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TERMS OF SERVICE

Effective November 1, 2023

Below are terms of use (the “Terms”) governing the Services provided by KINTO™ a trademark of Toyota Motor Credit Corporation (“KINTO” or “Kinto“, “us“, “we“, or “our“) to its drivers, couriers, partner transportation companies, and any other persons that use vehicles on the KINTO service under license (collectively “Drivers,” or individually “you”). Your access and use of the vehicles and Services (collectively, “Services”) on KINTO constitutes your agreement to be bound by these Terms as a Driver. This establishes a contractual relationship between us and you as a Driver. As a Driver, you are considered a client and not an employee, contractor, sub-contractor, or special employee of the vehicle owner or KINTO. Furthermore, you are determined to not have any employment status of any kind with the vehicle owner or its affiliates, partners, agents or vendors, nor that of KINTO, or any of KINTO’s partners, agents or vendors. If you do not agree to these Terms, you may not access or use the Services, as updated from time to time in accordance with the Amendments section below.

Services.
The Services constitute use of us or our affiliates’, partners’, or licensors’ vehicles, as well as the following “Applications”: accessories, telematics, safety, security or other technology platforms, and web or mobile applications which enable users to arrange, schedule and rent transportation and/or logistics services, gain access to vehicles, and operate them.

Reservations.
Drivers may reserve the Services via KINTO’s reservation system. Reservations will be made on an as-available, first-come basis, and we do not guarantee the availability of the Services at any particular time. The length of each term of use of the Services will be agreed to on a per drive basis via our reservation system. We reserve the right to change or cancel the Services at any time with or without notice. Reservations may be made no earlier than seven days in advance. We may set time limits to a continuous reservation of our Service, regardless of vehicle availability in the reservation system.

License.
Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-sublicensable, revocable, non-transferable license to: (i) access and use vehicles; (ii) access and use the Applications on your personal device solely in connection with your use of the Services; and (iii) access and use any content, information and related materials that may be made available to you through the Services by us, in each case solely for your use in conjunction with ride sharing, ride hailing, delivery, personal use, or any other service approved by us. Any rights not expressly granted herein are reserved by us or our affiliates, partners, or licensors. This license is restricted to the state in which the vehicles are stationed.

Authorized Drivers.
Only you may drive your vehicle during your reservation.

Ownership.
The Services, underlying assets, and all rights therein are and shall remain Company property or the property of our licensors. Neither these Terms nor your use of the Services convey or grant to you any rights: (i) in or related to the Services except for the limited license granted above; or (ii) to use or reference in any manner our names, logos, product and service names, trademarks or services marks or those of our licensors.

User Accounts.
In order to use most aspects of the Services, you must be registered for and maintain an active personal user account (“Account“). You must be at least 21 years of age to obtain an Account. Account registration may require you to submit to us or to our administrative partners certain personal information, such as your name, address, mobile phone number, date of birth, and copy of your valid driver license, as well as at least one valid payment method (such as a credit card from an accepted payment partner). You agree to maintain accurate, complete, and up-to-date information in your Account. Your failure to maintain accurate, complete, and up-to-date Account information, including having an invalid or expired payment method on file, may result in your inability to access and use the Services or our termination of this Agreement with you. You are responsible for all activity that occurs under your Account, and you agree to maintain the security and secrecy of your Account username and password at all times. Unless otherwise permitted by us in writing, you may only possess one Account.

Billing & Payment.
When you make a reservation in our reservation system, KINTO or its administrative partner will authorize your payment card by charging the full rental amount plus taxes at time of reservation. KINTO accepts payment via credit or debit card. Prepaid cards are not accepted. The name on the credit and debit card must match the Driver’s license and name on the KINTO account. You will receive an invoice and confirmation of your payment electronically via the KINTO mobile app. You are responsible for ensuring your ability to pay the actual amount due. A reservation that is made and never activated will be billed for the full reservation unless the Driver cancels it.

Application fees are non-refundable in all cases, regardless of the outcome of an applicant’s background check.

Pricing Structure.
Pricing for access to KINTO’s Services includes the costs of maintenance, roadside assistance, and vehicle insurance, see the Insurance section below. For plan details please see the KINTO website at kinto-us.com or offer to you. We reserve the right to amend rates, rate structures, terms and credits at any time.

Driving and Criminal Record Requirements.
We obtain a Motor Vehicle Report (MVR) and perform a criminal background check for every applicant. In order to qualify for the Service, each applicant must have a motor vehicle history that meets the following specifications:

  • Drivers must be at least 25 years old
  • Drivers must be able to legally drive in the state of use with an active in-state license
  • No more than two moving violations in the past three years (ex. accidents, traffic light violations)
  • No more than two cell phone or distracted driving violations in past three years
  • No more than one moving violation and one accident in the past three years
  • No more than two accidents in the past three years
  • No major moving violations in the past three years (ex. driving on a suspended license, reckless driving)
  • No DUI or other drug-related driving violations in the past seven years
  • No more than three total violations in the past three years
  • No criminal record

We reserve the right to conduct a review of all Drivers records on an ongoing basis to ensure compliance with the above rules. We reserve the right to revoke a Driver’s driving privileges at any time for any reason not limited to those listed above.

On-Demand Authorization.
When using the vehicle for rideshare, driver must be authorized to provide services on an approved ride-sharing, ride-hailing, or delivery service. Approved on-demand services include Amazon Flex, Caviar, DoorDash, HopSkipDrive, Instacart, Postmates, Seamless, Uber/UberEats, and Via. You must first receive written approval from us before operating on a service other than those listed in this paragraph.

Driver’s License.
Drivers must carry a valid driver during every trip. Driving eligibility is conditional on your possession of a valid driver’s license. If your license is suspended, withdrawn, or expired, for any reason, your right to drive a vehicle expires immediately. You must immediately inform us of any suspension, withdrawal, or expiration of your driver’s license. Drivers must report any changes in contact information (e.g. addresses or phone numbers) to us immediately.

Insurance and Damage Liability.
We provide liability insurance, which covers damages up to $30,000 in bodily injury per person, $60,000 bodily injury each accident, and $25,000 property damage each accident in the event of an at-fault accident. This insurance does not cover the cost of your own medical expenses in the event of an accident – to ensure you are covered in the event of this situation, please consult your personal medical policy and/or personal auto insurance policy.

We expect you to drive and treat the vehicles with the utmost care. We reserve the right to suspend your driving privileges and access to the vehicles if we determine, in our sole discretion, that you are not taking appropriate care when driving vehicles on the KINTO service or using other Company assets.

In instances where you are operating the vehicle (i) illegally (suspended license, under the influence, etc.), (ii) in a manner not allowed by these Terms of Service, (iii) with deliberate intent on damaging the vehicle, or (iv) negligently, you will bear the full cost of damage to vehicles on the KINTO service as well as any damage to third parties not covered by the vehicle’s insurance policy.

If you are involved in an incident resulting in damage to the vehicle, third parties or third-party property, a damage fee of up to $1,000 may apply. A damage fee may apply, but is not limited to, dents, scratches, collisions, flat tires, windshield cracks, dead batteries, engine problems, vandalism, theft, other Company or partner property, third party damages and, in some cases, third party personal injuries. In the event of a collision or other incident where additional investigation is required, we will charge the Driver $1,000 at the start of the investigation process. At that time, the Driver’s account will be temporarily disabled pending investigation. Once the investigation is complete, the Driver will be reinstated at our sole discretion. If the cost of repair is less than $1,000, the Driver will be refunded any remaining balance from the damage fee.

In cases of theft or loss, a Driver may be held responsible for the entire cost of recovery or replacement. Drivers are not responsible for normal wear and tear on the vehicle.

Before each reservation, we ask you to check the car inside and out and report any damage to us. This ensures that you will not be held responsible for damage that may have happened before your reservation. See the “Checking Your Car Before Departure” section below.

Restrictions.

  • Smoking is prohibited in all vehicles.
  • Due to allergies and sanitary concerns, pets with the exception of service animals are only allowed in locked pet carriers while in the vehicles.
  • Vehicles on the KINTO service may not be used:
    • by anyone who is not a valid Driver in good standing with us;
    • for purposes other than personal transportation or on-demand work with approved ride sharing, ride hailing; delivery or other partner transportation companies;
    • for any illegal purpose or in any illegal manner;
    • for the purpose of towing, pushing, or propelling any trailer or any other vehicle;
    • while the Driver is under the influence of any intoxicating substance;
    • in any race, test, or competition;
    • in a careless, reckless or negligent manner;
    • if it has been obtained from us by fraud or misrepresentation;
    • other than on paved roads;
    • when it has been loaded beyond its rated capacity or with more passengers than the vehicle has seat belts
    • unless a reservation has been made; or
    • for travel outside of the United States, such use of KINTO vehicles is strictly prohibited.

Checking Your Car Before Departure.
Before using a KINTO vehicle, you are required to check the vehicle for any mechanical or physical defects. If you notice damage, you must report it by emailing us at support@kinto-us.com before the start of your reservation. When reporting damage to us, please be sure to note the assigned vehicle number. If you forget to notify us and the next driver reports the damage, we may hold you financially responsible for the damage. You must also check to make sure that the following items are present in the vehicle and inform us if any of them are missing:

  • Insurance card and registration
  • Garage Pass (if applicable)
  • Charging cable (electric vehicles only)

You may not drive if the insurance or registration are missing! (Please note: if a vehicle is newly acquired, its registration may be affixed to the windshield.)

Car Care.
Our operations partners regularly clean and maintain all of its vehicles. Drivers are expected to return a vehicle in the same condition they found it. Here are the main categories for which drivers are responsible:

  • Fuel: Drivers are responsible for fueling the car while in use and returning the vehicle at the level you started with. We will make every effort to ensure the vehicle is at full fuel at the start of every reservation, however if the vehicle is not at full fuel level at the start of your reservation, please contact customer support. Any fraudulent credit request will be grounds for dismissal from our Services and be grounds for us to take legal action against the fraudulent party.
  • Electric Vehicle Charge: Drivers are responsible for charging the car while in use and returning the vehicle at the same level it was at time of pick-up. . We will make every effort to ensure the vehicle has a range of at least 150 miles at the start of every reservation, however if the vehicle is below the 150 miles range at the start of your reservation, it is the Drivers responsibility to report it to customer support. Any fraudulent claims will be grounds for dismissal from our Services and legal action against the fraudulent party.
  • Cleanliness: Drivers must maintain a clean vehicle during use and return the vehicle as clean when the vehicle is up.
  • Vehicle Electronic Components and Hardware: Drivers are responsible for Fees and Penalties (if no Fee or Penalty is prescribed herein, the replacement cost) with regard to any missing or damaged electronic vehicle components or hardware installed by us or on our behalf, including, but not limited to, telematics units and dashboard cameras.

Returning the vehicle.
You must properly return your vehicle to its assigned location by the end of your reservation period or late fees will be applied and your account will be suspended. Proper return means that:

  • The interior of the vehicle, including the rear where your passengers have been, is clean and you have taken all of your personal belongings. 
  • Please ensure that the gasoline tank is full or EV charge range is at 150 mile. If a Driver does not return a vehicle with full fuel or 150 EV charge range, a fee will apply. 
  • Electric vehicles will come with a level one charging cable. If the cable is lost or damaged (other than through regular wear and tear), the Driver will be charged a fee.
  • You have notified KINTO staff of any new damage to the vehicle. 
  • The vehicle’s windows are rolled up tightly, all of the vehicle’s documentation is in the glove box, the vehicle is entirely contained within its reserved parking spot and properly locked. If a vehicle or other Company or partner property are not properly secured, a fee will apply. 

It is your responsibility to ensure the safe return of the vehicle. You are not allowed to return the vehicle to a location other than its assigned location. If you fail to return the vehicle by your drop-off time as stated in your reservation, and you have not contacted us, we reserve the right to call or text your listed phone number. If you fail to return the vehicle to its assigned location, you may be charged for the total costs of recovering the vehicle, including but not limited to labor and towing costs. If you cannot be contacted, the vehicle may be reported to the police as missing, you will be charged all associated fees, and criminal charges could be executed.

Emergencies.
KINTO offers 24-hour emergency assistance for situations requiring immediate attention. Please text  us immediately at (629)-20-KINTO in the following situations:

  • You show up for your reservation and the vehicle is not in its assigned location.
  • The vehicle won’t start.
  • You are unable to park the vehicle in the correct location.
  • You are running late and unable to extend your reservation because another driver has reserved the vehicle after you.
  • The vehicle is displaying a warning light or has a mechanical issue.
  • You need roadside assistance, such as a flat tire or dead battery.

Traffic and Parking Tickets.
If you get a traffic or parking ticket or toll violation while using a KINTO vehicle, it is your responsibility to notify us and pay it promptly. If we or our administrative partner receives a citation incurred during your driver session, we will charge you to recover the amount and assess a non-refundable Citation processing fee.

Towing and Impoundment.
If a vehicle is towed during your driver session, contact KINTO immediately. You will be assessed any costs associated with returning the vehicle to its lot.

Maintenance and Emergency Repairs.
Drivers are required to heed any warning lights on the dashboard of the vehicle and contact KINTO immediately. Failure to acknowledge warning lights or noises from the vehicle may result in fees for negligence. 24-hour emergency roadside assistance is available for emergencies.

Breakdowns, Accidents, and Damage.
Any accident or damage in connection with the vehicle you are using must be immediately reported to KINTO and, if appropriate, to the police. You are obliged to secure evidence from any available witnesses, and to provide us with a written description of the accident and the damage incurred. After an accident you may only continue your trip with the explicit permission of KINTO staff. In case of a hit and run, you must obtain a police report. You agree to provide us and any other claims adjustment service with the findings of any report or any notice relating to a claim or a lawsuit against us or any of our partners regarding any accident involving a vehicle used in the KINTO Service. You agree to cooperate fully with us in the investigation and defense of any such claim or lawsuit. If for some reason the vehicle owner’s insurance policy does not apply (for example only, because you have driven while intoxicated) you may be liable for the entire cost of vehicle repair or replacement and claims made by third parties. You may be held responsible for any damage occurring to the vehicle or claims made against the Service’s parties for damages resulting from your use of the vehicle. You are responsible for any damage caused to any of KINTO’s in-vehicle systems or hardware resulting from use or tampering.

Fees and Penalties.
Fees will be applied to your account for the following reasons or any violations of these Terms:

Damage Fee
Up to $1,000 (see Insurance and Damage Liability)

Vehicle returned with less than full tank of fuel but greater than 50%
$70

Vehicle returned with less than ½ tank of fuel
$150

Electric vehicle returned with less than 150 miles of range but greater than 100 miles of range
$70

Electric vehicle returned with less than 100 miles of range
$150

Vehicle late return fee
$25/hr for any portion of an hour up to 4 hours, with a max late return fee of $100

Cancellation later than 24 hours before reservation start
Full reservation amount

No-show
Full reservation amount

Early return
No refunds will be issued

Failure to properly secure the vehicle
$50

Leaving vehicle interior dirty and/or with odor
$50

Professional detailing required (such as, but not limited to, smoke odor or stained interior)
$150

Unauthorized driver
$250 + suspension from Service

Citation processing fee
$30 + the cost of the citation

Customer requested electric vehicle emergency charge
$100

Vehicle abandoned, towed or returned to the wrong location
$200

Missing or damaged telematics unit
$550

Missing or damaged dashboard camera
Up to $750

Missing or damaged level one charging cable
$850

Missing or damaged items (toll tag, license plate holder, parking pass)
$50

Vehicle impounded
$500

Over Mileage Limit Fee
$0.25 for each mile over 1,400 mile per week limit

We reserve the right to terminate the license granted hereunder and your ability to use the Services at any time for any of the above violations, for any other violation of these Terms, or for any other reason, whether or not outlined in these Terms, in our sole and absolute discretion. We may also at any time without notice temporarily suspend an individual Driver’s permission to drive any or all vehicles available on the KINTO Service.

In addition to the fees and penalties above, we reserve the right to repossess a vehicle at any time, without notice, if we determine that it was used in violation of applicable law or these Terms, subject to state law restrictions.

Avoiding Late Fees.
Returning a vehicle late or blocking a vehicle that you are not using impacts your fellow members’ access to KINTO. In order to limit the impact of late returns, you should:

  • Attempt to extend your reservation to if you expect to be late.
  • Contact us to communicate a late return.

Cleaning Policy.
At the time of pick-up, if the vehicle’s interior or exterior is dirty and/or has an odor, report the issue to the customer support team. Before returning the vehicle, ensure the vehicle is clean and in the same condition it was in at time of pick-up. Please check the entire vehicle , including the back seat. and remove trash and debris from the vehicle.Leaving trash in the KINTO parking lot is prohibited. If you anticipate a problem with cleaning the vehicleplease contact KINTO ahead of time. You will be charged a cleaning fee, if you return the vehicle in violation of this policy.

If there are cleaning emergencies that make the vehicle unusable, please contact KINTO immediately and we can help you handle the situation. If significant cleaning by a professional is required, you may be assessed a cleaning fee. In cases that involve the actions of a rideshare passenger, you may qualify for reimbursement from your on-demand service provider.

Smoking in a vehicle is strictly prohibited. You are responsible to ensure that no one smokes in the vehicle while it is in your possession. If you return a vehicle that smells like smoke, you will be assessed a fee. Smoking could result in termination of the license granted hereunder and your loss of access to our Services.

Liens and Impoundment.
If the vehicle is towed and/or impounded during your reservation, you are responsible for recovering the vehicle and you agree to pay any costs arising from the vehicle being towed and impounded, as well as any late return or fees that are incurred. If KINTO is involved in recovering a towed or impounded vehicle, we will assess a fee in addition to any costs associated with vehicle recovery.

Automatic Suspension.
Your permission to drive on the KINTO service will be automatically suspended, in our sole and absolute discretion, if:

  • you are charged with driving recklessly or without due care or any related vehicular offense, including (but not limited to): operating a motor vehicle while impaired, operating a motor vehicle dangerously, or failure to stop at the scene of an accident;
  • you fail to return a KINTO vehicle five or more hours after the scheduled end of your reservation;
  • you return a KINTO vehicle one or more hours late three times in any ninety-day period;
  • we reasonably believe you have committed fraud or identity theft
  • you use a KINTO vehicle in the carrying out of any crime or for any other illegal activity or purpose; or
  • we are unable to collect payment for any reason.

Additionally, your permission to drive on the KINTO service will be suspended if we are unable to collect payment for any reason.

Data Policies.
Termination by User. You may terminate this Agreement at any time, for any reason or for no reason, by notifying us via email at support@kinto-us.co that you are terminating your Services account. In such notice, you may also request that we delete from our servers all of the Credentials Information. Such requests will be honored within a reasonable time period after they have been received provided that you give us all reasonably necessary information and cooperation. Data (except Credential Information) collected prior to the effectiveness of the termination will continue to be stored in our backup systems and may be used in accordance with our privacy policy and consistent with applicable laws.

Location-Based Services.
You hereby expressly consent to our use of location-based services (including without limitation GPS systems) in connection with your use of Vehicle Services—both with respect to the vehicle and your devices—and expressly waive and release us from any and all liability, claims, causes of action or damages in any way relating to our use of the precise location and other location-based services. You understand and agree that we may use location-based services, to the extent permitted by applicable law, to track, locate, measure driving behavior, or disable a vehicle used in connection with the Vehicle Services.

Dashcam Data.
You hereby expressly consent to our use of the dashcam device to capture dynamic driving data which may include biometric data as well as video recordings of the interior (including passenger occupants) and exterior of the vehicle (including front, right and left of the cab) collectively “dashcam data” in connection with your use of Vehicle Services. The use of this technology may constitute the capture of biometric identifiers under the Texas Capture or Use of Biometric Identifier Act, Bus. & Com. § 503.001 et seq., which defines a biometric identifier to include a record of face geometry. By using our Vehicle Services, you agree and consent to our collection and use of biometric identifiers. You understand and agree that we may use dashcam data, to the extent permitted by law, to assist in the investigation and defense of any vehicle accident claim and to promote safe driving behaviors by our Drivers. If you do not consent to our collection and use of your biometric identifiers, do not proceed with using our Vehicle Services. We will not sell, lease, or otherwise disclose your biometric identifiers to another person unless permitted by law. We will store, transmit, and protect from disclosure your biometric identifiers using reasonable care and in a manner that is the same as or more protective than the manner in which we store, transmit, and protect from disclosure other confidential and sensitive information. We will destroy the biometric identifiers within a reasonable time, but no later than the first anniversary of the date the purpose for collecting them expires, unless we are required by law to maintain them for a longer period of time.

Security.
We will make any legally required disclosures in the event of any compromise of personal information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

Indemnification and Hold Harmless.
You agree to indemnify and hold us and our parent and affiliates and their respective directors, officers, employees, agents, successors and assigns, harmless from all losses, liabilities, and expenses whatsoever (including without limitation reasonable attorneys’ fees) incurred by us arising out of or relating to the vehicle or your use of the vehicle during your reservation, including claims of or liabilities to third parties.

Limitation of Liability.
IN NO EVENT WILL THE COMPANY BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE, EXEMPLARY, OR CONSEQUENTIAL DAMAGES (INCLUDING WITHOUT LIMITATION LOST PROFITS) ARISING FROM OR RELATED TO THESE TERMS, THE SERVICES, OR YOUR USE OF ANY VEHICLE.

Personal Property.
We are not responsible for any loss or damage to any personal property in or around any vehicle or the premises where KINTO operates.

Disclaimer of Warranties.
Except as prohibited under applicable law, we HEREBY DISCLAIM ALL WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE.

Choice of Law.
To the extent permitted by applicable state law, these Terms shall be governed by and construed under the laws of the State in which the vehicle was located when the reservation began, without reference to its conflicts of laws provisions.

Arbitration.
You and us agree that any dispute arising out of or related to the Services or these Terms (including without limitation any dispute regarding arbitrability) will be resolved exclusively through final and binding arbitration (an “Arbitration”) and not in court, provided that either party may assert claims in small claims court in the jurisdiction where the vehicle was located when the reservation began, provided that all of such party’s claims in the aggregate qualify to be heard in such small claims court. The Federal Arbitration Act governs this Agreement.

THERE IS NO JUDGE OR JURY IN ARBITRATION. BY USING THE SERVICES AND AGREEING TO THESE TERMS, YOU ARE GIVING UP YOUR RIGHT TO HAVE ANY DISPUTE DECIDED IN A COURT OF LAW BEFORE A JUDGE OR JURY. Further, court review of any arbitration award is limited.

Any Arbitration will be resolved before one neutral arbitrator working for ADR Services, Inc. (“ADR”), and any Arbitration will be held in the county where the vehicle was located when the reservation began. To begin an Arbitration proceeding, you must do so in accordance with ADR’s arbitration rules then in effect, which will govern all aspects of the Arbitration, including payment of fees.

Notwithstanding anything herein to the contrary, the prevailing party, as determined by the arbitrator, shall be entitled to recover his, her, or its reasonable attorneys’ fees and costs and expenses incurred in connection with the Arbitration.

YOU AGREE THAT ANY ARBITRATION WILL BE CONDUCTED SOLELY ON AN INDIVIDUAL BASIS. IN NO EVENT MAY ANY ARBITRATION BE BROUGHT ON BEHALF OF A CLASS OR IN ANY OTHER CONSOLIDATED OR REPRESENTATIVE ACTION. THE ARBITRATOR MAY ONLY RELIEF IN FAVOR OF THE INDIVIDUAL PARTY SEEKING RELIEF AND ONLY TO THE EXTENT NECESSARY TO PROVIDE RELIEF TO REMEDY THAT PARTY’S INDIVIDUAL CLAIM(S).

Costs of Collection.
If you do not timely make any payment owed to us, you agree to pay for our reasonable costs incurred in seeking to collect such payments, including, without limitation, court costs and reasonable attorneys’ fees.

Amendments.
We may amend these Terms at any time. We will give notice of any such amendment, and you will have an opportunity to cease using the Services if you do not agree to the amended Terms. Your continued use of the Services constitutes your acceptance of these Terms. The prevailing version of these Terms will be found at kinto-us.com/terms-of-service.

No Waiver.
Our failure to exercise or enforce any right or provision of these Terms shall not constitute a waiver of such right or provision in that or any other instance.

Severability.
If any single part of these Terms is found to be invalid, illegal, or unenforceable, it shall not affect the validity of the rest of the Terms.

Privacy Policy

Effective November 1, 2023

1. SCOPE AND APPLICATION
This Privacy Policy describes how KINTO may collect, use, or disclose personal information from you through websites (including www.kinto-us.com/), mobile applications and other online or offline services offered by KINTO (collectively, the “Services”). This policy also describes your choices about the collection and use of such information.

Please note that KINTO is a service operated by Toyota Motor Credit Corporation (“TMCC”), but this Privacy Policy pertains only to Services provided by KINTO. For information about the privacy practices of TMCC or other Toyota affiliates, please visit the privacy disclosures posted at https://www.toyotafinancial.com/ or the privacy policy of other affiliates.

Please read this Privacy Policy carefully before you use our Services. By using the Services, you agree to be bound and abide by our posted Terms of Service (“Terms”), and this Privacy Policy. Your right to access or use the Services is terminated if you decline or violate these Terms or our Privacy Policy.

2. HOW WE COLLECT INFORMATION
We may collect information about you through the following categories of sources:

  • Directly or indirectly from you, through our Services both online (e.g., website, app) and offline (e.g., at locations we operate from);
  • From organizations that we may partner with to provide the Services to you;
  • From any vehicles you may use in connection with the Services;
  • By combining information from different sources, including online and offline data; and
  • From other sources that you may use to engage with us.

3. THE TYPES OF INFORMATION WE COLLECT
We may collect the following categories of information:

  • Profile and rental information, such as your name, mailing address, e-mail address, phone number, driver’s license, usage, membership information and other preferences (and username and password, or other user credentials, if we provide any access-restricted Services);
  • Background information, such as information provided on the application, Motor Vehicle Report and criminal background check information;
  • Transactional information including a history of all transactions you engage in with us through the Services including services purchased, obtained or considered, account balances and activity, as well as payment information (e.g., credit card or other financial account information and billing address) if you use the Services to make or receive payments;
  • Survey information in response to questions we may send you through the Services, including for research purposes or to improve our Services;
  • User Content that you may provide to publicly post via the Services if we permit (e.g., audio, photos, videos, comments, and other materials) along with any information you provide about yourself and the content—this may also include metadata associated with your content (such as location and date / time information embedded in pictures);
  • Promotional information we collect when you participate in a referral program (e.g., rebates) or in other contests we may offer;
  • Communications between you and us, such as via e-mail, mail, phone (e.g., recordings of calls with our customer service center) or other channels;
  • Offline activity you engage in with us, such as at locations we operate from;
  • Online User Activity described in the next section; and
  • Vehicle Data as described in section 5 below.

If you provide us with information regarding another individual, you represent that you have that person’s consent to give us his or her information and to permit us to use the information in accordance with this Privacy Policy.

4. AUTOMATED COLLECTION OF ONLINE USER ACTIVITY
We, our service providers and advertising partners may collect certain information about your device and use of our Services by automated means, including but not limited to cookies, pixels, SDKs and other similar technologies (“Online User Activity”). For example, a cookie is a file that may be placed on your device when using our Services to uniquely identify you or store information on your device for later retrieval. Cookies are very commonly used by websites and most browsers are configured by default to accept cookies.

When you use any website or app we provide, the information that we may collect by such automated means includes, for example:

  • Usage Details about your interaction with our Services (such as the date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
  • Device information and online identifiers including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, application performance data (page loading and selection success, etc.), operating system, browser type, mobile network information, the device’s telephone number and your choice of communication settings such as Wi-Fi, Bluetooth, and Global Positioning System (“GPS”));
  • Location information where you choose to provide us with information about your device’s location.

If you do not want information collected through the use of cookies, most browsers allow you to reject cookies, but if you choose to decline cookies, you may not be able to fully experience the features our Services provide. Because there is not yet a consensus on how organizations should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Certain advertising partners we use may be able to collect information about users’ online activities over time and across third-party websites.

5. VEHICLE DATA
This section provides additional terms applicable to those Services that involve the use of a vehicle (“Vehicle Services”) with respect to a user of those services (“Vehicle User”) and data associated with those individuals, vehicles and services (“Vehicle Data”). TO THE EXTENT YOU PARTICIPATE IN ANY VEHICLE SERVICES OFFERED BY STRATEGIC INNOVATION THAT ARE SUBJECT TO SPECIFIC TERMS OF SERVICE, THOSE TERMS WILL GOVERN IN THE EVENT OF ANY CONFLICT WITH THESE TERMS.

  • Additional Information
    In addition to the categories of personal information identified in the above sections, we may collect personal information before or during your use of Vehicle Services including, for example, (i) social security number, driver’s license number and expiration date, driver’s license image, date of birth, state or other government-issued identification card number, or other similar identifiers, (ii) information relating to a reservation, subscription or purchase of Vehicle Services, including services purchased, obtained or considered, account balances, payment history, or account activity, and other related information, and (iii) information collected from a vehicle and associated with a Vehicle User in connection with the Vehicle Services (e.g., dates, times and location of use, mileage, driving performance, driving record, criminal record, accidents and other data). We may collect such information from you, the vehicle, and as applicable from third parties such as background check providers and government agencies.
  • Location-Based Services
    You hereby expressly consent to our use of location-based services (including without limitation GPS systems) in connection with your use of Vehicle Services—both with respect to the vehicle and your devices—and expressly waive and release us from any and all liability, claims, causes of action or damages in any way relating to our use of the precise location and other location-based services. You understand and agree that we may use location-based services, to the extent permitted by applicable law, to track, locate, measure driving heavier, or disable a vehicle used in connection with the Vehicle Services.
  • Dashcam Data
    You hereby expressly consent to our use of the dashcam device to capture dynamic driving data which may include biometric data as well as video recordings of the interior (including passenger occupants) and exterior of the vehicle (including front, right and left of the cab) collectively “dashcam data” in connection with your use of Vehicle Services. The use of this technology may constitute the capture of biometric identifiers under the Texas Capture or Use of Biometric Identifier Act, Bus. & Com. § 503.001 et seq., which defines a biometric identifier to include a record of face geometry. By using our Vehicle Services, you agree and consent to our collection and use of biometric identifiers. You understand and agree that we may use dashcam data, to the extent permitted by law, to assist in the investigation and defense of any vehicle accident claim and to promote safe driving behaviors by our Drivers. If you do not consent to our collection and use of your biometric identifiers, do not proceed with using our Vehicle Services. We will not sell, lease, or otherwise disclose your biometric identifiers to another person unless permitted by law. We will store, transmit, and protect from disclosure your biometric identifiers using reasonable care and in a manner that is the same as or more protective than the manner in which we store, transmit, and protect from disclosure other confidential and sensitive information. We will destroy the biometric identifiers within a reasonable time, but no later than the first anniversary of the date the purpose for collecting them expires, unless we are required by law to maintain them for a longer period of time.

6. HOW WE USE THE INFORMATION THAT WE COLLECT
Except where otherwise noted, we may use the personal information that we obtain about you for the following business and commercial purposes as allowed by applicable laws:

  • Provide our Services to you, including for identity verification and to determine if you qualify for certain Services we offer, to manage your interactions with us, facilitate memberships, subscriptions, payments and other transactions with us, to link your account with third party services, general business operations and administration, and respond to your inquiries and other communications;
  • Engage in customer satisfaction and marketing activities, and tailor the content that we display to you in our Services and communications, including data analytics, industry and market research, lead generation, advertising, and offer services and information that we believe may be of interest to you;
  • Inform you about changes to this Privacy Policy, our Terms and other administrative developments;
  • Comply with and enforce as needed applicable legal requirements, industry standards, our policies, and our contractual rights, which includes, for example, for audit, compliance, policy, procedures, or regulation needs, to maintain the security our systems and services, and to investigate customer and insurance claims, fraudulent activities, and accidents;
  • Analyze and enhance our communications and strategies, such as by identifying when emails sent to you have been received, read or acted upon; and
  • Engage in data analytics to operate, evaluate, and improve our Services, including for customer analysis and modeling, credit risk management, customer applications and credit approvals, to monitor the performance of our Services through metrics such as total number of visitors, traffic, and demographic patterns, as well as optimize, diagnose or fix issues with the Services; and
  • Promote safety for our drivers and customers, by analyzing and detecting potentially dangerous conditions or behaviors, including providing real-time in-vehicle alerts.

We may also use or share information in an anonymized or aggregate manner for many purposes such as research, analysis, modeling, marketing, and advertising, as well as improvement of our Services.

7. ONLINE ADVERTISING
You may see us promoted by other organizations, on various websites, web pages, social media and other platforms. Please note that we do not always have complete information about where our organization may be displayed or promoted, and if you believe that our Services our featured in venues that are inappropriate or offensive, please contact us.

8. HOW WE SHARE YOUR INFORMATION
We will not disclose your personal information to third parties without your consent, except in the following circumstances.

  • We may share your information as permitted by law, including, for example, with our corporate affiliates, and with service providers that we believe need the information to perform a technology, business, or other professional function for us (examples include IT and cloud services, maintenance and hosting of our Services, background check providers, motor vehicle agencies, payment processors, shipping and returns partners, loyalty program operators, data analytics providers, marketing and training partners, social networks and other service providers). We only provide such vendors with information so they can perform their required functions on our behalf.
  • We may share your information with other companies that offer loyalty programs to offer those benefits in conjunction with our Services.
  • Subject to all applicable laws, we may provide a third party with information about a Vehicle User (including Vehicle Data) if: (a) there is a complaint, dispute or conflict, including an accident, relating to a Vehicle User; (b) it is necessary to enforce the terms of any agreement with the Vehicle User; (c) it is required, in our sole discretion, by applicable law, regulation, ordinance, license, or operating agreement; (d) it is necessary, in our sole discretion, to protect the safety, rights, property, or security of us, the Services, or any third party; to detect, prevent or otherwise address fraud, security or technical issues; and/or to prevent or stop activity which we, in our sole discretion, consider to be, or to pose a risk of being, illegal, unethical, or legally actionable.
  • We also may disclose information about you (i) if we are required to do so by law or legal process such as a subpoena, when we believe in good faith that disclosure is necessary or proper; (ii) when we believe disclosure is necessary to prevent harm or financial loss; (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity, including a violation of our Terms; or (iv) under exigent circumstances to protect the personal safety of our staff, users or the public.
  • We reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Policy.
  • Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us and applicable law.

9. COOKIES
Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile, or other devices (e.g., smartphones or tablets).

You can block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies you may not be able to access all or parts of the Site.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

10. YOUR PRIVACY CHOICES
We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

  • Account profile: Your online account profile may provide different options for the type of personal information you can provide as well as the types and methods of communication that you prefer. You may view or update your profile and privacy settings by logging in to your online account.
  • Marketing Emails: From time to time, we may contact you via email or through other channels for the purpose of providing announcements, promotional information and/or other general communication. In order to improve our Services, we may be notified when you open an email from us or click on a link therein. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us. Even if you opt out of receiving such communications, we may continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our terms of service.
  • Text messages: In the event you are enrolled in any service that provides text messages to you, you can opt-out by replying “STOP” to any text message received.
  • Cookies: Web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly.
  • Mobile devices: As with cookies, mobile devices may allow a user to block certain information requests or device permissions (e.g., location information), but doing so may adversely impact some features or functions offered by our Services. Mobile device or mobile operating system providers typically provide instructions on how to adjust such privacy features.

11. STATE-SPECIFIC NOTICES

  • Notice to California Residents
    The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

    The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

    Notice at Collection of Personal Information

    We currently collect and, in the 12 months prior to the Updated date of this Privacy Policy, have collected the following categories of Personal Information:

    • Identifiers (name, postal address, online identifier, Internet Protocol address, email address, Social Security number, driver’s license number)
    • Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)
    • Other type of state identification card number
    • Telephone number
    • Credit and debit card number
    • Internet or other electronic network activity information (information regarding consumer’s interaction with websites, application or advertisement)
    • Geolocation data
    • Commercial information (records of products or services purchased, obtained, or considered; transactional history)
    • Biometric information (imagery of face, voice recordings, from which an identifier template, such as a faceprint, or a voiceprint, can be extracted)(i.e. dashcam or vehicle recordings)
    • Characteristics of protected classifications under California or federal law (race, sex/gender), age (40 and older)
    • Audio, visual, or similar information (i.e. dashcam or vehicle recordings)
    • Sensitive Personal Information. Personal Information that reveals a Social Security number, driver’s license; precise geolocation

    We collect Personal Information directly from California residents directly and from any vehicles you may use in connection with the Services, background check providers, government entities advertising networks, internet service providers, data analytics providers, operating systems and platforms, social networks, and data brokers. We do not collect all categories of Personal Information from each source.

    In addition to the purposes stated above in the Section “HOW WE USE THE INFORMATION THAT WE COLLECT” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

    • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
    • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
    • Debugging to identify and repair errors that impair existing intended functionality
    • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing similar services
    • Undertaking internal research for technological development and demonstration
    • Undertaking activities to verify or maintain the quality or safety of a service that is controlled by us, and to improve, upgrade, or enhance the service that is controlled by us
    • Advancing our commercial or economic interests, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

    Disclosure of Personal Information

    The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the last Updated date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information.

    Category of Personal Information Categories of Recipients
    Identifiers (name, postal address, online identifier, Internet Protocol address, email address) Corporate affiliates; Payment processors; Background check providers; Motor vehicle agencies; Shipping and returns providers; Marketing providers; Cloud storage providers; Maintenance and hosting platform providers
    Identifiers (Driver’s license number) Background check providers; Motor vehicle agencies
    Identifiers (Social Security number) Background check providers
    Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology) Data analytics providers
    Telephone number Corporate affiliates; Marketing providers; Cloud storage providers; Maintenance and hosting platform providers
    Credit and debit card number Payment processors
    Geolocation data Cloud storage providers; Maintenance and hosting platform providers
    Commercial information (records of products or services purchased, obtained, or considered) Corporate affiliates; Marketing providers; Cloud storage providers; Maintenance and hosting platform providers
    Biometric information (imagery of face, voice recordings, from which an identifier template, such as a faceprint, or a voiceprint, can be extracted)(i.e. dashcam or vehicle recordings) Cloud storage providers; Maintenance and hosting platform providers
    Audio, visual, or similar information (i.e. dashcam or vehicle recordings) Cloud storage providers; Maintenance and hosting platform providers
    Sensitive Personal Information. Personal Information that reveals a Social Security number Background check providers
    Sensitive Personal Information. Personal Information that reveals a driver’s license Background check providers; Motor vehicle agencies

    We disclosed Personal Information for the following business or commercial purposes:

    • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
    • Debugging to identify and repair errors that impair existing intended functionality
    • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing similar services
    • Undertaking activities to verify or maintain the quality or safety of a service that is controlled by us, and to improve, upgrade, or enhance the service that is controlled by us
    • Advancing our commercial or economic interests, such as by inducing another person to buy, join, subscribe to, provide, or exchange products, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

    We do not collect, sell, or share the Personal Information of consumers under 16 years of age. We do not use Sensitive Personal Information for purposes other than those the CCPA and its regulations allow for.

    Retention of Personal Information

    We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

    Your Rights

    If you are a California resident, you have the following rights with respect to your Personal Information:

    1. The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
    2. The right to delete Personal Information that we collected from you, subject to certain exceptions;
    3. The right to correct inaccurate Personal Information that we maintain about you;
    4. If we sell or share Personal Information, the right to opt out of the sale or sharing;
    5. If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
    6. The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

    How to Submit a Request to Know, Delete, and/or Correct

    You may submit a request to know, delete, and/or correct through our CCPA Data Privacy Request webform available here or by calling us toll free at 1-855-546-8620.

    If you submit a request to delete online, you may be asked to confirm separately that you want your Personal Information deleted.

    If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

    Our Process for Verifying a Request to Know, Delete, and/or Correct

    If we determine that your request is subject to an exemption or exception, we will notify you of our determination. If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

    If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the Personal Information, we will ask you to re-authenticate yourself with respect to that account.

    If you do not maintain a password-protected account, or if you are an accountholder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.

    For requests to access categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

    For requests to access specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

    Notice of Financial Incentive

    From time to time, you may have the opportunity to provide Personal Information in exchange for discounts and price differences. For example, we provide discounts and price differences if you enroll in our loyalty programs. Categories of Personal Information that we may collect when you enroll in our loyalty programs include your name, email address, and telephone number.

    How to Opt-In and Right to Withdraw

    Signing up for discounts and price differences is optional. By providing your email address or telephone number during the loyalty program sign-up process, you affirmatively opt in to receiving the financial incentive and to joining our loyalty program. You have the right to withdraw from the financial incentive at any time. If you opt out of receiving a financial incentive, we will not reduce the value of any financial incentives you previously received from us. If you wish to withdraw from receiving the financial incentive, you may submit such a request at any time by emailing us at info@kinto-us.com.

    How the Financial Incentive is Reasonably Related to the Value of Your Personal Information

    The financial incentive or price difference is reasonably related to the value provided by your Personal Information. We take into consideration, without limitation, the anticipated revenue generated from such information, the anticipated expenses which we might incur in the collection, storage, and use of such information, and the anticipated expenses which we might incur related to the offer, provision, and imposition of any financial incentive or price difference. Based on this analysis, the value of your Personal Information that allows us to make these offers and financial incentives is the value of the offer itself.

12. CONFIDENTIALITY AND SECURITY
We endeavor to maintain reasonable administrative, technical and physical safeguards designed to protect the personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot ensure the security of any information you transmit to us, or guarantee that this information will not be accessed, disclosed, altered, or destroyed. We will make any legally required disclosures in the event of any compromise of personal information. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Services, you agree to accept notice in that form.

13. CHILDREN’S PRIVACY
Our Services are not directed to children under the age of sixteen (16) nor do we market our products or services to such children. We do not knowingly collect any data from or about children under the age of 16. If you believe that we might have any information from or about a child under 16, please contact us as directed below.

14. FOR APPLE IOS USERS
To comply with our legal and contractual obligations, we retain KINTO user accounts and user data in accordance with our data retention policies. We maintain this data to: (1) comply with applicable law (e.g., for tax reporting and product recalls) ; (2) protect against, identify, and prevent fraud and other criminal activity, claims and other liabilities (e.g., to identify use of our vehicles for illegal activities); (3) enforce our policies (e.g., to prevent vehicles from being taken out of the country); (4) investigate ongoing incidents (e.g., active police or insurance investigations); (5) honor our contractual obligations (e.g., to complete an active reservation by a customer); and (6) enforce contractual obligations (e.g., to collect unpaid bills, fees, tolls and citations from customers).

15. CHANGES TO OUR PRIVACY POLICY
As permitted by law, we may change this Privacy Policy by posting a revised version of the policy to our website. If the changes are material, we will endeavor provide notice of the changes on the website prior to the changes becoming effective. We encourage you to periodically review the Privacy Policy posted on the website for information about our privacy practices.

16. CONTACT US
If you have any questions, concerns or comments about this Privacy Policy, our privacy practices, or if you would like us to update information or preferences you provided to us, please contact us at info@kinto-us.com.