Privacy Policy

Personal information we collect

Information you provide to us

Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, email address, phone number, city, and state.
• Account data, such as the email address and password an operator uses to establish an account on the Service, along with company name, storefront details, notification email and phone number, and other workspace settings.
• Rental request data provided by renters, such as date of birth, driver’s license status and issuing region, insurance status and carrier, deposit readiness, stated payment method, rental purpose, requested vehicle, rental dates, pickup or delivery preference, delivery location, and free-form notes.
• Identity verification data. To verify renter identity, our identity verification provider collects a government-issued identification document (such as a driver’s license, state ID, or passport), a selfie, and liveness and face-match results. This information is collected and processed by our verification provider on our behalf. We receive the verification result and related verification details, and we may retain a record of the verified identity details so that the same verified person can be recognized in future requests.
• Communications data based on our exchanges with you, including when you contact us through the Service, email, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources

We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Public sources, such as public records and other publicly available sources.
• Data providers, such as information services and data licensors.
• Service providers that provide services on our behalf or help us operate the Service or our business.
• Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction, such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.

Automatic data collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type, IP address, unique identifiers, language settings, and general location information such as city, state, or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, access times and duration of access, and whether you have opened our emails or selected links within them.
• Communication interaction data, such as your interactions with our email or other communications (for example, whether you open emails), which we may measure through pixel tags embedded in our emails.

Tracking and other technologies

Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. The Service uses strictly necessary cookies required to operate it — for example, cookies that keep operators signed in to their dashboard and cookies that support the identity verification process. We do not currently use cookies for advertising purposes. You can control cookies through your browser settings, but disabling strictly necessary cookies may prevent parts of the Service from working.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations

• provide the Service, including hosting operator storefronts, receiving rental requests, and presenting requests to operators in their inbox;
• verify renter identity through our identity verification provider, including government ID verification, liveness checks, and face matching;
• generate request assessments that score and summarize a rental request against an operator’s stated requirements, to assist the operator’s review — assessments support the operator’s judgment and do not approve or decline rentals;
• recognize returning renters across requests;
• conduct market research and analysis on behalf of operators using publicly available information;
• establish and maintain your user profile on the Service;
• communicate with you about the Service, including by sending service-related announcements, updates, security alerts, and support and administrative messages;
• send operators notifications about new rental requests by email and, where configured, by text message; and
• provide support for the Service, and respond to your requests, questions, and feedback.

Service personalization

• understand your needs and interests;
• personalize your experience with the Service and our service-related communications; and
• remember your selections and preferences as you navigate webpages.

Service improvement and analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Direct marketing

We may send operators and prospective customers direct marketing communications about the Service. You may opt out of our marketing communications as described in the Opt-out of communications section below. We do not use personal information for third-party interest-based advertising.

Compliance and protection

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations, or requests from government authorities;
• protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including identity fraud and duplicate or misrepresented rental requests.

Data sharing in the context of corporate events

We may share certain personal information in the context of actual or prospective corporate events — for more information, see How we share your personal information below.

Aggregated, de-identified, and anonymized data

We may create aggregated, de-identified, and/or anonymized data from your personal information and other individuals whose personal information we collect, and we will not attempt to reidentify any such data. We may use and share this data for our lawful business purposes, including analyzing and improving the Service and promoting our business.

Further uses

In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention purposes. To determine the appropriate retention period, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How we share your personal information

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection):

• Rental operators. When a renter submits a request through an operator’s storefront, we share the request information and the identity verification result with that operator so the operator can evaluate and act on the request. The operator’s own policies and practices govern their use of that information.
• Affiliates. Our corporate parent, subsidiaries, and affiliates, if any.
• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business, such as cloud hosting and database infrastructure, identity verification, communications delivery, address services, data providers, and artificial intelligence service providers.
• Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
• Business transferees. We may disclose personal information in the context of actual or prospective business transactions (for example, investments in Bouncer, financing of Bouncer, or the sale, transfer, or merger of all or part of our business, assets, or shares), including an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in certain U.S. states can find additional information about their rights in the State privacy rights notice below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and other technologies. For information about cookies employed by the Service and how to control them, see the Tracking and other technologies section above. Most browsers let you remove or reject cookies through your browser settings.

Blocking images and clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory — for example, the information needed to submit a rental request or complete identity verification — we may not be able to provide those services.

Delete your content or close your account. If you wish to request deletion of certain content or to close your account, please contact us at legal@withbouncer.xyz.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security

We employ technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by anyone under 18 years of age, and rental requests require renters to be at least 18 years old. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you, please contact us:

• Email: legal@withbouncer.xyz

State privacy rights notice

Except as otherwise provided, this section applies to residents of U.S. states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”).

This section describes how we collect, use, and share Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.

For purposes of this section, the term “Personal Information” has the meaning given to “personal data,” “personal information,” or other similar terms, and “Sensitive Personal Information” has the meaning given to “sensitive personal information,” “sensitive data,” or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws.

Your privacy rights. The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information:

• The categories of Personal Information that we have collected.
• The categories of sources from which we collected Personal Information.
• The business or commercial purpose for collecting and/or selling Personal Information.
• The categories of third parties with which we share Personal Information.
• The categories of Personal Information that we sold or disclosed for a business purpose.
• The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.

Access. You can request a copy of the Personal Information that we have collected about you.

Appeal. You can appeal our denial of any request validly submitted.

Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.

Deletion. You can ask us to delete the Personal Information that we have collected from you.

Opt-out.

• Opt-out of certain processing for targeted advertising purposes. We do not process your personal information for targeted advertising purposes.
• Opt-out of or appeal profiling/automated decision making. Request assessments generate a score and summary to help an operator review a rental request. They do not by themselves approve or decline a rental; the operator makes all rental decisions. We do not use your Personal Information to engage in profiling or automated decision-making that produces legal or similarly significant effects without human review.
• Opt-out of other sales of personal data. We do not sell your Personal Information within the meaning of State Privacy Laws.

Consumers under 16. We do not have actual knowledge that we collect, sell, or share the personal information of consumers under 16 years of age.

Sensitive Personal Information. We process certain categories of Sensitive Personal Information as described in this Privacy Policy — specifically government-issued identification data and identity verification results collected through our identity verification provider. We use this information only to provide the Service (verifying renter identity and preventing fraud) and not to infer characteristics about consumers.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Exercising your state privacy rights. You may submit requests to exercise any of the state privacy rights listed above by emailing legal@withbouncer.xyz. Please note that some Personal Information — such as renter request information shared with an operator — may be held by the operator, and you may need to contact the operator directly to exercise rights in information they control.

Verification of identity; authorized agents. We may need to verify your identity in order to process your information, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Information practices. The following describes our practices currently and during the past 12 months:

• Sources and purposes. We collect all categories of personal information from the sources and use them for the business/commercial purposes described above in this Privacy Policy.
• Retention. The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.
• Deidentification. We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.

Personal information that we collect, use, and disclose. The chart below summarizes the Personal Information we collect, the purposes for which we collect it, and the third parties to whom we may disclose it, by reference to both the categories defined in the Personal information we collect section above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). It describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form web forms, may contain other categories of personal information not described below.

Additional information for California residents

Shine the Light law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family, or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send requests for this information to legal@withbouncer.xyz. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Additional information for Nevada residents

Nevada residents have the right to opt out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email legal@withbouncer.xyz.

Additional information for Texas residents

We do not sell personal data as defined by the Texas Data Privacy and Security Act, and we do not sell sensitive personal data.

Contact us

If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section above.