Privacy policy

Last revised: December 13, 2019

Turo Inc., for and on behalf of its subsidiaries (collectively, “Turo”, “we”, or “us”) cares about privacy and wants you to be familiar with how we collect, use, process and disclose your personal information. This Privacy Policy covers our privacy practices in connection with your access to or use of our websites and applications (“Platform”), including when you communicate with us or other Turo users via the Platform (collectively “Services”), or when you otherwise provide us with personal information.

Personal information we collect

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


Personal information you give us

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

Profile information. We may also ask you to provide additional profile information to use certain features of the Turo Service which may include street addresses, phone numbers, driver’s license number, date of issuance and issuing country and/or state, profile photos, employer, city, school, biography, and date of birth. Certain parts of your profile (like your profile photos, employer, city, school, and biography) are part of your public profile page and will be publicly visible to others.

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

Payment information. We collect your financial information (like your digital payment details or bank account or payment card numbers) in connection with a potential or actual transaction, which may be processed and stored by one or more third party payment services providers or digital payments companies.

Authentication information. In some instances, we may ask you to provide us a photograph and/or other demographic information, such as a scanned copy of a driver’s license, passport, or credit/debit card, last four digits of your Social Security number, social insurance number, social media account information, driver’s/motor vehicle record, insurance information, and other forms of identification. Where we request that you withhold certain information (such as obscuring or redacting all but the last four digits of your payment card number), please do so.

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


Personal information we automatically collect when you use or access our Services.

Usage data. We collect information about your interactions with the Platform, such as the pages or other content you view, your searches, bookings you have made and other actions on the Platform.

Location information. When you use certain features of the Platform, we may collect information about your approximate location (e.g., city/town associated with your IP address) or when you opt in to use our location sharing feature, the precise location information of your mobile device. Keep in mind that most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device’s settings menu.

Log data. We automatically collect log information when you use the Platform, even if you have not created a Turo account or logged in. That information includes, among other things: details about how you’ve used the Platform, IP address, length of stay, frequency of visits, hardware and software information, unique device identifiers, device event information (e.g., crashes, browser type) and the page you’ve viewed or engaged with before or after you’ve used the Platform.

Trip information. In addition to the trip information you provide to us (as described in the ‘Personal Information you give us’ section above), we also collect transactional information related to your trip on the Platform, including the date and time of your trip, amounts charged and other related trip details.

Remote vehicle access. If a vehicle is enrolled in a Turo Go program or has a Turo Go device installed, the information we collect depends on the make, model and year of the vehicle but may include, GPS location, car battery voltage, fuel level, odometer reading, malfunction indicator lamp (e.g., a check engine light), door state (e.g., locked/unlocked), engine state (e.g., stopped/running) and VIN.

Cookies and similar technology. When you access our Platform, 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.


Information we collect from third party sources.

Third party services. If you choose to log in to our Services through a third party site or service (e.g., Apple, Facebook or Google), the third party service may send us information such as your registration and profile information from that service. The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your Turo account and authorizing Turo to have access to this information, you agree that Turo 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 those third parties’ privacy policies to understand how they use and share your personal information.

Third party in-vehicle devices. If your vehicle, or a vehicle you book through the Services, includes an in-car device or system operated by a third party service (including vehicle manufacturers) or installed by the host, that host or service may record information about your use of the car. The host and third-party service will be solely responsible to you for its use of such information but may disclose such information to Turo.

Background information. To the extent permitted by applicable laws, Turo may obtain reports from public records of criminal convictions or local versions of background checks and/or registered sex offenders checks. We may use your information, including your full name and date of birth, to obtain such reports.

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 from third party service providers and/or partners. We may combine the information about you that we receive from third party sources with other information we have about you.

How we use your personal information

We use, store and process your personal information to provide and improve our Services and ensure a secure, safe and trusted experience. For example, we may use your information:


To provide our Services, including to:
  • enable you to access and use the Turo Services
  • provide customer support
  • send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you at any telephone number, by placing a voice call or through text (SMS) or email messaging
  • facilitate your login to the Service via third-party identity and access management providers, such as Facebook
  • enable the processing of transactions and send notices about your transactions
  • personalize or customize your user experience
  • enable you to communicate with other Turo users, including by sending them messages or other information during the booking process
  • if you provide us or our service providers any information relating to other people in connection with the Services, we may use and store this information to facilitate your referral invitations; send your requests for reviews, for fraud detection and prevention and for any purpose you authorize at the time of collection
  • administer referral programs, rewards, surveys, contests, or other promotional activities or sponsored events in which you participate

To improve our Services: We may use the personal information you provide to analyze and improve the Service and to develop new products and services, including by studying our user demographics of the Service.

To send you marketing and promotional communications: We may send you Turo-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the ‘Opt out of marketing’ section below.


To ensure a secure, safe and trusted experience, including to:
  • verify your identity or authenticate information provided by you, including during account creation and password reset processes
  • resolve disputes, collect fees, and troubleshoot problems
  • detect, prevent, and/or remediate fraud, abuse, security incidents or other potentially harmful, prohibited or illegal activities
  • determine your likelihood of getting into an accident or of making an insurance claim, such by checking your auto insurance score
  • using information from your device to identify unsafe driving behavior, including speeding or harsh braking and acceleration, and to raise awareness regarding such behaviors
  • detect, prevent or remediate violations of and enforce our Terms of Service and Policies
  • manage and protect our information technology infrastructure
  • conducting investigations and risk assessments
  • conduct checks against databases and information sources (such as but not limited to public government databases)
  • perform creditworthiness and solvency checks

To comply with law: We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.

To create anonymous data: We may create aggregated, de-identified or other anonymous data from your personal information and other individuals whose personal information we collect. 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 Service and promote our business.

With your consent: In some cases, we may specifically ask for your consent to process your personal information.

We may also use your personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.


How we disclose your personal information

With your consent

You may direct us to share your information or consent to it as described at the time of sharing.


Profiles, listings and other public information

Your public listing page on our Platform will always include some basic information, such as your user ID/name associated with your account, your public profile photo, and for hosts, the city where your car is located, your listing description, your calendar availability, transaction related information to allow our community to evaluate your reliability and responsiveness, and reviews/feedback. Your public listing page may also include aggregate demand information (such as number of page views over a period of time) and information about your cancellations. Our Services may also display the approximate geographic pick-up location of your vehicle.

Our Services 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 hosts and guests

Turo enables car owners to offer and share their vehicles 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, Turo may provide your mobile phone number and/or driver’s license information to facilitate communication or your photograph to facilitate identification. We will provide the address of the vehicle and/or the proposed delivery location. We may also share user-uploaded “Trip Photos” with captions with the other party involved in the reservation if that feature is selected. Turo users engaged in a booking with you may send you text messages (such as to confirm pickup or delivery location). Standard telephone minute and text and data charges may apply.


Service providers

We may share information with vendors and service providers who are engaged by, or working with, us in connection with the processing of payments, operation of our Services and customer support functions and who need access to such information to carry out their work for us (including, for example, web hosting, analytics, email delivery, marketing, insurance companies, claims administrators, and customer support services). In some cases, the service provider may be directly collecting the information from you on our behalf. For hosts who choose to use our photography program, your contact information will be shared with the photographer assigned to shoot your vehicle. These providers may use your personal information only as directed or authorized by us.


Third-party platforms and social media networks

If you have enabled features or functionality that connect the Service to a third-party platform or social media network (such as by logging in to the Service using your account with the third-party, providing your API key or similar access token for the Service to a third-party, or otherwise linking your account with the Service to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.


Professional advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where 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 corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.


Responding to legal requests, preventing harm, and protecting our rights

As noted above, 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 we consider such disclosure is reasonably necessary to comply with our legal obligations or legal process, to respond to claims asserted against us and for safety purposes described above. 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 Turo, you, or any other user to legal liability or to protect the rights, property, or personal safety of Turo, our employees, our users, or members of the public.

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 and choices

Communication preferences

You can control the methods by which we may contact you about your account, your booking and listing activities, promotions, and announcements in the Notifications section within your Turo account.


Opting out of marketing communications

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 message from us by replying STOP to our marketing message or as described in the message.


Correct and update

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 support.turo.com. For your protection, we may need to verify your identity before implementing your request.


Account closure

If you wish to close your account and request deletion of your personal information, please send an email to accountclosure@turo.com or contact us at support.turo.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 investigation, comply with audits and investigation, to enforce our Terms of Service and 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

If we are legally required to offer this option, you may request a copy of your personal information provided to us by visiting your account page on the web. We will send you a copy of the personal information to the email address provided in your account as soon as reasonably practicable. We may request proof of identification or re-authentication to verify your access request.


Location data

Users of our mobile application can disable the application’s access to the device’s location within the device’s settings.


Targeted online advertising

Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Users in the EEA may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly titled link). Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that do not participate in the opt out mechanisms that we linked above. In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.


Choosing not to share your personal information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the 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 our Services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.


Third-party platforms or social media networks

If you choose to connect to the Service via a third party platform or social media network, you may have the ability to limit the information that we may obtain from the third party at the time you login to the Service using the third party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third party’s platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. 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.

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 transmission over the Internet, and no method of storing information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your information that we store.

Important information

This section describes some additional important privacy information related to your use of our Services.


Cross border transfer

The Services are controlled and operated by us from the United States. Your information may be used, stored and processed in any country where 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. You can learn more about how we protect your data from government requests here.


Sensitive information

We ask that you not send us, and you not disclose, any sensitive information unless specifically requested (e.g., Social Security numbers, social insurance numbers, passports, information related to racial or ethnic origin, or health), on or through the Services or otherwise to us.


Children’s privacy

Our websites are general audience websites, and our Services are not intended for anyone under the age of 18. We do not knowingly collect information from users under the age of 18. If a child under the age of 18 has already provided us with information, his or her parent or guardian may contact us for the purpose of deleting this information or closing an account.


Third party privacy practices

This Privacy Policy addresses only the use and disclosure of information collected by Turo. 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 Services 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.


Signed in

If you sign in to our Platform using an email address and password, your session will expire after 30 days unless you log out but if you sign in through a social network login such as Facebook or Google, you will stay logged on/signed in until you explicitly sign out of your account or clear your Cookies. If you are using a public or shared computer you should sign out and/or clear your Cookies when you are done using our Platform in order to protect your account and your information. If you do not sign out, you or any other user of the computer/browser you signed in on will be able to view and access your account, including your social media accounts.


Translations

Where Turo has provided you with a version of this Privacy Policy in a language other than English, in case of any wording discrepancies between such version and the English version, the English wording takes precedence.

Changes to this privacy policy

We may change this Privacy Policy. Please take a look at the “Last revised” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy. If you don’t agree to these changes, you can contact us to close your account and you will only be bound by the prior version of the Privacy Policy.

Contact

Turo welcomes your questions and comments about privacy, and what we do. Please feel free to contact us at our address in the United States.

You may also email us.

Information for California residents

This information applies only to California residents and describes how we collect, use and share their Personal Information in operating our business, and their rights with respect to that Personal Information.

Only as used in this section only and at the linked information below, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (CCPA) but does not include information excluded from the scope of the CCPA.


Your California privacy rights.

As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request 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 Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of recipient.
  • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of recipient.

Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.

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

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as:

  • Denying you goods or services,
  • Increasing the price/rate of goods or services,
  • Decreasing service quality, or
  • Suggesting that we may penalize you as described above for exercising your rights.

However, we may charge you a different price or vary the quality of the service you receive if that difference is reasonably related to the value to us of the Personal Information we are unable to use due to the exercise of your rights. We may also offer you financial incentives that result in different prices or service quality.

We do not sell personal information to third parties. As described in our Privacy Policy, we do allow third parties to collect personal information through our Platform and share personal information with third parties for business purposes, including advertising and marketing on our Services and elsewhere based on users’ online activities across various services, sites, and devices.


How to exercise your rights

You can request to exercise your information, access and deletion rights by contacting us at support.turo.com or emailing privacy@turo.com.

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.


Personal information that we collect, use and share

The chart accessible here summarizes the Personal Information we collected, used and shared during the 12 months before the “last revised” date of this Privacy Policy. In that chart, we describe the sources through which we collect your Personal Information in the section above entitled Personal information we collect, and describe the business and commercial purposes for which we collect, use, and share this information in the section above entitled How we use your personal information.


Information for European users

The information in this section applies only to individuals in the European Union, the European Economic Area or the United Kingdom (collectively, “Europe”).

Personal information. Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. Turo Inc. is the controller of your personal information covered by this Privacy Policy for purposes of the European data protection legislation. You may contact us at privacy@turo.com.

Legal bases for processing. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. If you have questions about the legal basis of how we process your personal information, contact us at privacy@turo.com.

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention. We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; or for fraud prevention). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


Your rights.

European data protection laws give you certain rights regarding your personal information. If you are located in Europe you may ask us to take the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information.
  • Transfer. Transfer a machine‐readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to privacy@turo.com or our postal address or by accessing certain features in the Services.

We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us at privacy@turo.com or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.


Cross‐Border Data Transfer

If we transfer your personal information from Europe to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so, for example, by implementing the standard contractual clauses adopted by the European Commission. Please contact us at privacy@turo.com for further information about any such transfers or the specific safeguards applied.


Thanks for using Turo!