PROTECTING YOUR PRIVACY

At RepairShare, Inc. ("RepairShare", "we" or "our"), we take protecting your privacy seriously. In order for our websites, mobile applications, products, and services (collectively, "services") to function properly, we need to collect and use some of your Personal Information. We want you to understand what Personal Information we collect and how we use it. This Policy is incorporated as part of the Terms of Service that apply to your use of the services. When you use our services, you acknowledge that you have accepted the Terms of Service and this policy without exception. You also acknowledge that you consent to our privacy practices, including our use and disclosure of your Personal Information. If you do not consent to the Terms of Service or this Policy, please do not use our services or provide any Personal Information.

WHAT OUR PRIVACY POLICY COVERS

This Policy covers any RepairShare-affiliated site, product, or service which links to this Policy and any collection, storage, transfer, sharing, disclosure and handling of your Personal Information when you use our services which we define below. This Policy does not cover, and we are not responsible for, third-party websites or applications that may be linked from our services; linking to them does not imply an endorsement. We are not responsible for these websites or applications or any information they may collect. You should always review the privacy policy of any third-party website or application that collects your Personal Information

When you use our services, we may collect the below types of Personal Information:

• Name;
• Mailing address;
• Email address;
• Cell phone number;
• Electronic Serial Number ("ESN") or International Mobile Equipment Identity ("IMEI") data;
• Device serial number and media access control ("MAC") address;
• Records of products or services you have purchased from us;
• Any information that you provide as part of filing a claim;
• As part of the claim process, RepairShare or its affiliates may require you to provide a copy of your driver’s license, passport, or other personal identification card;
• Shipping and billing information, credit card information or other preferred payment means;

RepairShare may also draw inferences from the Personal Information we collect from you to potentially offer products or services that we believe would be a good fit for you (Note: at any time you may choose to withdraw your consent to RepairShare’s use or disclosure of your Personal Information for marketing and promotional purposes by contacting RepairShare as outlined in "Contacting RepairShare" below.

Password Management Features

A feature of certain RepairShare mobile applications allow you to share your passwords with the application for safekeeping. Any passwords that you share are not visible by, transmitted to, or stored by RepairShare in clear text. They are saved on your device, with only an encrypted copy being sent to RepairShare for which we do not have the decryption key. This allows you to use the application seamlessly on multiple devices, without your password leaving your device in a usable format.

Using a Third-Party Account on our Services

If you use a third-party service (such as Google or other social media platform) to create an account, we may receive Personal Information that you allow such third-party service to share with us such as your name, e-mail address, profile picture, or other Personal Information.

Log Information

RepairShare also automatically gathers and stores certain information in our server logs about the use of RepairShare’s services, including the number of unique visitors, the frequency of visits, how users interact with our services, user experience preferences, and other information that may help RepairShare improve the user experience, mitigate fraudulent activity, and comply with legal requirements. Such information may include Personal Information such as: IP address, Unique Device Identifier, CallerID / ANI (Automatic Number Identification) information, content of web pages, transaction with APIs (Application Program Interface), transactions with IVR (Interactive Voice Response) systems, activity and content of visitor interaction with call center representatives; application usage activity, hardware information, hardware and system settings, browser type, browser language, length of call, participant added to or exited from a call, the date and time of your request or call, or referral URL.

Cookies, Pixel Tags, and Other Tracking Technologies

RepairShare and its partners use cookies or similar technologies, such as Google Analytics, on our websites and mobile applications to analyze trends, administer the website, track users’ movements around the website. Google Analytics uses third-party cookies to collect standard internet log information and visitor behavior information.  The information generated by the cookie about your use of this website, including your IP address, is transmitted to Google. This information is used to evaluate visitors’ use of the website and to compile website activity statistical reports for us. We do not use the statistical analytics tool to track or to link an IP address with the identity of a computer user. If you do not want any information to be collected and used by Google Analytics, you may be able to install an opt-out open_in_new add-on to your web browser. You may learn more about how Google collects and uses personal information at "How Google uses data when you use our partners’ sites or apps" open_in_new.

We also use these technologies to tailor and deliver advertising that may be more relevant or interesting to our users, and gather demographic information about our user base as a whole.

A cookie is a small data file that is managed by your web browser or other application and stored on your local system. RepairShare uses session and persistent cookies to, among other things, identify your device during a particular interaction, analyze your behavior during a particular visit, and serve you advertising.

Pixel tags, also known as web beacons, help RepairShare better manage user experience and content tracking. They also assist us in serving you advertising, including re-engaging you if you have searched for, viewed, and/or purchased our products or similar products. Pixel tags are tiny graphics with a unique identifier, which provide a similar function to cookies and are used to track user interaction with content provided by RepairShare, an affiliate organization, or non-affiliated companies to assist us in providing, maintaining and operating our marketing. In contrast to cookies, which are stored on a user’s device hard drive, pixel tags are embedded within content. The small size and transparency of pixel tags are not intended to deceive content recipients, but rather minimize distraction. You may opt out of third-party cookies or similar tracking technologies used to serve you targeted advertising based on the Personal Information (e.g., device information) in our cookie banner or, if you are a California consumer, by following the "Sale of Personal Information" instructions contained in the Your California privacy rights section of this Policy.

You can also elect to block all cookies from first parties (such as RepairShare) and from third parties (such as entities involved in advertising) by using the cookie blocking options built into your browser software. The methods for doing so vary from browser to browser, and from version to version. Please note, however, that if you do decide to block cookies or similar technologies, some parts of RepairShare’s websites may not function correctly. In any case, you can make decisions and take steps about your privacy and the adverstisements you receive. In addition, associations in the digital advertising ecosystem provide methods for opting out of interest-based advertising (i.e., advertising that’s been customized based on predictions about your interests generated from your visits to different websites).

Third-party data sources

RepairShare may leverage external data sources in order to provide context and background on the users of its services in order to improve customer experience, mitigate fraud or malicious activity, or comply with internal company and external regulatory requirements.

Personal Information we collect from Technical Data

When you install and use certain elements of our services, such as a mobile or web application, browser plug-in, or Alexa skill, we may collect the below types of Technical Data, which may include:  

• Telephony data, i.e. your network type, network operator name, subscriber identity module ("SIM") operator name, SIM country;
• Carrier name;
• Operating system version;
• Device model;
• Performance and data usage, i.e. data storage amount, Central Processing Unit ("CPU") and memory consumption;
• Battery status and battery usage patterns and power consumptions
• Lists of other installed applications;
• Listing of types (i.e. Gmail, Yahoo, etc.) of other email accounts configured to your device;
• Device information related to your choice of settings for your device such as Global Positioning System ("GPS") settings, and Bluetooth settings;
• Geolocation information, if you enable this on your device operating system and are you using a location-based service. You may turn this off at any time within the device settings;
• Copies of information that you choose to backup from your device, including any related metadata; and
• Aggregated, anonymous non-public Personal Information.

How we use your Personal Information

RepairShare may use your Personal Information to:

1. Fulfill a service to you;
2. Establish and verify your identity;
3. Handle and resolve billing disputes;
4. Monitor and maintain the performance and functionality of the device consistent with your choices;
5. Activate and maintain your account;
6. Provide technical support and click-to-chat functionality;
7. Provide information back-up services;
8. Protect and improve our services;
9. Offer updates, notices, invitations to participate in online, verbal or video surveys, and other information about applications and services available from RepairShare or its affiliates as permitted by law. (Note: at any time you may choose to withdraw your consent to RepairShare’s use or disclosure of your Personal Information for marketing and promotional purposes by contacting RepairShare as outlined in  section of this Policy);
10. Respond to your questions, inquiries, comments and instructions;
11. To enforce the applicable Terms of Service;
12. Comply with the law and defend our rights;
13. Track and analyze de-identified data and provide such data to third parties that provide services to RepairShare;
14. Protect against fraud and potential fraud;
15. Notify you of any known breach of your Personal Information; and
16. Maintain the security and integrity of RepairShare’s systems and services.

Password Management

For certain RepairShare mobile applications that allow you to share your passwords with the application for safekeeping, you may choose to allow the application to identify other email accounts that you may want to include in your use of the application. As such, if you allow the mobile application to scan an email account, no connections are made to any other server other than the selected email account. The sign-in and authentication takes place using your device’s account manager system. The mobile application will never see or transmit your password and instead will use a token to log into that account. After signing-in, the app will only look at the mail headers and messages to extract the service name, service URL, and username. No information is transmitted to any server at any point of the process of the extraction. The extracted information is stored in the local application memory of the device on which it is run and only for that duration, and it is deleted immediately after results are shown.

Communications Tools

Certain RepairShare services may collect audio, text, or video to allow you to communicate with us or another individual (e.g., a friend or family member). These communications tools enable you to send and receive messages, share your screen, make and receive video chats, or add us to your conversation to provide our services (e.g., tech support). After your communication ends, we will not store or review the contents of a communication if we are not a participant in the communication. If we are a participant in the communication, we may store and review the text or audio content of your communication with us according to the purposes described in this Policy. We may also review the Technical Data (e.g., device model, operating system) and Log Information (e.g., length of call, participant added to or exited from call) collected from your use of our communications tools for these same purposes.

HOW WE SHARE YOUR PERSONAL INFORMATION

We will not use or disclose your Personal Information to non-affiliated third parties except as disclosed in this Policy.

RepairShare may transfer or license your Personal Information to:

• Non-affiliated companies to assist us in providing, maintaining and operating our services or marketing. These companies are required to comply with the principles set out in this Policy and only use such information for the purposes for which it was provided to them;

• A third-party, in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of its business or of any assets or shares of our business or a division thereof in order for you to continue to receive the same or similar products and services from the third-party. In such an event, we will provide notice of any material change to this Policy, or our Services, in the manner described in this Policy. In these circumstances, Personal Information may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business.

RepairShare may also disclose your Personal Information to:

• Comply with the law and/or legal process in which a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order, or judicial or administrative proceeding);

• Defend our rights and/or property or the rights and property of others;

• Enforce our Terms of Use and/or this Policy;

• Respond to claims that the content(s) of a communication violates the rights of another; or

• Detect, prevent or otherwise address fraud, security, or technical issues.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We use commercially reasonable, industry standard technical, administrative, and physical controls to protect your Personal Information, including data encryption where appropriate; however, since the internet is not a 100% secure environment, we cannot ensure the security of information during its transmission between you and us. Accordingly, you acknowledge that when you transmit such information, you do so at your own risk. We will notify you of any confirmed security breach of your Personal Information to the extent required by and in accordance with state and federal law.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

RepairShare will retain your Personal Information as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or not prohibited by applicable law.

HOW YOU ARE NOTIFIED IF THE POLICY CHANGES

We may change this Policy from time to time. If we do, we will post the updated Policy with the last revised date. Your continued use of our services means that you consent to the updates. You should periodically read the Policy to understand our privacy practices.

If we make material changes to this Policy, we will notify you in the website, product, service, or application or by email and seek your affirmative consent where required. 

COMMUNICATING WITH YOU ELECTRONICALLY

By using our services, you agree that we can communicate with you electronically. This includes any required notifications (i.e., legal, technical, regulatory, security, or privacy) relating to your use of the services.

COMMERCIAL MESSAGES

Where required, RepairShare will seek your express consent to send you such messages. This consent is sought by RepairShare, Inc. You may withdraw your consent by using the "unsubscribe" link located in the Where to turn with questions section of this Policy.

YOUR RIGHTS RELATED TO YOUR PERSONAL INFORMATION

While we take various steps to ensure the accuracy and completeness of your Personal Information, we rely upon you to provide accurate and complete information when interacting with us.

Upon your request and as allowed or required by law and consistent with our applicable partner agreements, you may request RepairShare to take the following actions with your Personal Information: (i) provide you with a copy, (ii) correct, (iii) update, or (iv) delete. To make such a request, or if you have a privacy-related complaint, please contact RepairShare.

SOCIAL MEDIA

Please be aware that any information that you submit to a social media website such as Facebook, Instagram or Twitter is done at your own risk and without any expectation of privacy. RepairShare cannot control the actions of social media website users and is not responsible for any content or submissions contained on such websites. You should always review the privacy policy of any third-party website, product, service, or application.

By using any functionality that permits submissions to social media websites, you are indicating that you have reviewed the applicable privacy policy and terms of use of that website. Additionally, in the event that we offer functionality through our services that permits the posting of content on social media, please be aware that these websites may allow you to publicly post and share this content. RepairShare cannot guarantee the privacy and safety of these websites and is therefore not responsible for any content you post. Use these features at your own risk.

CHILDREN UNDER 13

Our services are not directed to children under 13. We do not knowingly collect Personal Information from children under 13. If you become aware that your child is accessing the services and providing Personal Information without your consent, please contact us by using the information provided below. We will take steps to remove Personal Information from our storage systems and terminate the account if we determine that a child under 13 has accessed the services.

FOR NON-U.S. RESIDENTS

We may transfer Personal Information that we collect about you outside of the country in which it was collected. If you are visiting from the European Union or other region with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information about yourself, including your Personal Information, to a country and jurisdiction that does not have the same data protection laws in place as the European Union or other region. By doing so, you are consenting to the transfer of information about yourself, including your Personal Information, to the United States, as described in this Policy.

YOUR CALIFORNIA PRIVACY RIGHTS

CALIFORNIA SHINE THE LIGHT LAW

California residents may opt-out of RepairShare disclosing their Personal Information to third parties for their marketing purposes. If you are a California resident and do not want RepairShare to disclose your information to third parties for their marketing purposes, please contact RepairShare by any of the ways described in the Where to turn with questions section below and RepairShare will respond within 30 days.

CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

The CCPA provides privacy protections for California consumers through the provision of certain disclosures and granting of specific rights. If you are a California consumer, the following sections provide you with these disclosures and information about your rights and how to exercise them, should you choose to do so.

Categories of Personal Information we collect

Identifiers: Name, mailing address, email address, cell phone number, electronic serial number ("ESN") or International Mobile Equipment Identity ("IMEI"), device serial number, and media access control ("MAC" address), CallerID / ANI (Automatic Number Identification) information

California Customer Records personal information categories: Name, mailing address, email address, cell phone number, electronic serial number ("ESN") or International Mobile Equipment Identity ("IMEI"), device serial number, media access control ("MAC") address, CallerID / ANI (Automatic Number Identification) information, and financial information such as credit card number and debit card number

Protected classification characteristics under California or federal law: Demographic information including age, marital status, and sex (including gender)

Commercial information: Records of products or services you have purchased from us, responses to online, verbal or video surveys

Biometric information: A scan of driver’s license, passport, or other personal identification card to identify fraud in the claims process, or face scans should you download and use an RepairShare photography mobile application

Information we collect when you visit our websites: IP address, unique device identifier, the content of web pages, transactions with APIs (Application Program Interface), hardware information, hardware and system settings, browser type, browser language, length of call, participant added to or exited from a call, the date and time of your request or call, referral URL, cookies, and pixel tags Information we collect from Technical Data: your network type, network operator name, subscriber identity module ("SIM") operator name, SIM country, carrier name, operating system version, device model, performance and data usage (i.e., data storage amount, Central Processing Unit ("CPU") and memory consumption); battery status, battery usage patterns, power consumptions, lists of other installed applications, listing of types (i.e., Gmail, Yahoo, etc.) of other email accounts configured to your device, device information related to your choice of settings for your device such as Wi-Fi, Global Positioning System ("GPS") settings, and Bluetooth settings, and copies of information that you choose to backup from your device, including any related metadata Information we collect when we scan your Wi-Fi network: Internet service provider’s name, Wireless network’s name, Information about the capabilities of your Wi-Fi network, such as type of internet connection, make and model of your router, and maximum download and upload speed, Information about the health of your Wi-Fi network, such as measured levels of congestion, packet loss, jitter, latency, and throughput, IP addresses or any other identifiers of any devices that are connected to the network, and Information about each device’s internet usage, such as the device’s signal strength from the router and the maximum speed at which your device can operate with respect to your router

Geolocation Information: GPS, cell tower, and Bluetooth location data if you enable geolocation on your device operating system and are you using a location-based service. You may turn this off at any time within the device settings

Sensory information: Audio information from customer interactions with call center representatives, photos or videos should you download and use an RepairShare photography mobile application, or photos of your device taken by a service provider to confirm that it was damaged and has been repaired, and audio, text, or video information from your use of our communications tools

Inferences from Personal Information: Inferences we draw from the Personal Information we collect from you to potentially offer products or services that we believe would be a good fit for you

Categories of sources of Personal Information

We collect Personal Information from the following categories of sources:

• Directly from you;
• Partners and affiliates that assist us in providing products and services to you;
• Non-affiliated companies to assist us in providing, maintaining and operating our services or marketing; and
• Non-affiliated companies that provide us with demographic information.

Business purposes for collecting Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• Fulfill a service to you;
• Establish and verify your identity;
• Handle and resolve billing disputes;
• Monitor and maintain the performance and functionality of the device consistent with your choices;
• Activate and maintain your account;
• Provide technical support and click-to-chat functionality;
• Provide information back-up services;
• Protect and improve our services;
• Offer updates, notices, invitations to participate in online, verbal or video surveys, and other information about applications and services available from RepairShare or its affiliates as permitted by law. (Note: at any time you may choose to withdraw your consent to RepairShare’s use or disclosure of your Personal Information for marketing and promotional purposes by contacting RepairShare as outlined in  section of this Policy);
• Respond to your questions, inquiries, comments and instructions;
• To enforce the applicable Terms of Service;
• Comply with the law and defend our rights;
• Track and analyze de-identified data and provide such data to third parties that provide services to RepairShare;
• Protect against fraud and potential fraud;
• Notify you of any known breach of your Personal Information; and
• Maintain the security and integrity of RepairShare’s systems and services.

Disclosure of Personal Information for a business purpose

We may disclose your Personal Information to the following categories of third parties:

• Non-affiliated companies to assist us in providing, maintaining and operating our services or marketing. These companies are required to comply with the principles set out in this Policy and only use such information for the purposes for which it was provided to them; and
• A third-party, in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of its business or of any assets or shares of our business or a division thereof in order for you to continue to receive the same or similar products and services from the third-party. In such an event, we will provide notice of any material change to this Policy, or our Services, in the manner described in this Policy. In these circumstances, Personal Information may be shared with the actual or prospective purchasers or assignees, or with the newly acquired business.

In the preceding 12 months, we have disclosed the following categories of Personal Information to third parties for a business purpose:

• Identifiers;
• California Customer Records personal information categories;
• Protected classification characteristics under California or federal law;
• Commercial information;
• Biometric information;
• Internet or other similar network activity;
• Sensory information (i.e., audio information); and
• Inferences drawn (e.g., preferences) from Personal Information.

Sale of your Personal Information

We do not sell any Personal Information as the term is traditionally understood. However, under the CCPA, certain methods of advertising can be considered a sale of personal information to third parties that assist us in providing, maintaining and operating our marketing. This personal information includes the following categories:

• Identifiers;
• Internet or other similar network activity; and
• Inferences from personal information.

We may use this personal information to tailor and deliver advertising that may be more relevant or interesting to you, including serving targeted ads.

You may opt out of the sale of your personal information by contacting as provided in the Contacting RepairShare, Inc. section below.

In addition, if you visit our website, we engage in selling that may not identify you specifically, but rather the device you use. You may opt out of this type of selling by toggling off certain cookies or other similar technologies. This is done by navigating to the "Do Not Sell My Personal Information" link on our homepage, selecting "Sale of Personal Information" and toggling off "Targeting Cookies." You may also opt out of this type of selling by blocking and deleting cookies or similar technologies in your browser. Please note, however, that if you do decide to block cookies or similar tracking technologies, some parts of our sites may not function correctly.

We do not sell the personal information of individuals under the age of 16 if we have actual knowledge of the individual’s age.

Access to and deletion of your Personal Information

• Information Request: By submitting an information request, you may ask that RepairShare provide you with a copy of your Personal Information.
• Deletion Request: By submitting a deletion request, you may ask that RepairShare delete any of your Personal Information that we have collected about you and retained, subject to certain exceptions. These exceptions include but are not limited to the following: Providing a good or service that you requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise performing our contract with you; Detecting security incidents and protecting against fraud or illegal activity; Debugging products and services; Enabling solely internal uses that are reasonably aligned with consumer expectations; Complying with a legal obligation; and Making other internal and lawful uses of your Personal Information that are compatible with the context for which you provided it.

To make such an access or deletion request, please contact RepairShare at the address provided below.

ACCOUNTABILITY AND GOVERNANCE

RepairShare has implemented various measures to monitor compliance with and enforce this Policy.

CONTACTING REPAIRSHARE, INC.

If you have any questions about this Policy, about our website, product or service, or want to request access to, correction, or deletion of your Personal Information, or have a privacy-related complaint, you can contact RepairShare through our Contact Us web page.