Privacy Policy

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Last Updated: 21st November, 2023

Carly (“Carly,” “Company,” “we,” “us,” or “our”) believes that winning and keeping your trust is
important. As a result, we are dedicated to ensuring your privacy rights. This Privacy Statement
(“Statement”) informs you of how Carly collects, uses, distributes, or otherwise processes
information about natural persons (“Personal Data”), as well as how you can exercise your relevant
rights about such Personal Data. As stated later in this Statement, some parts of this Statement
apply solely to citizens of the state of California.

Changes to this privacy statement:

This Privacy Statement is subject to modification. Please read the “Last Updated” date placed at
the top of this page to find out when this Privacy Policy was last updated. Any modifications to
this Privacy Policy will take effect when we post the updated Privacy Policy on the Services, unless
otherwise specified. You accept the amended Privacy Policy if you continue to use the Services
after these changes. If you do not agree with these changes, you may contact us to have your
account closed.

Applicability and Scope:

This Statement applies to Carly’s processing of Personal Data when you:

i. Visit or use any services offered through this website https://www.carlyrental.com
(hereinafter the “Website.”)

ii. Use, download, or get access to any of our many internet-based products, including
paid or non-paid subscriptions, emails, mobile platforms, webinars, meetings,
initiatives, software, or apps (collectively, “Services”).

iii. becomes a host, visitor, or user of this Website.

iv. Apply for an employment opportunity with us.

v. Participate in social media conversations with Carly.

vi. Communicate with us by email, phone, or other means.

vii. Participate in or register for any of our events, seminars, networking/community
opportunities, and so on; or

viii. Otherwise, contact or interact with us.

This Statement covers whether you gave us Personal Data directly or we got it indirectly, including
from an alternate source, such as a third party. Additional privacy notifications may be given to
you in addition to this Statement.

Other Links:

It is vital to be aware that the Website and Services may contain connections to sites or offers run
by persons or businesses other than Carly. Such links, if appropriate, are given only to provide you
with information and convenience. Carly is not responsible for the content or conduct of such sites
or offers, nor for the safety or privacy of any information acquired by such third parties. You are
solely responsible for selecting the degree to which you may use any such information, and you
should study the appropriate privacy rules applicable to any third-party sites or products.

Collection of Information:

We collect three types of personal information:

i. personal information you provide to us;

ii. personal information obtained automatically as a result of your usage of the Services;
and

iii. private data from external sources or parties.

Data Provided by You:

Carly Account Information.

We require some personal information when you register for an
account with us, such as your name, email address, and password, in order to open your account.
Data from the profile. In order to use some aspects of the Services, we may additionally require
you to give additional personal information such as home addresses, telephone numbers,
driver’s license number, date of issuance and issuing nation and/or state, profile photographs,
employment, city, school, history, and date of birth. Certain sections of your profile (such as your
profile photographs, employer, city, school, and biography) will be available to others as part of
your public profile page.

Vehicle information.

We gather car-related information such as vehicle listing data, vehicle
identifying number (VIN), availability dates, reviews, and posted trip photographs.
Payment information. In connection with a possible or actual transaction, we gather your digital
payment details, financial institution accounts or credit/debit card numbers, and details of the
transaction, which may be processed and held by one or more third party provider of payment
services or digital payments corporations.

Data for identity verification.

We may collect identity verification information such as a
photograph or scanned copy of your driver’s license, passport, national ID card, or payment card,
the last four digits of your Social Security number, social insurance number, social media account
information, driver’s/motor vehicle record, insurance data, or other forms of identification
information in some cases.

Data from user research and surveys.

When you choose to engage in user research programs and/or
community surveys, we gather the information you submit. If you want to share it with us, this
may include your demographics.

Communications.

We gather data relating to your communication and any data you choose to
submit when you interact with us, whether by phone, email, or chat, or when you use the Services
to connect with other users.

Data which we automatically collect from you:

The use of data.
We collect information about how you use the Services, such as the pages and
other content you view, your search history, log-in information, bookings you’ve made, the length
of time you spend on a page or screen, websites you connect to or browse through within the
Services, paths you take between pages or screens, information you do on a page or screen, time
you spend using the Services, and other steps that you take on the platform. Information about
your use of the Website or Services is gathered automatically and passively through web logs using
various technologies, which may or may not individually identify you or other persons. IP
addresses, browser kinds, domain names, and other anonymous statistical data on aggregate usage
are some examples.

Data on location.
We may collect information about your approximate location (e.g., city/town
connected with your IP address) when you use certain features of the Services. We may acquire
exact location information from your mobile device if you choose to utilize our location sharing
function. Keep in mind that under the device’s settings menu, you may manage or prevent the
usage of location services by any programme on your mobile device. Where applicable, download
limitations or other similar consumption limits associated to your Carly account, login, email
address, registration, etc. Furthermore, if you choose to download and use any optional third-party
apps with the Services, we will identify and store the information required for you to operate the
third-party application properly.

Data from in-vehicle devices.

We may remotely gather information about a vehicle if it is enrolled
in any Carly operation or has a Carly device installed. This information may include GPS position,
car battery voltage, fuel level, odometer reading, malfunction indication bulb, door status, engine
state, and VIN, depending on the make, model, and year of the vehicle.

Data from the device and the trip itself.

We get information about your computer or mobile device,
such as the operating system type and version number, the manufacturer and model, the browser
type, screen image quality, IP address, unique device identifiers, or general data about your
location, such as city, state, or geographic region. We gather transactional information about the
journeys you take using the Services, such as the date and time of your trip, the amounts charged,
and other trip-related facts.

Cookies, tracking technologies, and other electronic tools are used. A “cookie” is a short text file
with a unique identifier that is stored on a browser or internet device and is used to collect limited
information about your online preferences and improve website efficiency. Carly or one of our
designated third parties may set a cookie on your browser and/or device when you visit the
Website. Web beacons are also used in certain email communications. Carly employs cookies and
other tracking technologies to manage your settings, customize and distribute content and
advertising, offer social networking services, and evaluate Website user data.
We may employ both “session cookies” (which expire when the browser is closed or the machine
is switched off) and “persistent cookies” (which remain active until removed). You may control
website cookies by changing your cookie choices or by using the pop-up at the bottom of a website,
and you always have the option to change these settings by accepting, rejecting, or removing
cookies. If you modify your preferences, you may discover that certain Websites or Services
functionalities and features may not perform as intended.

Types of cookies we may use:

Cookies that are required or necessary.

These cookies are required for the Website’s core
functionality and cannot be disabled. Session cookies, for example, are required to transmit the
Website, as are login cookies and security cookies.

Cookies from social media.

These cookies enable users to share our Website or content on social
media platforms. Because these cookies are not under our control, you should read the privacy
policies of each social networking site to understand how they function.

Cookies for advertising purposes.

These cookies track visitor behavior across websites in order to
learn their preferences and target specialized marketing to them. Carly may choose to contract with
third-party advertising networks that gather IP addresses and other information from web beacons
on our websites, emails, and third-party websites now or in the future.

Useful cookies.

These cookies allow us to tailor our website content to a user’s preferences. They
remember the user’s preferences, language, country pages viewed, and any modifications the user
makes to the font size or other aspects of our website pages. These cookies can anonymize the
information they gather and cannot follow your browsing activity on other websites.

Cookies for analytics.

These cookies track user interactions and engagements with our website and
collect information such as page views, time and approximate location of users, and user activity
on the website, allowing us to better understand and develop our website.
We may also get some third-party cookies from your system or device if you use the Services.
Cookies placed by sites, applications, and/or entities other than Carly are referred to as third-party
cookies. Within the Services, third-party cookies may be employed.

Data Collected from Third Parties:

Services provided by a third party. If you choose to use our Services through a third-party site or
service, the third-party service may give us information from that service, such as your registration
and profile information. The information we may obtain varies per service and is managed by the
provider in question. By linking a third-party account to your Carly account and granting Carly
access to this data, you agree that Carly may gather, store, and use this data in accordance with
this Statement. We are not liable for how third parties use or disclose your information. To learn
more about how those third parties, use and distribute your personal information, please see their
privacy policies.

Background check services.

To the extent permitted by law, we may get background information
about you from sex offender registries, public records, background check providers, and other
screening services. Credit reports, facts on previous criminal convictions, and credit reports are
examples of such information. We may use your information, including your full name and birth
date, to get such reports.

Devices installed in a car by any third party.

If your vehicle, or a vehicle you book through the
Services, has an in-vehicle device or system that is controlled by a third-party service or installed
by the host, that service or host may record data about your usage of the automobile. These devices
or systems may monitor the condition, performance, and operation of the vehicle, as well as track
fuel usage, distance traveled, position, and other data. The host and/or third-party services will be
completely liable for how such information is used, although they may share such information
with Carly, who will handle it in line with this Statement.

We may obtain additional information about you from credit bureaus and other third-party data
sources, as well as demographic and fraud detection data, to the extent allowed by relevant law.
We could merge the data we already have on you with the information we get from outside sources.

Usage of Your Personal Data:

We treat your Personal Data for the following reasons in compliance with relevant legislation,
using the following legitimate basis.
 legitimate objectives of a third party or of Carly;
 the requirement to carry out a deal with you;
 Respect for relevant laws, rules, or court orders; and
 Express permission (as needed by applicable legislation) for the use of your data (in cases
where we rely on your consent, you can revoke it by contacting us as described below).

We may use your personal data to validate your identity or confirm information you submit, such
as during the account setup and password reset processes, as well as to handle disputes, collect
payments, and fix issues.

The following typical cases are recognized as having such legal bases:
 While operating our Website or providing you with our Services (to host or guest.)
 For registration purposes.
 While entertaining your supports request or when you contact us with any question.
 While applying for a job with us.
 For compliance of any terms or policies posted by us.
 To probe any offence or spam.
 For marketing or advertising purposes.
 To find more about our offered Services.
 For payment purposes.
 In compliance with any legal obligation.

Your personal information may be used by us to evaluate and enhance the Services, as well as to
create new goods and services. One way we may do this is by looking at the demographics of the
Services’ users. With your data, we could also produce aggregated, de-identified, or other
anonymous data. We remove information that would allow us to identify you personally to turn
personal information into anonymous data. For legitimate business objectives, such as monitoring
and enhancing the Services and promoting our enterprise, we may use and disclose this anonymous
data to other parties.

We use your personal information as we consider it necessary or reasonable to comply with
relevant laws, legitimate demands, and legal procedures, such as responding to subpoenas or
requests from government agencies. In rare situations, we may expressly request your consent for
processing your identifiable data.

Disclosure of Personal Information:

We may disclose your information at your request or with your permission. However, we will
share your information in the following ways.

Profiles, Listings, and Other Forums:

Basic details like your user ID or name linked to your account, your public profile photo, and, for
hosts, the city in which your vehicle is located, your listing description, your calendar availability,
transaction-related data so that our community can assess your responsiveness and dependability,
and reviews or comments about you will always be included on your public listing page on the
Services. Information regarding your cancellations and aggregate demand data, such as the total
number of page visits over time, may also be included on your public listing page. The approximate
geographic location of your vehicle’s pick-up may also be displayed by the Services.
The Services enable search engines to locate your online profile and public listing pages, which
means that search engines may search and display your public profile and public listing pages as
results from searches.

To Purchaser:

In the event of bankruptcy or dissolution, or in connection with a business transaction such as a
corporate divestiture, merger, consolidation, acquisition, a restructuring, or sale of assets, we may
sell, exchange, or otherwise share some or all of our business or assets, including your personally
identifiable information.

With Legal Team:

We may share your personal information to professional advisers such as attorneys, bankers,
auditors, and insurers as needed in the course of their professional services to us.

With different Providers:

We may share information with suppliers and service providers that help us run our Services and
business and require access to such information to accomplish their jobs. In some situations, the
service provider may collect information directly from you on our behalf. Your contact details will
be exchanged with the photographer appointed to picture your car if you opt to use our photography
service. These service providers may only use your personal information as we request
or authorize.

Published Data:

We may disclose limited information on leadership teams and key people to other business
professionals via our Services.

Advertising Network Partners:

We may release information gathered automatically and passively via various technologies on our
Website to marketing partners in order to target you with advertisements.

Featuring Purposes:

If you activate features or capabilities that connect the Services to a third-party platform or social
media network, we may reveal to the third-party platform or social media network personal
information that is required to allow the connection or that you have permitted us to release. We
have no control over how third parties take your personal information.

Between Host and Guest:

We make it possible for car owners to rent out and share their vehicles with other people. If you
accept a booking made via the Services, we may provide the other party in that transaction access
to your information as long as it’s reasonably needed to complete the transaction. For instance, we
could provide us access to your cell phone number to help you communicate, the details on your
driver’s license to verify your identity and license validity, or your picture to help you identify
yourself. We will also give the other party access to the vehicle’s address and, if relevant, the
planned delivery location. If you utilized the Trip Photo feature, we could provide the other party
access to the trip photographs you post along with the captions you attach. Text messages from
the other party may also be sent to you (for example, to confirm pickup or delivery location).
Standard phone minute rates, as well as text and data charges, may apply.

Legal and regulatory compliance:

In order to comply with laws, regulations, and legal processes, we may share Personal Data to
other parties.

California Rights:

This California Privacy Notice (hereafter referred to as the “Notice”) is a supplement to the
information in the Statement and is only relevant to California residents as defined by applicable
law. The definitions of “Personal Information” and “Sensitive Personal Information” as provided
in the California Consumer Privacy Act of 2018 (the “CCPA”), as revised by the California Privacy
Rights Act (the “CPRA”), and any implementing regulations, shall apply for the purposes of this
Notice. As a California resident, you enjoy the following rights.
Personal Details. You have the right to obtain information about how we gathered and applied
your Personal Information.

Deletion.

You have the right to request that we remove the Personal Information we have obtained
from you.

Correct.

You have the right to request that we remove, amend, or remedy any errors in your
Personal Information.

Access.

You have the right to seek a copy of the Personal Information we have gathered on you
over the last 12 months.

In order to exercise any right stated in this Statement, you may contact us at our “contact us”
details.

Certain Preferences or Choice:

In the notifications area of your Carly account, you may personalize how we communicate you
about your account, your booking and listing activity, specials, and announcements. While using
our Services, you will have the following preferences or choices;
 To opt out our marketing services.
 To correct or update information provided by you.
 To close or deactivate your account with us.
 To prevent sharing of location access.
 To stop receiving our promotional emails.

Children or Minor:

Carly’s Services are just for business clients and are not meant for children. We do not collect
Personal Information from minors under the age of 18. If you are a parent or legal guardian and
feel your kid has given us with Personal Data without your permission, please contact us and we
shall remove such Personal Data from our databases.

Protecting of Personal Data:

We use a variety of technical, physical, and administrative safeguards to secure information
against unauthorized access, deletion, or alteration while it is in our possession. However, no
method of transferring or storing information can be guaranteed to be completely safe, and we are
unable to guarantee the privacy of your personal information.

Retention of Data:

We keep Personal Data for a period of time that corresponds to the purpose for which the Personal
Data was received. Furthermore, retention periods may be determined by other criteria, such as the
nature and sensitivity of the Personal Data, including any potential risk of harm arising from
unlawful access or disclosure, as well as whether we are required to retain it by additional
legal/regulatory obligations.

Your Comments and Concerns:

This website is operated by Carly.

Address: 500 Terry Francois Street, 6th Floor. San Francisco, CA 94158.
Email: _________________________________
Contact Number: ________________________