MOWR RENTR’S PRIVACY POLICY
 
1.      Applicability.
This Policy applies to Users of Mowr’s services anywhere in the world, including Users of Mowr’s apps, websites, features, or other services.
 
1.1.   This Policy describes how Mowr and its affiliates collect and use personal data. This Policy applies to all Users of our apps, websites, features, or other services anywhere in the world, unless covered by a separate privacy policy. This notice specifically applies to:
 
Users: individuals who rent or host rental services, including those who receive services requested by another individual; and
 
1.2.   This Policy also governs Mowr’s other collections of personal data in connection with Mowr’s services. We may also collect the personal data of those who start but do not complete applications to be service providers.
 
1.3.   All those subject to this Policy are referred to as “Users” in this Policy.
 
1.4.   Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. Please contact us with any questions regarding our practices in a particular country or region.
 
2.      Data Control and Transfer. Mowr Technologies, LLC is the data controller for the personal data collected in connection with use of Mowr’s services anywhere in the world.
2.1.   Mowr operates, and processes data, throughout the United States. We may also transfer data to countries other than the one where our Users live or use Mowr’s services. We do so in order to fulfill our agreements with Users, such as our Terms of Use, or based on Users’ prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses.
 
3.      Data We Collect.
3.1.   Mowr collects:
3.1.1.      Data provided by Users to Mowr, such as during account creation;
 
3.1.2.      Data created during use of our services, such as location, app usage, and device data;
 
3.1.3.      Data from other sources, such as Mowr partners and third parties that use Mowr APIs.
 
3.2.   The following specific data is collected by or on behalf of Mowr: This includes:
3.2.1.      User profile: We collect data when Users create or update their Mowr accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of Host’s, emergency contact information, User settings, and evidence of health or fitness to provide services using Mowr apps. This also includes gender and/or occupation (only when required to provide a service).
 
3.2.1.1.            We may use the photos submitted by Users to verify their identities, such as through facial recognition technologies.
 
3.2.2.      Background check and identity verification: We collect background check and identity verification information for Host’s and other service providers. This may include information such as driver history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on Mowr’s behalf.
 
3.2.3.      Demographic data: We may collect demographic data about Users, including through User surveys. In some areas, we may also receive demographic data about Users from third parties.
 
3.2.4.      User content: We collect the information Users submit when they contact Mowr customer support, provide ratings or compliments for Host’s, or otherwise contact Mowr. This may include feedback, photographs or other recordings collected by Users.
 
3.3.   Data Created During Use Of Our Services. This includes:
 
3.3.1.      Location data (Mower): Mowr collects this data when the Mowr app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.
 
3.3.2.      Location data (Users and service recipients). We collect precise or approximate location data from Users’ and service recipients’ mobile devices if they enable us to do so. Mowr collects this data from the time a Mow is requested until it is finished, and any time the app is running in the foreground of their mobile device. We use this data to enhance your use of our apps, including to improve services, enable safety features, and prevent and detect fraud. Mowr collects Mower location data, and links location data collected during a Mow with their User’s account, even if the User has not enabled us to collect location data from their device. This enables us to offer services to the User like receipt generation and customer support.
 
3.3.3.      Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, service information, date and time the service was provided, amount charged, square items rented, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.
 
3.3.4.      Usage data: We collect data about how Users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
 
3.3.5.      Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
 
3.3.6.      Communications data: We enable Users to communicate with each other and Mowr through Mowr’s mobile apps and websites. For example, we enable Host’s and Users to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, Mowr receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Mowr may also use this data for customer support services (including to resolve disputes between Users), for safety and security purposes, to improve our products and services, and for analytics.
 
3.4.   Data from other sources. This includes:
3.4.1.      User feedback, such as ratings, feedback, or compliments.
 
3.4.2.      Users participating in our referral programs. For example, when a User refers another person, we receive the referred person’s personal data from that User.
 
3.4.3.      Mowr account owners who request services for or on behalf of other Users, or who enable such Users to request or receive services through their accounts.
 
3.4.4.      Users or others providing information in connection with claims or disputes.
 
3.4.5.      Mowr business partners through which Users create or access their Mowr account, such as payment providers, social media services, or apps or websites that use Mowr’s APIs or whose APIs Mowr uses.
 
3.4.6.      Vendors who help us verify Users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
 
3.4.7.      Insurance, vehicle, or financial services providers for Host’s and/or other service providers.
 
3.4.8.      Partner lawncare companies (for Host’s who use our services through an account associated with such a company).
 
3.4.9.      Publicly available sources.
 
3.4.10.  Marketing service providers.
 
3.5.   Mowr may combine the data collected from these sources with other data in its possession.
 
4.      How We Use Personal Data: Mowr collects and uses data to enable reliable and convenient lawncare and lawnmowing services. Broadly, we use the data we collect for the following purposes: to enhance the safety and security of our Users and services; for customer support; for research and development; to enable communications between Users; to send marketing and non-marketing communications to Users; in connection with legal proceedings.
 
4.1.   Mowr uses the data it collects for purposes including:
 
4.1.1.      Providing services and features. Mowr uses the data we collect to provide, personalize, maintain, and improve our products and services. This includes using the data to:
a.       Create and update Users’ accounts.
 
b.      Verify Host’s’ identity, background history, and eligibility to work.
 
c.       Enable lawncare and lawnmowing services.
 
d.      Offer, process, or facilitate payments for our Services.
 
e.       Offer, obtain, provide, or facilitate insurance, vehicle, invoicing, or financing solutions in connection with our services.
 
f.        Track and share the progress of Mows.
 
g.      Enable features that allow Users to share information with other people, such as when Users submit a compliment about a Mower or refer a friend to Mowr.
 
h.      Enable features to personalize Users’ Mowr accounts.
 
i.        Enable Accessibility features that make it easier for Users with disabilities to use our services, such as those that enable deaf or hard-of-hearing Host’s to alert their Users of their disabilities, allow only text messages from Users, and enable receipt of flashing Mow request notifications instead of sound notifications on their mobile device.
 
j.        Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
 
4.2.   Safety and Security. We use personal data to help maintain the safety, security, and integrity of our services and Users. This includes:
 
4.2.1.      Screening Users and Host’s before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe Host’s and/or Users.
 
4.2.2.      Using data to help identify unsafe behavior such as aggression, yelling, and poor conflict resolution, and to inform them of safer and kinder practices. We also use data from Host’s’ devices to verify the type of vehicles and equipment they used to provide services.
 
4.2.3.      In certain regions, using information derived from driver’s license photos, and other photos submitted to Mowr, for safety and security purposes. This also includes comparing photographs that we have on file against photographs (i) of other Users to prevent identity-borrowing, and (ii) from public databases to verify User identity.
 
4.2.4.      Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
 
4.2.5.      Using User ratings and feedback to encourage compliance with our Required Conduct and as grounds for deactivating Host’s and Users with low ratings or who otherwise violated such guidelines in certain countries.
 
4.3.   Customer Support. Mowr uses the information we collect (including recordings of customer support calls with notice to and the consent of the User) to provide customer support, including to:
 
4.3.1.      Direct questions to the appropriate customer support person.
 
4.3.2.      Investigate and address User concerns.
 
4.3.3.      Monitor and improve our customer support responses and processes.
 
4.4.   Research and Development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the User experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.
 
4.5.   Enabling communications between Users. For example, a Mower may message or call a User to confirm a Mow location or User may contact a driver to retrieve a lost item.
 
4.6.   Marketing. Mowr may use the data we collect to market our services to our Users. This includes sending Users communications about Mowr services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.
 
We may also send communications to our Users about products and services offered by Mowr partners. We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on User location, past use of Mowr’s services, and User preferences and settings. We may also send Users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services.
 
4.7.   Non-Marketing Communications. Mowr may use the data we collect to generate and provide Users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Mowr or its partners.
 
4.8.   Legal Proceedings And Requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Mowr’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
 
4.9.   Automated Decision-Making. We use personal data to make automated decisions relating to use of our services. This includes:
 
4.9.1.      Enabling dynamic pricing, in which the price of a Mow is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic, and the number of Users and Host’s using Mowr at a given moment.
 
4.9.2.      Matching available Mowrs to Users requesting services. Users can be matched based on availability, proximity, and other factors.
 
4.9.3.      Determining Mowr ratings, and deactivating Host’s and Users.
 
4.9.4.      Deactivating Users who are identified as having engaged in fraud or activities that may otherwise harm Mowr, its Users, and others. In some cases, such as when a User is determined to be abusing Mowr’s referral program, such behavior may result in automatic deactivation.
 
4.9.5.      Using Mower location information, and communications between Users and drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a Mower is delaying a User pickup in order to induce a cancellation, we will not charge the User a cancellation fee and will adjust the amounts paid to the Mower to omit such a fee. To object to such adjustment, please contact Mowr customer support.
 
5.      Cookies And Third-Party Technologies. Mowr and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this Policy. Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Mowr uses cookies and similar technologies for purposes such as: 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.
 
We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.
 
6.      Data Sharing And Disclosure. Some of Mowr’s products, services, and features require that we share data with other Users or at a User’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes. Mowr may share the data we collect:
 
6.1.   With other Users. This includes sharing:
 
6.1.1.      Users’ first name, rating, and services location with Host’s.
 
6.1.2.      For Host’s, we may share data with the User including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during Mow); average rating provided by Users; total number of Mows; length of use of the Mowr app; contact information (depending upon applicable laws); and Mower profile, including compliments and other feedback submitted by past Users.
 
6.1.3.      We also provide Users with receipts containing information such as a breakdown of amounts charged, Mowr first name, photo, Mow location, and such other information required on invoices in the country or region where the driver or delivery person operates.
 
6.2.   At the User’s Request. This includes sharing data with:
 
6.2.1.      Other people at the User’s request.
 
6.2.2.      Mowr business partners. If a User requests a service through a partnership or promotional offering made by a third party, Mowr may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; those with an API or service with which we integrate; or other Mowr business partners and their Users in connection with promotions, contests, or specialized services.
 
6.3.   With The General Public. Questions or comments from Users submitted through public forums such as Mowr blogs and Mowr social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a User.
 
6.4.   With The Mowr Account Owner. If a User requests services or places an order using an account owned by another party, we may share their order information, including real-time location data, with the owner of that account.
 
6.5.   With Mowr Subsidiaries And Affiliates. We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Mowr processes and stores data in the United States on behalf of its international subsidiaries and affiliates.
 
6.6.   With Mowr Service Providers And Business Partners. Mowr provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These may include: (a) payment processors and facilitators; (b) background check and identity verification providers; (c) cloud storage providers; (d) Google, in connection with the use of Google Maps in Mowr’s apps (see Google’s privacy policy for information on their collection and use of data); (e) Facebook, in connection with the use of the Facebook Business Tools in Mowr’s apps and websites (see Facebook’s privacy policy for information on their collection and use of data); (f) marketing partners and marketing platform providers, including social media advertising services; (g) data analytics providers; (h) research partners, including those performing surveys or research projects in partnership with Mowr or on Mowr’s behalf; (i) vendors that assist Mowr to enhance the safety and security of its apps; (j) consultants, lawyers, accountants, and other professional service providers; and (k) insurance and financing partners.
 
6.7.   For Legal Reasons Or In The Event Of A Dispute. Mowr may share Users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.
 
This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, User agreements, or other policies; to protect Mowr’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.
 
This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
 
6.8.   With Consent. Mowr may share a User’s personal data other than as described in this notice if we notify the User and they consent to the sharing.
 
7.      Data Retention And Deletion.
 
7.1.   Mowr retains User data for as long as necessary for the purposes described above.
 
7.2.   Users may request deletion of their accounts at any time. Mowr may retain User data after a deletion request due to legal or regulatory requirements or for the reasons stated in this policy.
 
7.3.   Mowr retains User data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the category of User to whom the data relates, the type of data, and the purposes for which we collected the data.
 
7.4.   Following an account deletion request, Mowr deletes the User’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the User’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to Host’s and other service providers, this generally means that we retain their account and data for a minimum of 7 years after a deletion request.
 
7.5.   For Purposes Of The Legitimate Interests Of Mowr Or Other Parties. This includes using personal data to maintain and enhance our Users’ safety and security. For example, we use personal data to prevent use of our services by Users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned Users to prevent their use of Mowr’s apps. We also use usage data to prevent matching of Users and Host’s for whom there is higher risk of conflict (for instance, because they have been the subject of prior complaints from other Users). This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing Mowr’s Terms of Service. In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.
 
7.6.   To Fulfill Mowr’s Legal Obligations. Mowr is subject to laws and regulations in many cities and countries that require it to collect and retain data about our Users’ trips and deliveries, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws. Mowr may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. Mowr may also share information with public health authorities where required or permitted by law.
 
8.      Choice And Transparency. Mowr enables Users to access and control the data that Mowr collects, including through in-app settings; device permissions; in-app ratings pages; and marketing opt-outs. Mowr also enables Users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that Mowr restrict its processing of User personal data.
 
9.      Updates To This Policy. We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law. If we make significant changes, we will notify Users in advance of the changes through the Mowr apps or through other means, such as email. We encourage Users to periodically review this notice for the latest information on our privacy practices.
 
 

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