Privacy Policy

This Privacy Policy discloses the privacy practices for Neighbors Trailer, LLC (“Company”), www.NeighborsTrailer.com website, the Neighbors Trailer mobile application and various related services (together referred to as the "Site") and any website or app that may link to this Privacy Policy (the “Services”). Neighbors Trailer, LLC, the provider of the Services (referred to as "us " or "we"), is committed to protecting your privacy online. Please read the information below to learn the following regarding your use of our Services. You acknowledge that this Privacy Policy is part of our Terms of Use, and by accessing or using our Services, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or use our Site or Services.

I. Types of Collected Information 

We collect four categories of personal information - personal information you give us; information automatically collected from your use of the Services; personal information from third-party sources; information from cookies.

Personal Information You Give Us

• Account Data. When you register for an account with us, we may require certain personal information to open your account, such as your name, email address, and password. If you do not provide such required information, you will not be able to open an account with us.
• Profile Data. We may also ask you to provide additional profile information to use certain features of the Services which may include your street addresses, phone numbers, driver’s license number, an image of your driver’s license, date of issuance and issuing country and/or state, profile photos, date of birth or other personally identifying information. Certain parts of your profile (like your profile photos and other biography data) are part of your public profile page and will be publicly visible to others.
• Trailer Data. We collect information you provide in relation to a vehicle such as trailer listing details, vehicle identification number (VIN), availability dates, reviews, and uploaded trip photos.
• Identity Verification Data. We may collect identity verification information such as a photograph or scanned copy of a driver’s license, a selfie, payment card, driver’s vehicle record, insurance information, or other forms of identification information. We may also use a third party to verify a driver’s record, and any information submitted to that third party is subject to their privacy policy. In addition, we may use a third party to verify that your selfie and driver’s license match. For this specific service, any information you submit to that third party is covered by their privacy policy.
• Payment Data. We collect your digital payment details, bank account or payment card numbers, and transaction information in connection with an actual or potential transaction with us, which may be processed and stored by one or more third party payment service providers or digital payments companies. Storage of such information shall be subject to those third party payment service providers’ privacy policies.
• Communications. When you communicate with us, including via phone, email, or any other method, or if you use the Services to communicate with other users, we collect information about your communication along with any information you choose to provide.
• User Research. We may collect information you provide when you choose to participate in user research initiatives and/or community surveys. This may include demographic information if you choose to share it with us.

Information We Automatically Collect

• Usage Data. We may collect information about your use of the Site and the Services, such as bookings you have made, your login history, your searches, the pages or other content you view, how long you spent on a page or screen, sites from which you link or browse to in the Services, navigation paths between pages or screens, information about your activity on a page or screen, access time, duration of access, and other actions on the Services.
• Location Data. When you use certain features of the Site or Services, we may collect information about your approximate location. When you activate our location sharing function on our app, it will share the precise location of that device with us. Most mobile devices allow you to control that functionality or disable the use of location services through your settings menu.
• Booking Data. We collect transactional information related to the bookings you make through the Services, including the date and time of your booking, amounts charged, and other related booking details.
• Device Data. We collect information about your computer or mobile device, such as its operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique device identifiers, or general location information such as city, state, or geographic area if available from your device.
• Cookies and similar technology. When you access the Services, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, clear gifs, pixel tags,e-tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively “Cookies”). For more detailed information on our use of these technologies, please see our policy on Cookies, Web Beacons, and Similar Technologies. At this time, we do not respond to browser ‘Do-Not-Track’ signals.

Personal Information We Collect From Third Parties

• Third-party Registration Services. If you choose to login to our Site or Services through a third-party website or service (e.g., Facebook, Apple, or Google), the third-party service may send us information about you such as your registration and profile information from that service. The information we may receive varies by service and is controlled by the relevant service. By associating an account managed by a third party with your Neighbors Trailer account and authorizing us to have access to this information, you agree that we may collect, store, and use this information in accordance with this Privacy Policy. We are not responsible for how those third parties use and share your information. Please refer to the privacy policies of the respective third-party website or service to understand how they use and share your personal information.
• Driver’s License Verification. We may use third party identity verification services to verify your driver’s license, confirm your identity and to protect against fraud and abuse. When you create an account, you will be asked to submit a valid driver’s license, along with an image of yourself (a selfie) so that we can be sure you are the person on your driver’s license. Our third-party provider may use a combination of machine learning tools and optical scans to authenticate your driver’s license, and may use facial recognition technology to produce a unique biometric identifier based on your facial geometry that can be used to compare your selfie to the image on the driver’s license you provided to determine the likelihood that the images are a “match.”  For our third party’s privacy policy, please click here.
  
  Neighbors Trailer does not receive the biometric identifier generated from the images. It is generated and held by our third-party provider until we inform them that the biometric identifier is no longer needed for the purposes described in this paragraph, which will occur no later than three (3) years after your last interaction with us. For identity verification and security purposes, Neighbors Trailer will have access only to the selfie image and will receive only the results of the identity verification process.  Neighbors Trailer does not possess, use, disclose or retain your biometric information for any other commercial purpose. Our third-party provider processes this information on our behalf strictly in accordance with our contractual agreements for identity verification services.
• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data, fraud detection information, or data from credit bureaus and other third-party data providers. We may combine the information about you that we receive from third-party sources with other information we have about you.

Cookies

• Usage of Cookies and Similar Tracking Tools. When you access the Services, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, clear gifs, pixel tags, e-tags, “flash cookies,” or other local storage provided by your browser or associated applications (collectively “Cookies”). Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones and other devices. Other technologies, including data that we may store on your web browser or device, identifiers associated with your device and other software, are used for similar purposes. In this policy we refer to all of these technologies as “cookies.”
• We use cookies if you have a user account. Cookies enable us to offer the Services to you and to understand the information that we receive about you, including information about your use of other websites and apps, whether or not you are registered or logged in.
• Why We Use Cookies. We use cookies for the following reasons:
  • Authentication – cookies help us verify your account and determine when you are logged in so that it makes it easier to access our Services.
  • Security – we use cookies to help us keep your account, data and Services safe and secure. We may also use cookies to combat activity tat violates our policies or otherwise degrades our ability to provide the Services.
  • Advertising – We may use cookies to help us show ads and to make recommendations of other businesses or organizations for which you may be interested in their products, services or causes they promote. We also use cookies to track and measure the efficacy of ad campaigns.
  • Features – We use cookies to enable the functionality for the provision of the Services.
  • Experience – We use cookies to provide you with the best experience possible.
  • Analytics and Research – We use cookies to help us understand how you are using the Services so we can improve them.
• When you use our Site or Services, we may store cookies on your device in order to facilitate and customize your use of our Site. A cookie is a small data text file, which a website stores on your computer's hard drive (if your web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the country where you are located, and your first name to welcome you back to our Site. The cookies make your use of the Site easier, make the Site run more smoothly and help us to maintain a secure Site. You are always free to decline our cookies if your browser permits, but some parts of our Site may not work properly in that case. We will collect and use non-personally identifiable information about you, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server. We shall not be liable for the placement of third party cookies or utilization of other tracking technologies. Through your use of the Site, you agree to release us from any liability regarding third party cookies. Data usage fees may apply, and you shall be the solely responsible for such fees. 

II. Use Your Personal Information

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

• To Provide the Services, including, but not limited to:
  • Operating the Site and Services
  • Providing customer support
  • Communicating with you about the Site, Services, updates, alerts, and any information requested by you
  • Requesting fraud detection or prevention
  • Facilitate logging in if you use a third party to do so, such as Facebook.
  • Personalize your experience
  • To enable you to communicate with the renter or the owner of the trailer
• For Research and Development. We may use your personal information to analyze and improve the Site and Services and to develop new products and services, including by studying our user demographics of the Services. We may also create aggregated, deidentified, 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. We 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. We and our third party partners may collect and use your information for marketing and advertising purposes, including:
  • Direct marketing
  • Interest-based advertising with third party partners
  • Security and safety, including but not limited to, verifying your identity, authenticating the information you provided, resolving disputes, collecting fees, detecting and preventing fraud, conduct checks against databases and third party sources (including government public databases)
• To Comply with Law. We use your personal information as we believe necessary or appropriate, in our sole discretion, to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.
• With Your Consent. We may, in some cases, ask for your consent to use your information. We may also use your information as described in this Privacy Policy. By using our Site and Services, you have agreed to the terms hereunder.

How We Disclose Your Information

• With Your Consent. By creating a profile, using our Site or Services, posting a listing, and responding to a listing, you consent you consent to our use of your information to facilitate the Services.
• Profiles, Listings, Public Information. Your listing on the Site or Services will always include some basic information about you, such as your user ID or name associated with your account, your public profile photo, the city where your trailer is located, your listing description, your calendar availability, transaction related information to allow our community to evaluate your reliability and responsiveness, and reviews or feedback about you. Your listing page may also include aggregate demand information (such as number of page views over a period of time) and information about your cancellations. The Site and Services may also display the approximate geographic pick-up location of your vehicle.
  
  By using the Site and Services, you agree to 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.
• Sharing Between Renters and Owners. We enable trailer owners to offer and share their trailers 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, we may provide your mobile phone number to facilitate communication, your driver's license information to confirm license validity and for identity verification, or your photograph to facilitate identification. We will also share the address of the trailer and, if applicable, the proposed delivery location with the other party. If you decide to text with the other party to any transaction to which you are a party, standard text message rates may apply.
• Service Providers. We may share information with vendors and service providers who support the operation of the Site, Services and business and who need access to such information to carry out their work for us (including, for example, web hosting, payment processing, marketing, insurance, claims administration, trailer recovery, etc.). In some cases, the service provider may directly collect the information from you on our behalf. Any of your information provided to these service providers shall only be used as instructed by us and governed by our agreement with them. Any information you provide these third party services providers will be governed by your agreement with them.
• Third Party Platforms Including Social Media. If you have enabled features or functionality that connect the Services to a third party platform or social media network (such as by logging in to the Services using your account with the third party, providing your API key or similar access token for the Services to a third party, or otherwise linking your Services account to a third party’s services), we may disclose to the third-party platform or social media network the personal information necessary to facilitate the connection or that you authorized us to share. We do not control the third party’s use of your personal information.
• Business Advisors. We may disclose your personal information to our business advisors, such as lawyers, bankers, auditors, and insurers, where such disclosure necessary in the course of the professional services that they render to us.
• Business Transfers. 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 merger, consolidation, corporate divestiture, acquisition, reorganization, or sale of assets, or in the event of bankruptcy or dissolution.
• Responding to Legal Requests, To Prevent Harm, To Protect Our Rights. 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 where we consider such disclosure is reasonably necessary to comply with our legal obligations or legal process, to respond to claims asserted against us, to protect our rights, and for our security and safety. 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 us, you, or any other user, or to protect the rights, property, or personal safety of us, our users, or others.
  
  We may also disclose your personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.

Your Preferences

• Preferences. You can control the methods by which we may contact you about your account, your booking and listing activities, promotions, and announcements by emailing us at service@neighborstrailer.com.
• Opting Out. 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 messages from us by replying STOP to our marketing message or as described in the message.
• Updating or Correcting Information. 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 service@neighborstrailer.com. For your protection, we may need to verify your identity before implementing your request.
• Closing Your Account. If you wish to close your account and request deletion of your personal information, please send an email to service@neighborstrailer.com. 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 audits and investigations, to enforce our Terms of Use or other 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.
• Access. You can request a copy of your personal information pursuant to any information access rights that you may have under applicable laws by emailing us at service@neighborstrailer.com. We may request proof of identification or re-authentication to verify your access request.
• Location Data. If you use our mobile application, you can disable the application’s access to the device’s location within the device’s settings.
• Interest-based Advertising Choices. Your choices for limiting use of your personal information for interest-based advertising include:
• Cookie preferences. This can be done through your web browser.
• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block sites from setting cookies for interest-based ads by using a browser with various privacy features and configuring them to block third party cookies/trackers.
• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies (but note we may work with companies that do not participate in these programs):
• European Interactive Digital Advertising Alliance (for users in the United Kingdom and Europe)
• Digital Advertising Alliance (for web users)
• Digital Advertising Alliance (for mobile app users)
• Network Advertising Initiative

• Some Services Not Available Without Information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Site and 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 the Site or Services.
• Third Party Platform and Social Media. If you choose to connect the Site or Services to a third party platform or social media network, such as by using the third party’s authentication service to log into your account on the Services, you may be able to control your settings through the third-party platform or social media network. 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.

V. Security

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 transmitting or storing information can be 100% secure and we cannot guarantee the security of your personal information.

VI. Other Information

• Cross Boarder Transfers. The Site and Services are controlled and operated from the United States. Your personal information may be used, stored, and processed in any country in which 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.
• Sensitive Information. We ask that you not send us, and you not disclose, any sensitive information (e.g., Social Security numbers, passport information, information related to racial or ethnic origin, or health) on or through the Site or Services or otherwise to us unless specifically requested.
• Minors. The Site and Services are not intended for anyone under the age of 18 and we do not knowingly collect personal information from users under the age of 18. If a minor under the age of 18 has already provided us with personal information, his or her parent or guardian may contact us to request that we delete it.
• Third Party Privacy Practices. This Privacy Policy addresses only the use and disclosure of information collected by us. This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or service to which the Site or Services may link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. If you disclose your information to others, or if you are directed to a third-party website, their privacy notices and practices will apply.

VII. Contact

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us using “ATTENTION: PRIVACY COMPLIANCE OFFICER” in the message. You may reach us at service@neighborstrailer.com.

VIII. Withdrawal of Consent

If you no longer wish for us to process your data, please contact us via email using the service@neighborstrailer.com email address.

IX. Privacy Policy Updates

We reserve the right to modify this Privacy Policy at any time for any reason. It is your sole responsibility to check our policies so please review them frequently. Changes and clarifications will take effect immediately upon their posting on the Site. Should we make material changes to this Policy, we will notify you here that it has been updated so that you are aware of what information we collect and how it is used.

UNITED STATES REGIONAL PRIVACY STATEMENT

This PRIVACY NOTICE FOR RESIDENTS applies solely to visitors, users, and others who reside in the States of California, Utah, Virginia, Texas, Connecticut, and Colorado (“consumers” or “you”). We adopt this notice to comply with the various privacy laws of those jurisdictions.

• Information We Collect. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include (a) publicly available information from government records; (b) de-identified or aggregated consumer information; or (c) information excluded from the applicable law’s scope, for example health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), a state equivalent or clinical trial data.

• Use of Personal Information. Our use of your Personal Information is described above in this Policy. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
• Sharing Personal Information. We share your Personal Information only as described above. In the proceeding twelve (12) months, we have shared only the information in the chart above that is reflected as a “YES” in the right hand column.

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates and service providers, such as payment processing companies.
• Other users.For example, when you rent a trailer through our Services, we disclose information about you to the trailer owner.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.For example, when you enter payment information, we disclose certain information about you to the payment processor.

• Your Rights and Choices. Applicable law provides consumers (residents of the aforementioned states) with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose or identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable

consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug the Services or other products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with any applicable law.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Request a Correction

The right to request that we correct inaccurate personal information can be made directly to us at service@neighborstrailer.com.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us through our Site.

Only you or a person registered with the state where you reside that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12- month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Non-Discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted by the applicable law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.