Carsan Inc. and its subsidiaries (collectively, "Carsan", "we", or "us") care about privacy and want you to be familiar with how we collect, use, process, and disclose your personal information. This Privacy Policy describes our privacy practices in connection with our websites and applications that link to this Privacy Policy (collectively, the "Services") and our offline interactions with you in settings where we post this Privacy Policy.

Personal information we collect
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.

Personal information you give us

Account data.
When you register for an account with us, we require certain personal information to open your account, such as your name, email address, and password.

Profile data.
We may also ask you to provide additional profile information, such as street addresses, phone numbers, driver's license number, date of issuance and issuing country and/or state, profile photos, employer, city, school, biography, and date of birth. Certain parts of your profile (like your profile photos, employer, city, school, and biography) are part of your public profile page and will be publicly visible to others.

Vehicle data.
We collect information you provide in relation to a vehicle, such as vehicle listing details, vehicle identification number (VIN), availability dates, reviews, and uploaded trip photos.

Payment data.
We collect your digital payment details, bank account or payment card numbers, and transaction information in connection with a potential or actual transaction, which may be processed and stored by one or more third-party payment service providers or digital payments companies ( Currently Clover Network. LLC).
Read more about Clover Privacy Policy

Identity verification data.
In some instances, we may collect identity verification information such as a photograph or scanned copy of a driver's license, passport, national ID card, or payment card, last four digits of your Social Security number, social insurance number, social media account information, driver's/motor vehicle record, insurance information, or other forms of identification information. Where we request that you withhold certain information (such as obscuring or redacting aspects of identification information), please do so. To learn more, visit our Help Center article about Getting Approved to Drive.

Communications.
When you communicate with Carsan, including via phone, email, or chat, or use the Services to communicate with other users, we collect information about your communication and any information you choose to provide.


Personal information we automatically collect.

Carsan uses, stores, and processes your personal information to provide and improve its services and for security and safety purposes. This includes using your information to:
Provide and operate the services
Offer customer support
Send you service, support, and administrative messages, reminders, technical notices, updates, security alerts, and information you request
Facilitate your login to Carsan via third-party identity and access management providers
Process transactions and send notices about them
Personalize your user experience
Allow communication with other Carsan users during the booking process
Facilitate referral invitations
Send requests for reviews and for fraud detection and prevention
Administer referral programs, rewards, surveys, contests, and other promotional activities

Carsan also automatically collects the following information:

Usage data: interactions with the services such as pages viewed, searches, bookings, time spent on pages, navigation paths, etc.

Location data: approximate location based on IP address, or precise location with opt-in for location sharing

Device data: operating system, device type and model, browser type, IP address, unique device IDs, etc.

Trip data: trip details such as date, time, and amounts charged

In-vehicle device data: GPS location, car battery voltage, fuel level, odometer reading, door state, engine state, VIN, etc.

Cookies and similar technology: small data files placed on your device to track your use of the services.

For more information on the use of cookies, please see Carsan's policy on Cookies, Web Beacons, and Similar Technologies. Currently, Carsan does not respond to browser 'Do-Not-Track' signals.

How we use your personal information

We use, store, and process your personal information to provide and improve the Services and for security and safety purposes. For example, we may use your information:

To provide the Services, including to:
- Provide and operate the Services
- Provide customer support
- Send you service, support, and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you through phone, text (SMS) or email
- Facilitate your login to the Services via third-party identity providers such as Facebook, Google, and AppleProcess transactions and send transaction notices
- Personalize your user experience
- Enable communication with other Carsan users during the booking process
- Facilitate referral invitations
- Send requests for reviews, fraud detection, and any authorized purpose at time of collection. Administer referral programs, rewards, surveys, contests, and promotional activities in which you participate.

For research and development:
Carsan may use your personal information to analyze and improve the Services and to develop new products and services, including by studying our user demographics of the Services. Carsan may also create aggregated, de-identified, or other anonymous data from your personal information. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. Carsan may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

For marketing and advertising:
Carsan and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:

Direct marketing. Carsan may send you Carsan-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 Opting out of marketing communications section below.

Interest-based advertising. Carsan may contract with third party advertising and social media companies to display ads on the Services and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data, online activity data, and/or geolocation data described above) over time across our Services and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. These ads are known as "interest-based advertisements". You can learn more about your choices for limiting interest-based advertising, in the Interest-based advertising choices section below.


For security and safety, including to:
- Verify your identity or authenticate information that you provide, including during account creation and password reset processes
- Resolve disputes, collect fees, and troubleshoot problems
- Detect, prevent, and/or remediate fraud, abuse, security incidents, or other potentially harmful, prohibited, or illegal activities
-Determine your likelihood of getting into an accident or of making an insurance claim, such as by checking your auto insurance score
- Using information from your mobile or in-vehicle device to identify unsafe driving behavior, including speeding or harsh braking and acceleration, and to raise awareness regarding such behaviors
- Detect, prevent, or remediate violations of and enforce our Terms of Service and Policies.
- Manage and protect our information technology infrastructure
- Conduct investigations and risk assessments
- Conduct checks against databases and information sources (such as but not limited to public government databases)
- Perform creditworthiness and solvency checks

To comply with law:
Carsan uses 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.

With your consent:
In some cases, Carsan may specifically ask for your consent to process your personal information.
Carsan may also use your personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.


How we disclose your personal information:

With your consent: Carsan may share your information with your direction or with your consent. Public information: Your public listing page on the Services will show your user ID, name, public profile photo, location, listing description, calendar availability, transaction information, reviews, and feedback. The Services may also show the approximate pick-up location of your vehicle. This information may be indexed by search engines and published as search results. Sharing between Owners and Drivers: Carsan enables car owners to share their vehicles with others. If you agree to a booking, Carsan may provide necessary information to the other party in that transaction such as mobile phone number, driver's license information, photograph, and vehicle address. The other party may send you text messages and standard phone minute, text and data charges may applyService providers: Carsan may share information with vendors and service providers to support the Services and business operations, such as web hosting, analytics, payment processing, email delivery, marketing, insurance, claims administration, and customer support services.Third-party platforms and social media networks: If you connect the Services to a third-party platform or social media network, Carsan may disclose personal information to facilitate the connection or as authorized by you.Professional advisors: Carsan may disclose your personal information to professional advisors such as lawyers, bankers, auditors, and insurers if necessary. Business transfers: Carsan may sell, transfer, or share some or all of its business or assets, including personal information, in connection with a business transaction or in the event of bankruptcy or dissolution. Legal requests and protection: Carsan may disclose personal information to courts, law enforcement, or third parties if required or permitted by law or to comply with legal obligations, respond to claims, or protect rights, property, and safety of Carsan, users, or others. Other disclosures: Carsan may also disclose personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.

Your preferences and choices
Carsan's communication preferences can be controlled in the Notifications section of your Carsan account. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, but continue to receive service-related and non-marketing emails. You can opt out of receiving marketing text messages by replying STOP to the message.

You can review, correct, and edit your personal information at any time by logging in to your Carsan account and reviewing your account settings and profile. You can also request a correction of your information by contacting Carsan support. To protect your identity, Carsan may verify your identity before implementing your request.

To close your Carsan account and delete your personal information, send an email to support@carsana.com or contact Carsan support. Carsan may be unable to delete information needed to comply with laws, prevent fraud, or enforce its terms of service and policies. Residual information may remain within Carsan's databases and records.

You can request a copy of your personal information by logging in to your Carsan account. Carsan may request proof of identification or re-authentication to verify your request.

Users of the Carsan mobile app can disable the app's access to the device's location in the device's settings.

To limit the use of your personal information for interest-based advertising, you can block cookies in your browser or block advertising ID use in your mobile settings. You can also use privacy plug-ins or browsers like Brave, or opt-out tools from the European Interactive Digital Advertising Alliance, Digital Advertising Alliance, or Network Advertising Initiative.

Where the law requires collection of your personal information or where it is necessary to provide the Services, if you do not provide it, Carsan may not be able to provide the Services. If you connect your Carsan account to a third-party platform or social media network, you may control your settings through that platform. However, if you withdraw Carsan's access to information from the third party, that choice will not apply to information that Carsan has already received.

Security
Carsan employs various technical, physical, and organizational measures to protect your personal information from unauthorized access, destruction, or alteration while it is under our control. However, 100% security cannot be guaranteed in transmitting or storing information.

Other important information

Cross Border Transfer
Carsan operates and controls its services from the United States. Your personal information may be used, stored, and processed in any country where we have facilities or use service providers, including countries outside of your state, province, or country of residence that may have different data protection rules. As a result, your information may be subject to access requests from governments, courts, regulatory agencies, security authorities, or law enforcement in those jurisdictions based on the laws in those places.

Sensitive Information
Please refrain from sending or disclosing sensitive information (e.g., Social Security numbers, passports, information about racial or ethnic origin, or health) through the Services or to us unless specifically requested.

Children
The Services are not intended for anyone under the age of 18, and Carsan does not knowingly collect personal information from users under the age of 18. If a child under the age of 18 has provided us with personal information, their parent or guardian can contact us to request deletion.

Third-Party Privacy Practices
This Privacy Policy only addresses Carsan's use and disclosure of collected information. Carsan is not responsible for the privacy practices of third parties, including those operating sites or services linked to our Services. Linking to another site or service does not imply endorsement by Carsan or its affiliates. If you share your information with others or visit a third-party website, their privacy policies and practices will apply.

Translations
In the case of discrepancies between translated versions of this Privacy Policy and the English version, the English version prevails.


Changes to Privacy Policy

Carsan may make changes to this Privacy Policy. The "Last revised" date at the top of the page indicates when it was last updated. Changes become effective when posted on the Services or as indicated. Your use of the Services after changes are made means you accept the revised Privacy Policy. If you do not agree with the changes, you may contact us to close your account.


Contact
Carsan welcomes your questions and comments about privacy. Feel free to contact us.