Privacy Policy

Last Modified: March 18, 2019

Scope of this Policy and Users Subject to this Policy.

This privacy policy (the “policy”) applies to the users of the services of TowZing, Inc. (“TowZing” or “we”) anywhere in the world, including users of any of TowZing’s apps, websites, features, or other services.

This policy describes how TowZing and its affiliates collect and use personal information to provide our services. This policy applies to all users but may be supplemented by a separate privacy policy or statement for certain users that will be posted on the applicable app or website or otherwise provided to them.

This policy specifically applies to:

  • Customers: users who request and/or receive towing, fuel delivery, vehicle lockout, tire changes, battery replacements, jump starts and other automobile roadside assistance (“roadside assistance services”) through any TowZing app or website or by contacting TowZing by phone;
  • Drivers: users who provide roadside assistance services to Customers on behalf of a TowZing Alliance Member; and
  • TowZing Alliance Members: users who are sole proprietors or independent businesses that have signed up with the TowZing Alliance to provide roadside assistance services to TowZing

This policy also applies to those who provide information to TowZing in connection with a request for services via a telephone dial-in service or whose information TowZing otherwise receives in connection with its services.

For purposes of this policy, all those subject to this policy are referred to as “users.” We may also address users as “you.”

The practices described in this policy are subject to applicable laws in the place(s) in which TowZing operates for purposes of this policy. This means we only engage in the practices described in this policy in a particular jurisdiction if permitted under its laws. Please contact us if you have questions about our practices in your jurisdiction.

The Information We Collect.

SUMMARY

TowZing collects:

  • Information that you provide to TowZing or information provided to TowZing from our TowZing Alliance Members;
  • information created when you use our services, such as location, usage, and device information; and
  • information from other sources, such as TowZing’s affiliates and third parties that use TowZing APIs (Application Programming Interfaces).

I. Information you provide or provided from our TowZing Alliance Members.

This may include:

User profile: We collect information when you create or update your TowZing account or (if you are a Driver) when a TowZing Alliance Member creates or updates an account for you. This may include your name, e‑mail, phone number, login name and password, address, payment or banking information (including related payment verification information), government identification numbers, driver’s licenses or passport if required by law, birth date, vehicle license plate and vehicle identification number (VIN), photo, and signature. This may also include vehicle or insurance information of Drivers and TowZing Alliance Members and their vehicles (including license plates and VINs) that is provided to TowZing by our TowZing Alliance Members.

Background check information: We may collect background check information from TowZing Alliance Members. This information may be collected by us or a vendor on TowZing’s behalf.

Demographic data: We may collect demographic information about you, including through user surveys.

User content: We may collect information that you submit when you contact TowZing customer support, provide compliments or complaints for other users, or otherwise contact TowZing for any other reason not listed. All calls made to TowZing are recorded for supervision and training purposes.

II. Information created when you use our services.

This may include:

Location information: Depending on the TowZing services that you use, and your app settings or device permissions, we may collect your precise or approximate location information determined through data provided by various sources, such as GPS, IP address and WIFI.

  • If you are a Driver, TowZing collects location information when the TowZing app is running in the foreground or background of your device.
  • If you are a Customer and provided permission for the processing of location data, TowZing collects location information when the TowZing app is running in the foreground of your device, and in certain regions and under certain circumstances, TowZing also collects this information when the TowZing App is running the background of your device.

Transaction information: We collect transaction details related to your use of our services, including the type of roadside assistance service you requested or provided, your order details, delivery information, date and time the roadside assistance service was provided, amount charged, distance traveled, and payment method. If you use a promotional code, we may associate you with the use of the code.

Usage information: We may collect information about how you interact with our services, including information such as access dates and times, app features used or pages viewed, app crashes and other system activity, type of browser, third-party sites or services you used or were using before, while, or after interacting with our services. We utilize cookies, pixel tags, and similar technologies that create and maintain unique identifiers to provide this information. See below to learn more about the technologies TowZing uses.

Device information: We may collect information about the devices you use to access our services, including the hardware models, device IP address, operating systems, and versions, software, file names, preferred languages, unique device identifiers, adverting identifiers, serial number, device motion information, and mobile network information.

III. Information from other sources.

This may include:

  • User feedback;
  • users providing your information in connection with a referral or affiliate programs;
  • users requesting services for or on your behalf;
  • users or others providing information in connection with claims or disputes;
  • insurance providers;
  • financial services provider;
  • publicly available sources; and
  • marketing service providers.

How We Use Your Information.

SUMMARY

TowZing collects and uses information to enable reliable and convenient services. We also use the information we collect to:

  • Enhance the safety and security of our users and services;
  • provide customer support;
  • conduct research and development of future services and product offerings;
  • provide promotions or contests; and
  • in connection with legal proceedings or law enforcement investigation.

TowZing does not sell or share your personal information to third parties for third-party direct marketing purposes. If this changes for any reason, you’ll be notified of a change in our privacy policy on your first use of our services after such change or by any other commercially reasonable means.

I. Providing services and features.

TowZing uses the information we collect to provide, personalize, maintain, and improve our products and services. This may include:

  • Creating and updating your account;
  • verifying your identity;
  • enabling and facilitating roadside assistance services, including automated processing of information to provide accurate pricing based on the requested roadside assistance services;
  • processing or facilitating payment for roadside assistance services;
  • tracking the progress of roadside assistance services; and
  • performing internal operations necessary to provide our services, including troubleshooting software bugs and operation problems, conducting data analysis, testing, and research, and monitoring and analyzing usage and activity needs.

II. Safety and security.

We use your data to help maintain the safety, security, and integrity of our services and users. This may include:

  • Screening TowZing Alliance Members;
  • using information from users’ devices to identify the manner in which roadside assistance services are performed;
  • requiring TowZing Alliance Members to ensure that each Driver maintains an accurate self‑photo that is shared with our Customers to help to ensure that the person performing the roadside assistance services and using the app matches the Driver in the account we have on file; and
  • using Customer and Driver ratings to encourage improvement by affected users and as grounds for deactivating users with a rating below a certain minimum.

III. Customer support.

TowZing uses the information we collect, including recordings of customer support calls after notice to you and with your consent, to assist you when you contact our customer support services. This may include:

  • Directing your questions to an appropriate customer support person;
  • investigating and addressing your concerns; and
  • monitoring and improving our customer support responses.

IV. Research and development.

We may use the information we collect for testing, research, analysis, and development of our products and service. This allows us to improve and enhance the safety and security of our products and services, develop new features and products, and facilitate insurance finance solutions in connection with our services.

V. Legal proceedings and requirements.

We may use the information we collect to investigate or address claims or disputes relating to your use of TowZing’s services, a Customer’s use or roadside assistance services, a TowZing Alliance Member’s or Driver’s performance of roadside assistance services, or as otherwise allowed by applicable law.

Cookies and Third-Party Technologies.

SUMMARY

Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. We and our affiliates, and our and our affiliates’ vendors and other third parties, use cookies and other identification technologies on our and their websites, mobile applications, e-mail communications, advertising, and other online services and for a number of purposes including: authenticating users, remembering user preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services.

You have the right to choose whether or not to accept or remove cookies. However, they are an important part of how our services work, so you should be aware that if you choose to refuse or remove cookies, this could affect the availability and functionality of the services.

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 or to require your acceptance of each individual cookie. To do so, please follow the instructions provided by your browser, which are usually located within the “Help” or “Preferences” menu. Please note that removing or rejecting browser cookies does not necessarily affect third-party flash cookies, which may be used by us, affiliates, or third parties in connection with our services. To delete or disable flash cookies please visit this site  (https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html) for more information. For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit https://youradchoices.com/.

For mobile users, you usually have controls in your device’s Operating System that enables you to choose whether to allow cookies or share your advertising ID with companies like TowZing and our advertising service providers. For information on controlling your mobile choices, you can visit www.networkadvertising.org/mobile-choices.

To help control or block certain ads in mobile applications, you may choose to download and utilize the DAA mobile app, https://youradchoices.com/appchoices.

Information sharing and Disclosure.

SUMMARY

Some of TowZing’s products, services, and features require that we share information with other users, with our affiliates or third parties, or at your request. We may also share your information with our affiliates, subsidiaries and third parties, for legal reasons or in connection with claims or disputes.  Additionally, we may also share your information in an aggregated and/or anonymized form which cannot reasonably be used to identify you.

I. With other users.

If you are a Customer, we may share your first name, current location, make and model of your vehicle, vehicle license plate number and VIN, and your photo with a TowZing Alliance Member and one or more of its Drivers so that the TowZing Alliance Member and its Drivers can locate you. The vehicle’s VIN number may be shared with a TowZing Alliance Member and one or more of its Drivers to confirm the vehicle and vehicle specifications, including the proper anchor points for towing. Additionally, after services are rendered, a Driver may take photos of your vehicle, and those photos may be shared with the related TowZing Alliance Member to confirm completion of the requested service. These photos may also be used and/or shared with third parties, including insurance companies and law enforcement agencies, in connection with investigations for claims, disputes or by request of law enforcement.

If you are a Driver, we may share your information with Customers, including your name and photo, license plate number, vehicle photo, location, an average rating provided by other users, and contact information (depending on applicable laws). Customers may also see what TowZing Alliance Member you are deployed from. The Customer will also receive a receipt containing information such as a breakdown of the amounts charged, your first name and photo, and the related TowZing Alliance Member. We may also share your location information and other information with the TowZing Alliance Member from which you were deployed.

II. At your request.

If you requested roadside assistance services through a promotional offering made by a third party, TowZing may share your information with that third party.

III. As required to provide location-based services.

TowZing utilizes a number of third-party services to provide accurate location-based on-demand services. For us to provide adequate services, your current and/or approximate location will be shared via APIs with our third-party service providers, which may include Google Maps.

IV. With TowZing subsidiaries and affiliates.

We may share information with our subsidiaries and affiliates for marketing purposes and to help us provide our services or conduct data processing on our behalf. For example, TowZing affiliates may answer or make customer support phones call on behalf of TowZing, and information shared by you during such calls will be disclosed to TowZing and, if necessary to provide services, the TowZing Alliance Members and Drivers or Customer (as applicable).

We may also share information with our subsidiaries and affiliates to market and promote their services and products to users.

V. With TowZing service providers and other businesses.

TowZing may provide information to its vendors, consultants, marketing affiliates, research firms, and other service providers or other businesses. This may include:

  • Payment processors and facilitators;
  • background check providers;
  • cloud storage providers;
  • market partners and marketing platform providers;
  • data analytics providers;
  • using your vehicle’s VIN to confirm and obtain vehicle information, including proper towing anchor points and other vehicle specifications;
  • consultants, lawyers, accountants, and other professional service providers;
  • insurance vendors, brokers, and companies; and
  • financing sources.

VI. For legal reasons or in the event of a dispute.

TowZing may share your information if we believe it is required by applicable law, regulation, legal process or government request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing your information with law enforcement officials, government authorities, insurance providers, or other third party or third parties as necessary pursuant to or to enforce this policy, any supplemental privacy statements, our Terms and Conditions of Use, any other policies or terms and conditions, any other agreements into which we may enter with you (including, in the case of TowZing Alliance Members, any agreements into which you may have entered to join the TowZing Alliance). We may also share your information to protect TowZing’s rights or property or the rights, safety or property of others (including other users), or in the event of a claim or dispute relating to your use of our services. If you are using another person’s credit card, we may be required by law to share information with that credit card holder, including service information.

This section also covers sharing your information with others in connection with or during negotiations of any merger, sale of company assets, consolidation or financing, or acquisition of all or a portion of our business by or into another company.

Information Retention and Deletion.

TowZing retains user profile and other information for as long as you maintain your TowZing account.

TowZing retains transaction, location, usage, and other information for up to 5 years from date of termination in connection with regulatory, tax, insurance, or other requirements in the place in which it operates. TowZing thereafter deletes or anonymizes such information in accordance with applicable laws.

A user may request deletion of its accounts at any time. Following such request, TowZing deletes the information that it is not required to retain and restricts access to or use of any information it is required to retain. In certain circumstances, TowZing may be unable to delete your account such as, if there is an outstanding credit or balance on your account or your account relates to an unresolved claim or dispute.

You may request that TowZing provide a detailed explanation regarding the information TowZing has collected about you, and how it uses that information. You can make requested by contacting us at legal@towzing.com.

California Privacy Rights.

California law permits residents of California to request certain details about their information and how it is shared with third parties for direct marketing purposes. TowZing does not share your personally identifiable information with third parties for third parties’ direct marketing purposes unless you provide us with consent to do so.

Marketing Opt-Out.

You may opt out of receiving promotional e‑mails from TowZing and its subsidiaries and affiliates here. You may also opt out of receiving e‑mails and other messages by TowZing by following instructions in those messages. Please note that if you opt out, we may still send you non-promotion messages, such as receipts for your services or information about your account.

Updates to This Policy.

We may occasionally update this policy. If we make significant changes, we will notify you of the changes through one of the TowZing apps, the TowZing website, or other means such as e‑mail. To the extent permitted under applicable law, by using any of TowZing’s services after such change or notice, as applicable, you consent to all such updates to this policy. We encourage you to periodically review this policy for the latest information on our privacy practices.