketing communications, and for legal proceedings and requirements.

TowMe uses data to provide, personalize, maintain, and improve our services, and may use it to help maintain the safety, security, and integrity of our services and users. The fraud and unsafe driving prevention and detection activities may be considered profiling under applicable laws, and can result in deactivation of users (generally only after human review).

We may specifically use account, approximate location, device and usage data, preferred language, and trip and order history to provide ads and marketing communications that are personalized based on users’ observed or inferred location, interests and characteristics (which may include inferred gender). We also may display ads for third party products that are not available on TowMe’s apps. These ads may contain links to third party apps or websites. Users should refer to such third parties’ privacy notices for information on their collection and use of data when visiting such apps or websites. We also may provide ads that are personalized based on data about users’ current trip or delivery request, including time of request and services requested.

TowMe may use data to send surveys and other communications that are not for the purpose of marketing the services or products of TowMe or its partners. We use data to investigate or

address claims or disputes relating to use of TowMe’s services, to satisfy requirements under applicable laws, regulations, operating licenses or agreements, insurance policies, or pursuant to legal process or governmental request, including from law enforcement.

C. Cookies and third-party technologies

TowMe and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and ads. TowMe uses cookies and similar technologies for purposes such as authenticating users, remembering user preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, and analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services.

We may also allow others to provide audience measurement and analytics services for us, to serve ads on our behalf across the internet or for other companies’ products and services on our apps, and to track and report on the performance of those ads. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

Depending on your location, you may be presented with a “cookie banner” when you visit our websites that disclose our use of tracking technologies, and enables you to accept or reject non-essential tracking technologies. Please note that declining non-essential tracking technologies may limit the availability and functionality of our Services. Your browser may allow you to decline cookies. To do so, please follow the instructions provided by your browser (which are usually located within the “Help” or “Preferences” menu). Some third-party Tracking Technology providers enable you to reject their tracking technologies using an opt-out link. Where available, we have provided such opt-out links in the table above. If you are located in the United States, you can also opt-out from the “sale,” or “sharing” of your personal data for purposes of personalized advertising as described herein or by communicating your opt-out preferences via your web browser using Global Privacy Control (GPC).

You may choose how we use tracking technologies on your mobile device using the choices offered by your device’s operating system. For iOS users, TowMe may, with your permission, track your activities on other companies’ apps, websites or offline properties for purposes of targeted advertising or measurement. If you grant TowMe permission to “Allow Tracking,” via iOS, TowMe will be permitted to track your activities as described herein. To modify this setting for your iOS device, visit the Settings/Privacy/Tracking and use the toggles associated with TowMe’s apps. For Android mobile devices, you can control whether or how third parties can track your activities by modifying or deleting your Android device’s advertising identifier, specifically by visiting your device settings/Privacy/Ads and choosing to either ‘Reset advertising ID’ or ‘Delete advertising ID’.

You can choose whether TowMe may share your data with third parties (such as advertising partners), or collect data regarding your interactions with third party apps and websites, for purposes of personalized ads. For further information about cookies, including how to see what advertising cookies have been set on your device and how to manage and delete them, you can visit http://youradchoices.com/.

D. Data sharing and disclosure

Some of TowMe’s services and features require that we share data with other users, or at users’ request or with their consent. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

TowMe may share data with other users, at users’ request or with users’ consent, with TowMe subsidiaries and affiliates, with TowMe service providers and business partners, for legal reasons or in the event of a dispute, and with your consent. We may also share data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

E. Data retention and deletion

TowMe retains user data for as long as necessary for the purposes described above, which varies depending on data type, the category of user to whom the data relates, the purposes for which we collected the data, and whether the data must be retained after an account deletion request for the purposes described below.

Users may request deletion of their account. Following an account deletion request, we delete the user’s account and data, except as necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account (such as an outstanding credit or an unresolved claim or dispute).

IV. Choice and transparency
TowMe enables users to access and/or control data that TowMe collects, including through:

• privacy settings

• device permissions

• marketing and advertising choices

  TowMe also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts, or request that TowMe restrict its processing of user data.

Customers and order recipients can set or update their preferences regarding location data collection and sharing via their device settings or by contacting us at [email protected]

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Users should check the available settings on their devices, or check with their provider.

Laws in California and other states give users in the state the right to opt out of the “sale” or “sharing” of their personal information. “Sale” refers to the disclosure of personal information to a third party in exchange for money or other value. “Share” refers to the disclosure of personal information to a third party for purposes of targeted advertising. TowMe discloses user personal information to third parties to enable personalized advertising on apps, websites or other properties owned by TowMe or other companies. Such disclosures may be considered “sales” or “sharing” of personal information under the laws described above. Users in the United States may opt-out of these below. If you opt out, TowMe will not disclose your personal information to third parties for purposes of targeted advertising. Please contact us at [email protected] with any such request.

In addition, Users may request the following from TowMe:

Data access: You may request the following information relating to TowMe’s collection, use and disclosure of your personal data during the past 12 months:

• The categories and specific pieces of personal data we have collected;

• The sources from which we collected the data;

• The business or commercial purpose(s) for which we use it; and

• The categories of third parties with whom we disclosed, sold or shared your data (as

  applicable).

• You may also request a copy of your personal information.

  Correction: You may request that TowMe correct inaccurate information about you. Deletion: You may request that TowMe delete your account and personal data.

  Opt-out of sales and sharing: You may opt out of the “sale” or “sharing” of your personal information. “Sale” refers to the disclosure of personal information to a third party in exchange for money or other value. “Share” refers to the disclosure of personal information to a third party for purposes of targeted advertising.

  Opt-out of profiling: You may request that TowMe opt you out of the processing of your data for purposes of certain kinds of “profiling” that could have a significant impact on consumers. Profiling generally refers to automated processing of personal data to analyze or predict an individual’s behaviors or characteristics.

You also have the right not to be discriminated against for exercising these rights. TowMe will respond to the above requests as required or permitted by law. Please contact us at [email protected] with any request to exercise such rights.

V. Updates to this Privacy Notice

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the TowMe apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.