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Privacy Policy (United States)

DRAFT FOR LEGAL REVIEW. Not legal advice and not ready to publish. This version is for a US-only launch and is written to meet the California Consumer Privacy Act as amended by the CPRA ("CCPA"), the other comprehensive state privacy laws (e.g. Virginia, Colorado, Connecticut, Texas, Oregon and others), and CalOPPA. Some of these laws only apply above revenue or volume thresholds, but following them from day one is simpler than retrofitting. Placeholders in [BRACKETS] must be filled in, and the service provider list and retention periods must match the product at launch. The GDPR version is in eu/.

Last updated: [DATE]

This policy explains how [COMPANY LEGAL NAME] ("we", "us") collects, uses and shares personal information when you use PDR Marketplace (the "Platform"), and the choices and rights you have. It covers Customers (individuals, body shops, dealerships and other businesses with vehicles to repair), Technicians, and website visitors.

1. Information we collect

| Category (CCPA term) | Examples | Source |

|---|---|---|

| Identifiers | Name, email, phone, account ID, IP address, device IDs | You; your device |

| Customer records | Address, business name, and optional insurance certificate uploads and business Federal Employer Identification Number (FEIN) (shown to Customers only as a badge, never as the document or number itself); for Technicians who add a payment card (for At-Home Service Fees or a subscription), billing name and address | You |

| Commercial information | Jobs posted, Listed Prices, Technicians' requests, approvals and confirmed jobs, repair location type (Customer's home or another location), revised estimates; Technicians' At-Home Service Fee charges, refunds and, once launched, subscription history | You; our records |

| Vehicle and job information | Photos and videos of the vehicle and damage, description, make, model, year, color, and optionally VIN and license plate | You |

| Geolocation | Repair address or area (Customers); service area, and precise device location if you allow it (Technicians) | You; your device |

| Internet and device activity | Pages viewed, clicks, browser type, crash logs, cookie data | Your device; cookies (see Cookie Policy) |

| Past-customer contact details | Name and email of a past customer and a description of the job, given to us by a Technician who invites them to leave a review; used only to send that request (one email plus one reminder) and deleted after [60] days if no review is left | Technicians |

| Communications | Messages, photos and files you exchange with other Users (in-app, or by email, text or call relayed through our masked addresses and numbers, including call times and durations) or with our support team | You |

| Professional information | Technician licenses, registrations, certifications, years of experience, reviews and ratings | You; other Users; public license databases |

| Sensitive personal information | Driver's license or other government ID (Technician verification); account login credentials; precise geolocation. (Technicians' card details go directly to our payment processor; we keep only the card type, last four digits and expiry. We do not collect Customers' bank or card details.) | You |

| Vehicles you own | Vehicles saved to your profile ("My garage"): make, model, year, mileage range, ownership or lease, purchase timeframe | You (optional) |

| Characteristics (demographics) | Age range, gender, household income range, home ownership, number of household vehicles, interests | You (optional profile questions); [third-party data providers, if used] |

| Inferences | Likely job types or areas of interest, likely vehicle needs, audience segments (e.g. "owns a vehicle 5+ years old in Dallas area"), used to recommend jobs and for marketing | Derived by us |

Photos can incidentally capture people, other vehicles, homes or embedded GPS data. We strip location metadata from uploaded photos [and blur license plates and faces before photos are shown to Technicians]. We do not use facial recognition and do not collect biometric identifiers.

We do not knowingly collect information from anyone under 18.

2. How we use it

  • Provide the marketplace: create accounts; let Customers post jobs and see a Listed Price, and let Technicians find and ask for them, let Customers approve a Technician, and let that Technician confirm; produce automated photo-based Estimates; enable private messaging, and relay email, texts and calls between a Customer and the Technician on their job through masked addresses and numbers, so neither side sees the other's personal phone number or email.

  • Technician fees: charge Technicians the At-Home Service Fee (and, once launched, subscriptions) through our payment processor, handle refunds and disputes, and keep billing and tax records. We do not process payments between Customers and Technicians, and Customers pay us nothing.

  • Trust and safety: verify Technicians, detect and prevent fraud, spam, abuse and security incidents, including automated scanning of messages and uploads; enforce our Terms.

  • Reviews: publish ratings and reviews.

  • Improve the Platform: analytics, debugging, and training our Estimate models using de-identified photos and job data (license plates, faces and location removed).

  • Communications: service messages (job alerts, account notices, and requests to rate a Technician after a completed job) by email, push or, with your consent, text; marketing emails (you can unsubscribe any time) and marketing texts only with your express written consent.

  • Marketing and audience insights: understand who uses the Platform (location by city or ZIP code, vehicles, demographics), measure and target our own advertising, and build audience segments.

  • Selling and sharing with partners: unless you opt out, provide certain information to third-party partners for their own marketing and analytics, as described in Section 4.

  • Legal: comply with law, respond to lawful requests, and protect our rights and Users' safety.

We use sensitive personal information only for purposes the CCPA permits without offering a right to limit: providing the services you request, verifying identity, security and fraud prevention, and complying with law. We collect precise geolocation only with your opt-in consent, use it only to match jobs, and never sell or share it. You can turn it off in your device settings at any time. We do not ask for race, ethnicity, religion, health, sexual orientation, citizenship or immigration status, and do not sell any sensitive personal information.

3. Automated estimates

Our Estimate tool uses software, including machine learning, to suggest a price range from your photos. It is only a guide; Technicians set their own prices and the Estimate does not decide anything about you. Automated fraud tools may flag accounts, but a person reviews any decision to suspend an account, and you can appeal by contacting [support@domain].

4. How we share it

  • Public job board. Open job posts are publicly visible to anyone, including people who are not signed in: damage photos (with location data removed and license plates and faces blurred), year, make, model, trim and color, the Listed Price, and the approximate area (city or ZIP code). We show only the first 11 characters of the VIN publicly (enough to identify the vehicle type, not the individual vehicle); the full VIN is shown only to the Technician who confirms the job. Your name, contact details, street address and license plate are never shown on the job board. A job post leaves the board when a Technician confirms it or you close it.

  • With other Users. A Technician who asks for a job is shown to that Customer by their public profile. After the Customer approves a Technician and the Technician confirms, that Customer and Technician see each other's first name (and business name for Technicians and business Customers) and can contact each other only through the Platform. We never give either side the other's personal phone number or email address. The repair address is shown to the Technician only when the repair is done at the Customer's location. Technician profiles, ratings and reviews are public. Business Customer profiles (body shops and dealerships) show the business name, general location and contact details they choose to display to Technicians; individual Customers' profiles show only their first name and approximate area.

  • Service providers that process data for us under contracts limiting their use of it: cloud hosting [e.g. AWS, region], email and SMS delivery, customer support, analytics, image processing and AI providers, identity verification and background checks, and our payment processor [e.g. Stripe] for Technician fees.

  • Legal and safety. Law enforcement, regulators and courts when required by law or to protect anyone's safety or rights.

  • Business transfers. A buyer or successor in a merger, acquisition or sale of assets.

  • With your consent or at your direction.

Sale and sharing of personal information, and your right to opt out

We sell and share certain personal information, as state privacy laws define those terms, with third-party partners. These partners are [auto insurers, auto dealers and parts retailers, automotive service companies, marketing and advertising companies, and data analytics companies]. They use it for their own marketing, advertising and analytics. We also "share" information with advertising companies to show you ads on other sites (cross-context behavioral advertising).

| Category | Sold or shared in the past 12 months? |

|---|---|

| Identifiers (name, email, phone, device IDs) | [Yes] |

| Vehicles you own; vehicle and job information (not photos, VIN or license plate) | [Yes] |

| Approximate location (city, ZIP code) | [Yes] |

| Characteristics (demographics you chose to provide) | [Yes] |

| Inferences and audience segments | [Yes] |

| Internet and device activity (via advertising cookies) | [Yes] |

| Precise geolocation, government ID, login credentials, messages, photos, VIN, license plates | No, never |

Your right to opt out. You can opt out of the sale or sharing of your personal information, and of targeted advertising, at any time:

  • click "Do Not Sell or Share My Personal Information" (also labeled "Your Privacy Choices") in the site footer or in your account settings;

  • turn on Global Privacy Control (GPC) in your browser, which we honor as an opt-out; or

  • email [privacy@domain] or call [toll-free number].

We do not need you to create an account to opt out, and opting out does not change how the Platform works for you or what it costs. After you opt out, we stop selling or sharing your information, tell the partners we sold it to in the previous [90] days, and wait at least 12 months before asking you to opt back in.

We do not sell or share the personal information of anyone we know is under 16. We do not offer payment, discounts or other incentives in exchange for your data.

Texas notice: We may sell your personal data. We do not sell sensitive personal data.

In the past 12 months we have disclosed each category in Section 1 to service providers for business purposes, and Identifiers, Vehicle and job information, approximate Geolocation and Professional information to other Users as described above.

5. How long we keep it

| Information | Retention |

|---|---|

| Account and profile | While your account is open, then deleted within [30] days of closure, except as below |

| Job posts and photos | [12] months after the job closes, or sooner if you delete them; de-identified copies may be kept |

| Messages | [24] months after the last message in a conversation |

| Technician fee, subscription billing and tax records | [7] years |

| Technician verification records | Account duration plus [3] years |

| Fraud and safety records | Up to [3] years, longer if needed for a legal claim |

| Analytics data | [14] months |

| Demographics, garage vehicles and audience segments | While your account is open; deleted within [30] days of closure or when you remove them from your profile |

6. Your privacy rights

Depending on your state, you may have the right to:

  • Know / access the personal information we hold about you and how we use and share it, and get a portable copy;

  • Delete personal information we collected from you;

  • Correct inaccurate information;

  • Opt out of the sale or sharing of personal information, targeted advertising, and profiling with legal or similarly significant effects;

  • Limit use of sensitive personal information (we only use it for permitted purposes, as above);

  • Not be discriminated against for exercising your rights.

How to exercise them: use the privacy settings in your account, email [privacy@domain], or call [toll-free number]. We will verify your identity by matching information you give us with our records. You may use an authorized agent, who must show your written permission. We respond within 45 days (extendable once by 45 days when necessary).

Appeals. If we deny your request, you can appeal by replying to our decision or emailing [privacy@domain] with "Appeal" in the subject. We will respond within the time your state's law requires. If you are not satisfied, you may contact your state Attorney General.

California "Shine the Light". California residents may ask once a year whether we shared personal information with third parties for their direct marketing. We do not.

Do Not Track. Browsers' "Do Not Track" signals have no common standard, so we do not respond to them; we do honor GPC signals as described above.

7. Security

We use encryption in transit and at rest, access controls, logging and regular testing. No system is perfectly secure. If a breach affects your information, we will notify you and regulators as state law requires.

Staying safe: remove valuables from your vehicle before an inspection, confirm a Technician's identity, license and insurance before handing over your keys, and keep communication on the Platform until you are comfortable.

8. Children

The Platform is not for anyone under 18. We do not knowingly collect information from children under 13 (COPPA) or anyone under 18, and will delete it if we learn we have.

9. Changes

We will notify you of material changes by email or in-app before they take effect. The date at the top shows the current version.

10. Contact

[COMPANY LEGAL NAME], [address]. Email: [privacy@domain]. Phone: [toll-free number].