Pulltail Privacy Policy

Please read the following carefully. This Privacy Policy explains how Pulltail, Inc. collects, uses, discloses and protects personal information when you use the Pulltail website, the Pulltail mobile applications and related services. If you are under 18 years of age, please read this Privacy Policy with your parents or guardian and ask them about anything you do not understand. Your use of the Services constitutes acceptance by you of this Privacy Policy.

1. Introduction and scope

Pulltail, Inc., the operator of the Pulltail app and pulltail.com (collectively, the "site", "website", "app" or "Pulltail app"), is dedicated to protecting our users' ("users" or "you") privacy rights. The purpose of this Privacy Policy is to inform you about our practices regarding the collection, use and disclosure of personal information when you use the applications, websites and services offered by us (collectively, the "Services").

This Privacy Policy applies to your access to and use of pulltail.com, the mobile applications named Pulltail made available through the Apple App Store and the Google Play Store, along with any revisions, updates and modifications thereto (collectively, the "App"), the tools we make available to trailer owners ("Hosts"), and any data, products, services and associated materials or media supplied with the App (together with the App and the website, the "Services"). It applies to individual renters, renters who use the Services on behalf of a business (for example, a motor carrier and its drivers), Hosts, and visitors to our website.

We take your privacy and data security seriously. This Privacy Policy is meant to help you understand what information we collect, how we use it, the limited conditions under which we disclose it to others, and how we keep it secure. Pulltail is the "business" or "controller" responsible for personal information collected through the Services, and this Privacy Policy is written to comply with the California Consumer Privacy Act as amended by the California Privacy Rights Act (together, the "CCPA"), the California Online Privacy Protection Act ("CalOPPA") and the comprehensive privacy laws of other U.S. states.

The personal information collected through the Services is collected, controlled and processed by:

Pulltail, Inc.
PO Box 9280
Glendale, CA 91226
Email: rental@pulltail.com
Phone: (513) 800-2711

This Privacy Policy does not apply to the practices of Hosts, motor carriers, insurers or other third parties that you interact with through the Services. Their use of your information is governed by their own privacy practices.

2. Information we collect

2.1 Information you provide to us

We collect information you provide directly to us. For example, we collect information when you register for an account, complete your profile, upload your driver's license, add a payment method, sign a rental agreement, list a trailer as a Host, subscribe to a newsletter or email list, participate in a survey, contest, promotion or referral program, or otherwise communicate with us. This information is necessary to ensure complete functionality of the Services and to perform the services you request. The types of information we may collect include:

• Account and profile information. Your first, middle and last name, nickname, email address, phone number, password, date of birth, home address, profile photo, how you heard about us, referral or promotional codes, and your notification preferences.
• Driver's license and identity information. Photographs of the front and back of your driver's license, the information printed on the license and encoded in its barcode (including your name, date of birth, address, license number, issuing state, license class, restrictions, issue and expiration dates, and the photograph and signature printed on the license), and the results of our verification checks. Where required to verify your identity, evaluate your eligibility or obtain a consumer report as described in Credit reports and eligibility checks, we may also collect your Social Security number. We ask for your explicit confirmation before you upload your license.
• Payment information. When you add a payment card, we collect your card number, expiration date, security code, name on the card and billing address, and we transmit them to our third-party payment processors, such as Authorize.Net, which store your card in a payment profile and process charges. We keep the payment details needed to charge authorized amounts, to document the payment authorization you sign and to respond to payment disputes. If you are a Host, we collect the bank account information needed to send you payouts (account holder name, routing number, account number and account type). We also collect records of your transactions, invoices, deposits, refunds, fees, fines and balances.
• Rental agreements and electronic signatures. The rental, lease, parking, payment-authorization and other agreements you sign electronically through the Services, your electronic signature, and the audit trail associated with each signature (such as the date and time, IP address, device information and, where you allow it, the location at the time of signing).
• Trailer condition photos and rental records. Photographs and notes you or a Host submit at check-in, check-out, inspection, repair, storage or incident reporting, along with pickup and return locations, dates and times, mileage and trailer identifiers.
• Insurance information. Certificates of insurance and related documents, your insurer's name, policy numbers, coverage limits, effective and expiration dates, and claim-related information.
• Business information. If you rent, drive or host on behalf of a business, the company name, address, phone and email, USDOT and MC numbers, operating authority and compliance status, the carrier you drive for, and, where required for payouts or vendor onboarding, tax identification numbers and tax forms.
• Onboarding and tax documents. Where required for the particular relationship you have with us (for example, Host payouts, vendor onboarding or driver onboarding), bank account details for payments, a photo ID, Social Security card, employment authorization documents, and completed tax and employment forms such as Forms I-9, W-4 and W-9.
• Vehicle and parking information. If you use our parking services, information about your tractor or vehicle, including license plate numbers.
• Communications. The content of messages you exchange with us or with other users through the in-app chat, support requests, emails, text messages and phone calls, and reviews and ratings you submit.
• Other information you choose to provide, such as when you fill out our contact form, respond to a survey, or request technical or customer support.

2.2 Information we collect automatically

When you access or use the Services, we automatically collect certain information, including:

• Log information. When you visit the Services, our servers automatically record certain log file information, such as your Internet Protocol ("IP") address, operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on the Services.
• Device information. Information about the computer or mobile device you use to access the Services, including the hardware model, operating system and version, unique device identifiers, app version and build number, mobile network information, push notification tokens, and information about your use of the Services. We keep a record of the devices you have used to sign in (including a device identifier, platform, browser or user agent and IP address) so that we can recognize trusted devices and detect unauthorized access.
• Location information. With your permission, we collect the precise location of your mobile device only while you are using the App, for example to show you the distance to nearby trailers and locations, to help with pickup and return, and to record where an agreement was signed. We do not track your location in the background or when the App is closed. We also derive approximate location (city, state and ZIP code) from your IP address. You can stop the collection of precise location information at any time through your device settings, but some features of the App, such as electronic signing, may no longer function if you do so. Our use of location information follows Apple's and Google's requirements for accessing location.
• Trailer telematics (GPS). Trailers rented through the Services may be equipped with GPS tracking devices supplied by third-party telematics providers (for example, SkyBitz). During your rental, these devices report the trailer's location, movement, speed, and related sensor and status information to us. We use this information to locate and protect our equipment, support pickup and return, verify mileage and usage, investigate incidents, tolls, fines and claims, and recover trailers that are lost, stolen or not returned.
• Information collected by cookies and other tracking technologies. We and our service providers use various tracking technologies, including cookies, pixels and web beacons, to collect information about you when you interact with our Services, including information about your browsing and purchasing behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve the Services and your experience, see which areas and features of the Services are popular, and count visits. Web beacons are electronic images that may be used in the Services or emails and help deliver cookies, count visits and understand usage and effectiveness. For more information, please see Cookies, analytics and advertising.

2.3 Information we collect from other sources

We may also obtain information about you from other sources and combine it with information we collect directly. For example:

• Document-processing and verification providers. The information extracted from your driver's license and insurance documents by our document-processing service providers, and the results of their checks.
• Consumer reporting agencies. With your authorization, consumer credit reports and scores from consumer reporting agencies such as Experian.
• Government and public records. Information about motor carriers from the Federal Motor Carrier Safety Administration (FMCSA) and similar public sources, including operating authority, safety and insurance status.
• Payment processors, card issuers and banks. Card verification results, card type and issuing bank information, fraud signals, and notices of disputes and chargebacks.
• Insurers and claims administrators. Information about your coverage and about claims involving a trailer you rented or hosted.
• Toll, parking and law enforcement authorities. Notices of tolls, parking violations, citations and fines incurred during your rental.
• Hosts and other users. Reviews, ratings, incident reports and condition photos submitted by the other party to your rental.
• Marketing and referral partners. Information from affiliates and referral partners about how you were referred to us, and from advertising partners about the performance of our campaigns.
• Social media and third-party sign-in. Information you make available when you post content to our pages or feeds on third-party social media sites, or if you use credentials from a third-party site to create or log into your account.

3. How we use information

We may use information about you for the following purposes:

• Provide, maintain and improve the Services, including matching renters with available trailers, parking and loads;
• Verify your identity, your eligibility to rent, and the validity of your driver's license, insurance and business credentials;
• Create, execute, store and enforce rental and other agreements;
• Process payments, deposits, refunds, payouts and collections; respond to payment disputes and chargebacks; and re-bill tolls, fines, violations, damage and other charges incurred during your rental;
• Manage your account and send you related information, including confirmations, invoices, updates, technical notices, security alerts, and support and administrative messages;
• Respond to your comments, questions and requests and provide customer service;
• Detect, investigate and prevent fraudulent transactions, unauthorized account access, identity theft and other illegal activities, and protect our and others' rights, property and safety;
• Locate, protect and recover our trailers and other equipment, and investigate accidents, damage, theft and other incidents;
• Handle insurance matters and claims;
• Communicate with you about the Services, offers, surveys, events and other news and information we think may be of interest to you, subject to your choices;
• Monitor and analyze trends, usage and activities in connection with the Services;
• Personalize and improve the Services and provide advertisements, content and features that match your profile or interests;
• Link or combine information we get from others with information we collect to help understand your needs and provide you with a better experience;
• Comply with legal obligations, including tax, accounting, motor carrier and law enforcement requirements, and establish, exercise or defend legal claims; and
• Carry out any other purpose for which the information was collected or that we describe to you at the time of collection.

3.1 Driver's license verification and document processing

Before you can rent a trailer, we require you to photograph the front and back of your driver's license using the App or our website. We use your license as follows:

• Barcode reading. We read the machine-readable barcode on the back of your license using software on your device or on our servers to obtain the information encoded in it.
• Extraction and validation by service providers. We transmit the images of your license to third-party document-processing service providers that use artificial intelligence and optical character recognition to extract the information printed on the license and return it to us in a structured form. We compare the extracted information with the barcode data and with the information in your account and on your payment method, and we check that the license is unexpired and appears genuine. We use the same providers to extract information from insurance certificates and similar documents you submit.
• Provider obligations. Each provider receives your information only as our service provider or processor under a written data processing agreement. The provider is required to process your information only to perform the extraction and validation services for us, is prohibited from using it for any other purpose, including training or improving its models, is prohibited from selling or disclosing it, and may retain it only for the limited period permitted under our agreement (for example, for security and abuse monitoring), after which it must be deleted. We do not send your Social Security number, payment information or trailer location data to these providers.
• Human review and your right to ask for review. The extraction results are used to assist our verification and fraud-prevention checks. If the information extracted from your license does not match the barcode or your account, if a provider cannot process your images, or if a check raises a concern, a member of our team reviews the matter before any decision to decline, suspend or terminate your access to the Services. We do not make decisions that produce legal or similarly significant effects on you solely by automated means. You may ask us to review any verification decision by contacting us at rental@pulltail.com.
• Purpose limitation. We collect and use the information from your driver's license, including the information obtained by scanning its barcode, only to verify your identity and age and the authenticity of your license, to complete and enforce your rental transaction, to prevent fraud, abuse and material misrepresentation, to resolve disputes and claims, and to comply with law. We do not use driver's license information for marketing and we do not sell it. Where a state law limits the information that may be collected or retained from a scanned license, we comply with that law.
• Your confirmation. When you upload your license, we ask you to confirm that you have read this Privacy Policy and agree to the processing described in this section. If you live in a state that requires your opt-in consent to process a government identification number or other sensitive information, this confirmation constitutes your consent. You may withdraw your consent at any time by contacting us, but we will not be able to complete your verification or provide rentals to you without it, and we may keep information we already hold as described in Data retention.

3.2 Credit reports and eligibility checks

With your authorization, we may obtain a consumer credit report and credit score about you from a consumer reporting agency (for example, Experian) in connection with a rental, lease or credit transaction that you initiate. We use the report to evaluate your eligibility, to set deposit, credit or payment terms, and to prevent fraud. We use consumer reports only for purposes permitted by the Fair Credit Reporting Act. If we take adverse action based in whole or in part on information in a consumer report, we will provide you with the notices required by law, including the name and contact information of the consumer reporting agency and your right to obtain a free copy of the report and to dispute its accuracy. For business accounts, we may also review public safety, authority and insurance records maintained by the FMCSA and similar sources.

3.3 No biometric identifiers or facial recognition

We do not ask you for a selfie or a video of your face. We do not collect, capture, purchase or otherwise obtain biometric identifiers or biometric information, such as scans of face geometry, fingerprints, voiceprints or retina or iris scans, and we do not perform facial recognition or compare your appearance with the photograph on your driver's license, either ourselves or through a service provider. The photograph printed on your license is processed only as part of the image of the document. If we ever change this practice, we will update this Privacy Policy and obtain any consent required by law before doing so.

4. How we share information

We may disclose information about you as follows or as otherwise described in this Privacy Policy:

4.1 Service providers

We disclose personal information to vendors, consultants and other service providers that perform services on our behalf and are permitted to use it only for that purpose. These include providers of:

• Cloud hosting, storage, databases and content delivery (for example, Google Cloud and Firebase, and Cloudflare);
• Document processing and identity verification using artificial intelligence and optical character recognition;
• Payment processing, card and bank account verification, and payouts (for example, Authorize.Net);
• Accounting, invoicing and bookkeeping (for example, QuickBooks);
• Consumer reporting and credit checks (for example, Experian);
• Trailer telematics and GPS tracking (for example, SkyBitz);
• Text messaging, voice calling, email delivery and email marketing (for example, Twilio, Dialpad and Mailchimp);
• Analytics, crash reporting and advertising measurement (for example, Google Analytics, Google Analytics for Firebase, Firebase Crashlytics and Google Ads);
• Customer support, internal communications, task management and security tools; and
• Electronic signature, document generation and mapping services.

The companies named above are examples. We may use other or additional third-party service providers in these categories from time to time.

4.2 Hosts, renters and other users

The Services connect renters with Hosts. To facilitate a rental, we share limited information with the other party, such as your name, profile photo, phone number and email address, your verification status, the business you represent, trailer and pickup details, condition photos, reviews and messages exchanged through the Services. We do not provide Hosts with copies of your driver's license images, payment card details or bank account information. If an incident, claim, unpaid balance or legal matter arises from a rental, we may share additional information with the other party, or with their insurer or attorney, to the extent necessary to resolve it. Information you post publicly, such as a nickname or a review, may be visible to other users.

4.3 Payment disputes, chargebacks, claims and legal proceedings

If you or your card issuer disputes a charge, if a chargeback or payment reversal is initiated, if a balance remains unpaid, or if a claim or dispute arises out of your use of the Services, we may disclose information to demonstrate that a transaction was authorized and that an agreement was entered into and performed. This information may include the images of your driver's license, the information extracted from it, the agreements you signed and their signature audit trail, check-in, check-out and inspection photos, trailer GPS records, invoices and payment records, and your communications with us. The information may be disclosed to your card issuer and bank, the card network (for example, Visa, Mastercard, American Express or Discover), our payment processor and acquiring bank, our insurers, courts, arbitrators, mediators, collection agencies, attorneys and other advisers. When we prepare evidence for these purposes we include only the information needed to resolve the matter, and we mask or omit sensitive details.

4.4 Insurers and claims administrators

If a trailer you rented or hosted is involved in an accident, damage, theft or another incident, we may share information about you and the rental with our insurers, the other party's insurers, claims administrators, adjusters and repair vendors for the purpose of handling the claim.

4.5 Toll, parking and government authorities

Tolls, parking violations, citations, fines and similar charges incurred while a trailer is in your possession are your responsibility under your rental agreement. We may disclose your name, address, driver's license information, rental dates and other information to toll operators, parking authorities, law enforcement agencies, courts and their contractors in order to identify the responsible driver, transfer liability for the charge to you, or respond to a notice, and we may re-bill the charge to your payment method.

4.6 Legal requirements and protection of rights

We may disclose information in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation, subpoena, warrant, court order or other legal process, or a lawful request from a government or law enforcement authority. We may also disclose information if we believe your actions are inconsistent with our Terms of Use, rental agreements or other policies, or to protect our and other parties' rights, property or safety, or to locate and recover our equipment.

4.7 Business transfers and affiliates

We may disclose information in connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction or financing, and between and among us and any current or future parent, subsidiary and affiliated company.

4.8 With your consent and aggregated information

We may disclose information with your consent or at your direction. We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

5. Cookies, analytics and advertising

We may allow others to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons, pixels, software development kits and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, device identifiers, browser type, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity.

Google Analytics, Google Analytics for Firebase and Firebase Crashlytics. The App uses the analysis tools Google Analytics for Firebase and Firebase Crashlytics (collectively, the "Google Analysis Tools") from Google LLC to analyze user behavior and to report on the stability and improvement of the App. Through Google Analytics for Firebase, Google collects data on the device (in particular the mobile advertising identifier), IP addresses and app activities on our behalf to evaluate the use of the App, to compile reports on the activities performed within the App and to permit it to offer us other services related to the use of the App. Firebase Crashlytics collects error reports following any crash of the App, including the device type, operating system version and some technical data, so that we can diagnose and solve problems. Analytics data is retained by Google for up to 14 months and crash data for up to 90 days. You can limit the use of the advertising identifier in your device settings: on Android, Settings, Google, Ads, then delete or reset the advertising ID or opt out of ads personalization; on iOS, Settings, Privacy and Security, Tracking, then disable "Allow Apps to Request to Track", and Settings, Privacy and Security, Apple Advertising, then disable "Personalized Ads". More information is available at https://firebase.google.com/support/privacy/, https://firebase.google.com/docs/crashlytics and in Google's privacy policy. On our website we use Google Analytics and the Google Ads tag to measure traffic and the performance of our advertising campaigns.

Your controls. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services. You can opt out of Google's use of cookies for advertising at https://adssettings.google.com and learn more at https://tools.google.com/dlpage/gaoptout. We treat a Global Privacy Control signal sent by your browser as a request to opt out of the sharing of your personal information for cross-context behavioral advertising for that browser. If you want to stop receiving personalized ads, you can adjust the settings described above; the number of ads you see will not change, but they may be less relevant to you.

Email hashing. If you have provided your email address, we might use a non-human-readable form (or "hash") of your email address to deliver, or facilitate delivery of, relevant advertisements and information to you on or by way of the Services or on or by way of other websites or media, including, for example, popular social media sites and features.

Do Not Track. Some browsers offer a "Do Not Track" setting. There is no industry standard for responding to these signals, and we do not respond to them at this time. We do respond to Global Privacy Control signals as described above.

6. Text messages, calls, email and push notifications

Text messages. By providing your mobile phone number and verifying it, you agree to receive text messages (SMS) from us at that number, including verification codes, rental and payment notifications, security alerts and customer support messages, and, if you opt in, promotional messages. Message frequency varies. Message and data rates may apply. You can stop receiving text messages at any time by replying STOP to any message or by contacting us; you may still receive verification codes and messages required to service your account. We will not sell or share your phone number with third parties for their own marketing purposes. Text messaging originator opt-in data and consent will not be shared with any third parties, except with our messaging service providers to the extent necessary to deliver the messages.

Calls. We may contact you by phone about your account, rentals, payments and support requests. Calls with our team may be monitored or recorded for quality, training and record-keeping purposes where permitted by law, and we will notify you at the start of a call if it is being recorded.

Email. We send transactional emails (such as confirmations, invoices, agreements and security alerts) and, subject to your choices, promotional emails. You may opt out of promotional emails as described in Your choices.

Push notifications. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or in the App.

7. Your choices and your rights

7.1 Your choices

• Account information. You may update, correct or modify information about you at any time by logging into your account or by emailing us at rental@pulltail.com. If you wish to deactivate your account, please email us at rental@pulltail.com, but note that we may continue to store information about you as required by law or for the legitimate business purposes described in Data retention.
• Location information. With your permission, we collect information about your actual location only while you are using our mobile applications, and never in the background. You may stop the collection of this information at any time by changing the settings on your mobile device, but note that some features of our mobile applications may no longer function if you do so. Trailer GPS devices are part of the equipment and cannot be disabled by renters.
• Camera and photos. Some features of our mobile applications require access to your device's camera and photo library, for example to photograph your driver's license and the trailer. We ask for your permission before accessing them, and you can revoke that permission at any time in your device settings.
• Cookies and advertising. See Cookies, analytics and advertising.
• Promotional communications. You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at rental@pulltail.com. If you opt out, we may still send you non-promotional communications, such as those about your account, your rentals or our ongoing business relations.
• Push notifications and text messages. See Text messages, calls, email and push notifications.

7.2 Your rights

All personal information we collect about you remains yours. Depending on where you live, you may have the following rights with respect to your personal information, subject to the exceptions provided by law:

• Right to know and access. To confirm whether we process personal information about you and to obtain access to it, including the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of third parties to whom we have disclosed it.
• Right to correct. To have inaccurate personal information corrected and incomplete personal information completed.
• Right to delete. To have your personal information deleted. Please note that a request to delete your personal information will also terminate your account, and that we may retain information where an exception applies, for example to complete a transaction, prevent fraud, resolve disputes, defend legal claims or comply with a legal obligation (see Data retention).
• Right to data portability. To obtain a copy of the personal information you provided to us in a portable and, to the extent technically feasible, readily usable format.
• Right to opt out. To opt out of the sale of personal information, the sharing of personal information for cross-context behavioral advertising or targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects. We do not sell personal information for money. See Cookies, analytics and advertising for how to opt out of advertising cookies.
• Right to limit the use of sensitive personal information. We use sensitive personal information only for the purposes permitted by law without a right to limit, as described in Sensitive personal information.
• Right to restrict or object to processing, and to withdraw consent. Where processing is based on your consent, to withdraw it at any time without affecting the lawfulness of processing before the withdrawal.
• Right to non-discrimination. We will not discriminate against you for exercising your rights.
• Right to appeal. If we decline to act on your request, to appeal our decision as described in How to submit a request, verification and appeals.
• Right to lodge a complaint. We take privacy concerns seriously. If you believe that we have not complied with this Privacy Policy with respect to your personal information, you may contact us.

To exercise any of your rights at any time, contact us at rental@pulltail.com or (513) 800-2711, and we will facilitate the exercise of your rights free of charge. We will confirm receipt of your request and respond within the time required by applicable law, generally within 30 to 45 days, and will inform you if we need more time. Before responding, we will verify your identity by matching the information in your request with the information in your account and, where necessary, by sending a confirmation to the email address or phone number on file; we will not ask you to upload a new copy of your driver's license solely to verify a request. You may designate an authorized agent to make a request on your behalf, in which case we may require proof of the agent's authority and verification of your identity.

8. Data retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including for as long as you have an account with us, for as long as you can bring a claim against us and we can defend ourselves, and for any period required by applicable law, unless a longer or shorter retention period is required or permitted by law. In particular:

• Driver's license images and extracted license data. We retain the images of your driver's license, the information extracted from them and the results of our verification checks for as long as your account is active and for at least five (5) years after the later of your last rental or the closure of your account, and for longer where necessary to resolve a payment dispute, chargeback, claim or investigation, to establish or defend legal claims, or to comply with law. We keep this information because it is our record that we verified your identity and because it is evidence in payment disputes and chargebacks, insurance claims, toll and violation matters, and legal proceedings. We delete or de-identify this information when it is no longer needed for these purposes.
• Signed agreements, signature audit trails, condition photos and rental records. For the duration of the limitations period applicable to claims under the agreement and for any period required by law.
• Payment and transaction records. For at least seven (7) years, as required for tax, accounting and audit purposes.
• Consumer reports. For the period necessary to make and document our decision and thereafter as required or permitted by the Fair Credit Reporting Act.
• Trailer GPS records. For the duration of the rental and for a limited period afterwards to support incident, toll, fine and claim investigations.
• Marketing information. Until you opt out or your account is closed.
• Analytics and log data. As described in Cookies, analytics and advertising, or for a shorter period where the data is no longer needed.

When we no longer need personal information, we delete it or de-identify it in accordance with our retention schedule and applicable law. Copies may persist in backups for a limited period before being overwritten.

9. Security

The security of your information is important to us. We implement and maintain reasonable administrative, technical and physical security measures intended to protect against unauthorized access, use, disclosure, alteration or destruction of the information we collect and maintain. These measures include encryption of information in transit and at rest, access controls and authentication for our personnel, restricted access to driver's license images and other sensitive information, and contractual security requirements for our service providers. However, please be aware that, despite our efforts, no data security measures, no method of transmission over the Internet, and no means of electronic or physical storage is absolutely secure.

As such, you acknowledge and accept that we cannot guarantee the absolute security of your information transmitted to, through or on the Services or via the Internet and that any such transmission is at your own risk. Where we have given you (or where you have chosen) a password which enables you to access your account, you are responsible for keeping this password confidential. Please do not share a password with anyone.

If we become aware of a security incident affecting your personal information, we will notify you and the relevant authorities as required by applicable law. Please report any suspected unauthorized access to your account to rental@pulltail.com immediately.

10. Children's privacy

The Services are not intended for children under the age of 18. Children under the age of 18 must not use the Services for any purpose without first obtaining legally valid parental or guardian consent to this Privacy Policy (both for themselves and on your behalf).

We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact us if you believe we have any personal information from any children under the age of 18 without such parental or guardian consent. We will take reasonable steps to delete it as soon as possible.

11. Social sharing features and third-party links

The Services may offer social sharing features and other integrated tools, such as Facebook and X (formerly Twitter) buttons (for example, "Like" or "Share"), which let you share actions you take on the Services with other media. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

The Services may contain links to third-party websites, applications and services, including those of Hosts, insurers, load boards and payment providers. This Privacy Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review their privacy policies before providing them with information.

12. Users outside the United States

The Services are offered in the United States and are intended for users located in the United States. Personal information is stored and processed in the United States by us and by our service providers, and the privacy laws of the United States may differ from those of your country. If you access the Services from outside the United States, you understand that your information will be transferred to and processed in the United States.

13. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time. You will know if the Privacy Policy has changed since the last time you reviewed it by checking the "Effective Date" at the beginning of the document. If we make a material change to the Policy, we will provide you with appropriate notice in accordance with legal requirements, for example by email, by a notice in the App or on the website, or by asking for your consent where the law requires it. By continuing to use the Services after changes have been posted, you are confirming that you have read, understood and consented to the latest version of this Privacy Policy.

14. Contacting us

If you have any questions about this Privacy Policy, wish to exercise any of your rights with respect to your personal information, or wish to file a complaint, please contact us at:

Pulltail, Inc.
Attention: Privacy
PO Box 9280
Glendale, CA 91226
Email: rental@pulltail.com
Phone: (513) 800-2711

15. Additional U.S. state privacy disclosures

This section supplements the rest of this Privacy Policy and applies to residents of California and of other states with comprehensive consumer privacy laws, including Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, to the extent those laws apply to us. Where a state law provides you with rights that are different from or in addition to those described in Your rights, we will honor the rights that apply to you. This Section also serves as our notice at collection under California law.

15.1 Categories of personal information we collect and disclose

In the preceding 12 months we have collected the categories of personal information listed below from the sources described in Information we collect, for the business and commercial purposes described in How we use information, and we have disclosed each category for a business purpose to the categories of recipients listed below. We do not sell personal information for money, and we do not knowingly sell or share the personal information of consumers under 16 years of age. The only "sharing" of personal information for cross-context behavioral advertising is the use of advertising cookies and tags described in Cookies, analytics and advertising, which involves identifiers and internet activity information disclosed to advertising and analytics providers; you can opt out as described there.

15.2 Sensitive personal information

We collect and use sensitive personal information only as necessary to perform the services you request, to verify your identity and prevent fraud, to resist malicious, deceptive, fraudulent or illegal actions directed at our business, to ensure the physical safety of natural persons and the security of our equipment, to process payments, to resolve disputes and claims, to verify and maintain the quality of our Services, and to comply with law. We do not use or disclose sensitive personal information to infer characteristics about you or for purposes that would give rise to a right to limit its use under California law, and we therefore do not offer a separate "Limit the Use of My Sensitive Personal Information" control. Where the law of your state requires your consent to process sensitive personal information, including a government identification number, we ask for your consent at the time of collection, as described in Driver's license verification and document processing, and you may withdraw it by contacting us.

15.3 Driver's license scanning

We scan the barcode on your driver's license and process the images of your license only for the purposes permitted by applicable driver's license scanning laws, including California Civil Code section 1798.90.1: to verify your age and identity and the authenticity of the license, to complete and enforce a rental transaction, to prevent fraud, abuse and material misrepresentation, and to comply with law. We do not use or disclose the information obtained from your license for marketing, we do not sell it, and we retain it only as described in Data retention.

15.4 Biometric information

We do not collect biometric identifiers or biometric information as defined by the Illinois Biometric Information Privacy Act, the Texas Capture or Use of Biometric Identifier Act, the Washington biometric identifier law or similar laws, and we do not use facial recognition. See No biometric identifiers or facial recognition.

15.5 Automated decision-making and profiling

We use automated tools, including artificial intelligence, to extract information from documents, to compare it with other information we hold, and to flag possible fraud or inconsistencies. These tools assist our team; they do not, on their own, make decisions that produce legal or similarly significant effects on you. A member of our team reviews flagged matters before we decline, suspend or terminate your access to the Services, and you may request a review of any such decision by contacting us. We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects, and we do not use your personal information for automated decisions about employment, credit (other than the consumer report described in Credit reports and eligibility checks, which is subject to the Fair Credit Reporting Act), housing, education, insurance or health care.

15.6 How to submit a request, verification and appeals

You may submit a request to exercise your rights by emailing rental@pulltail.com or calling (513) 800-2711. We verify requests as described in Your rights. You may use an authorized agent, and we may ask for written authorization and for you to confirm your identity directly with us. We will respond within 45 days of receipt of a verifiable request and may extend that period once by a further 45 days where reasonably necessary, in which case we will notify you. If we deny your request in whole or in part, we will explain why. Residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Virginia and other states that provide a right of appeal may appeal our decision by replying to our response or emailing rental@pulltail.com with the subject line "Privacy Appeal". We will respond to appeals within the period required by your state's law, generally 45 to 60 days, and will tell you how to contact your state attorney general if you are not satisfied with the outcome. We will not discriminate against you for exercising your rights.

15.7 California "Shine the Light" and Nevada

California Civil Code section 1798.83 permits California residents to request certain information about our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes. Nevada residents may submit a request directing us not to sell their personal information; we do not sell personal information as defined by Nevada law, and you may contact us at rental@pulltail.com with any questions.

15.8 Financial incentives

We may offer referral codes, promotional codes and other discounts that involve the collection of personal information, such as your name, email address and referral code. Participation is voluntary, and you may withdraw at any time by contacting us. We do not assign a monetary value to your personal information; the value of any incentive is the amount of the discount or credit offered.

If you have questions about these state disclosures or about our privacy practices in your state, please contact us at rental@pulltail.com.