Twisted Road Policies
Last Updated: May 23, 2018
We, either directly or through third party companies and individuals we engage to provide services to us, collect, process, or retain Personal Information from you and any devices you may use when you use our Services. The Personal Information we collect may include the following:
Personal Information that you give us (whether manually or automatically) when you access or use our Services;
Identifying information, such as your name, address, telephone number, and email address, when you register for an account with us;
Information you provide during a transaction, or other transaction-based content that you generate, or that is connected to your account as a result of a transaction you are involved in, such as listing a motorcycle, renting a motorcycle from one of our users, adding items to your Favorites, creating reviews, or uploading Trip Photos;
Financial information (such as payment card numbers) in connection with a potential or actual transaction, which is stored and processed by a third-party payment services provider; and
Bank account information provided by vehicle owners to receive payments, which is stored by a third-party digital payments company.
In some instances, when you use our Services, we may ask you to provide us with a photograph and/or other demographic information, such as a scanned copy of a driver’s license, passport, or credit/debit card, the last four digits of your social security number, social insurance number, social media account information, driver’s/motor vehicle record, insurance information, and other forms of identification. Where we request that you withhold certain information when providing us with personally identifiable information (such as obscuring or redacting all but the last four digits of your payment card number), please do so.
If you opt in to use our Location Sharing feature, we will collect geo-location data, including location information from your mobile device, and information about the location and movement of your vehicle or the vehicle you are renting during a rental period, based upon the movement of your mobile device for the purpose of allowing travelers and owners to share information with one another about their location.
Keep in mind that most mobile devices allow you to control or disable the use of location services by any application on your mobile device in the device’s settings menu.
If you communicate with Twisted Road’s customer service via telephone, we may record your telephone call for quality assurance, documentation, recordkeeping, and/or training purposes. If you do not wish to have your telephone call recorded, please do not communicate with us via telephone and instead communicate with our customer support via firstname.lastname@example.org.
When you access our Platform, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, clear gifs, pixel tags, e-tags, “Flash cookies”, or other local storage provided by your browser or associated applications (collectively, “Cookies”). We use these technologies to recognize you as a customer, to customize our Services, to measure promotional effectiveness, to help ensure that your account security is not compromised, to mitigate risk and prevent fraud, to promote trust and safety across our Services, and for other content and marketing purposes.
We may also collect from you any other Personal Information you choose to provide to us or our service providers, or that we are otherwise permitted or required to collect by applicable law.
Retention, Use, & Processing
Our primary purpose in collecting personal information is to provide our users with a secure, smooth, efficient, and customized experience. For example, we may use your Personal Information to:
- provide Twisted Road Services and customer support;
- process transactions and send notices about your transactions;
- verify your identity, including during account creation and password reset processes;
- resolve disputes, collect fees, and troubleshoot problems;
- manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
- improve the Services, including by customizing your user experience;
- measure the performance of the Services and improve our content and layout;
- manage and protect our information technology infrastructure;
- foster a trusted and safe environment for our Services, such as by detecting and preventing actual and potential fraud and other harmful activity, conducting investigations and risk assessments, enforcing our Terms or Service and policies, verifying any identification documents provided by you, and conducting checks against databases and information sources (including, but not limited to, public government databases) for fraud detection and prevention, risk assessment and harm prevention purposes, in each case with or without further notifying you as permitted by applicable law;
- provide targeted marketing and service update notices, and to deliver promotional offers based on your communication preferences;
- contact you at any telephone number or email address that you provide, including by placing a voice call or through text (SMS) or email messaging, as authorized by our Terms of Service;
- perform creditworthiness and solvency checks, compare information for accuracy, and verify such information with third parties;
- endeavor to verify your identity, through the use of a background check or otherwise;
- send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- enable you to communicate with other Twisted Road users, including, but not limited to, by sending them messages or other information during the booking process;
- administer referral programs, rewards, surveys, contests, or other promotional activities or sponsored events;
- comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements;
- carry out any other purpose which is disclosed to you and to which you consent; and
- carry out any other purpose permitted or required by law, which may include laws outside your country of residence.
We, either directly or through third party companies and individuals we engage to provide services to us, may contact you via electronic means, telephone, or postal mail to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to service your account. Additionally, we may contact you to offer coupons, discounts, and promotions, and to inform you about Twisted Road Services. Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with you. When contacting you via phone, to reach you as efficiently as possible we may use, and subject to applicable law, you hereby consent to receive, autodialed or prerecorded calls and text messages as described in our Terms of Service. Where applicable and required by law, you may decline to receive certain communications. Standard telephone minute and text and data charges may apply.
We retain your Personal Information as long as it is necessary and relevant for our operations. In addition, we may retain Personal Information from closed accounts to comply with applicable laws, detect or prevent fraud, collect any fees owed, resolve disputes, assist with or process claims, troubleshoot problems, assist with any investigation, comply with audits and investigation, to enforce our Terms of Service, and take other actions reasonably necessary to comply with, or otherwise permitted or required by, applicable law.
Third Party Advertising
We may use third-party advertising companies to serve advertisements regarding our Services when you access and use the Services and third party websites, based on information relating to your access to and use of the Services and third party websites. To do so, these companies may place or recognize a unique Cookie on your browser (including through use of pixel tags).
You have certain choices about how we use your Personal Information to communicate with you, to send you marketing information, and to provide you with a customized experience. You can control the methods by which we may contact you about your account, your rental activities, promotions, and other announcements in the Notifications section within your Twisted Road account. You may also access, update, and correct your registration or other Personal Information by logging into your Twisted Road Account.
You can access, review, correct, update, and edit certain Personal Information that has been previously provided to us by you at any time by logging in to your account and reviewing your account settings and profile. You can also access or request a correction of your Personal Information by contacting us at email@example.com. For your protection, we may need to verify your identity before responding to your request. If you wish to close your account, please contact us at firstname.lastname@example.org. Please note that we may need to retain certain information for record keeping, trust and safety, dispute resolution, payment, or other business purposes. There may also be residual information that will remain within our databases and other records, which will not be removed.
Your public listing page will always include some basic information, such as your user ID/name associated with your account, your public profile photo, and for owners, the city where your motorcycle is located, your listing description, your calendar availability, transaction-related information to allow our community to evaluate your reliability and responsiveness, and reviews/feedback. Your public listing page may also include aggregated demand information (such as number of page views over a period of time) and information about your cancellations. Our Services may also display the approximate geographic pick-up location of an owner’s vehicle on a map.
Our Services allow your public profile and public listing pages to be included in search engines, in which case your public profile and public listing pages may be indexed by search engines and may be published as search results.
Twisted Road enables motorcycle owners to offer and rent their vehicles to other individuals. If you agree to a rental transaction through the Services, we may provide your Personal Information to the other party in that transaction as reasonably necessary to facilitate the transaction. For example, Twisted Road may provide your mobile phone number and/or driver’s license information to facilitate communication, or your photograph to facilitate identification. We will provide the address of the vehicle and/or the proposed delivery location. We may also share user-uploaded “Trip Photos”, including captions, with the other party involved in the rental transaction if that feature is selected. Twisted Road users engaged in a rental transaction with you may send you text message (such as to confirm pickup or delivery location). Standard telephone minute and text and data charges may apply.
We may share Personal Information with vendors and service providers who are engaged by, or working with, us in connection with the operation of our Services and customer support functions and who need access to such information to carry out their work for us. In some cases, the service provider may be directly collecting the information from you on our behalf. For motorcycle owners who choose to use our photography program, your contact information will be shared with the photographer assigned to shoot your vehicle. These service providers may be located inside or outside your country of residence, including outside the EEA.
Change of Ownership
We may disclose and transfer information that you provide to us, including Personal Information, as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business (whether as a going-concern or not) or as part of a corporate reorganization, stock sale or other change in control.
We have endeavored to put into place reasonable security measures in an effort to protect Personal Information against unauthorized access, destruction, or alteration while it is under our control. However, no method of transmission over the Internet, and no method of storing information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us or of your Personal Information that we store.
We are not responsible for any unauthorized disclosure of Personal Information or other information caused by any third party. Your account information is accessible online through the use of a password. To protect the confidentiality of Personal Information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of our Services by any person using your password or your account. Please advise us immediately at email@example.com if you believe your password has been misused. We are not responsible for your failure to comply with this clause, or for any delay in shutting down your account after you have reported a breach of security to us.
Lodging a Complaint
Subject to applicable law, you also have the right to lodge a complaint with your local data protection authority or the European Data Protection Supervisor. If you are a resident of the EEA and believe we maintain your information within the scope of the General Data Protection Regulation, you may direct questions or complaints to:
European Data Protection Supervisor
Rue Wiertz 60
Office: Rue Montoyer 63, 6th floor
Tel. +32 2 283 19 00
Fax +32 2 283 19 50
The Services are controlled and operated by us from the United States, and are not intended to be subject to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country. As a result, this information may be subject to access requests from governments, courts, regulatory agencies, security authorities or law enforcement in those jurisdictions according to the laws in those jurisdictions.
We ask that you not send us, and that you not disclose, any sensitive Personal Information (e.g., social security numbers, social insurance numbers, passports, information related to racial or ethnic origin, political opinions, religion, trade union membership or other beliefs, health, biometrics, or genetic characteristics) on or through the Services unless specifically requested by us and in accordance with applicable law.
This section describes some additional important privacy information related to your use of our Services.
How you should use the information you receive on Twisted Road:
You may use the Personal Information that you have access to only for Twisted Road transaction-related purposes, or for other services offered through Twisted Road (such as complaints, claims reporting, dispute resolution, and user-to-user communications). Using Personal Information of other users that you have access to for any other purpose constitutes a violation of our Terms of Service. You are solely responsible for your use of any Personal Information you find on our Services and for complying with all applicable laws when using such information.
Unwanted or threatening email:
Our websites are general audience websites, and our Services are not intended for anyone under the age of 18. We do not knowingly collect Personal Information from users under the age of 18. If a child has already provided us with Personal Information, his or her parent or guardian may contact us at firstname.lastname@example.org the purpose of deleting this information or closing an account.
Third Party Privacy Practices
We cannot guarantee the privacy or security of your information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of your trading partner and any third parties you deal with or whose sites you visit before entering into a transaction and choosing to share your information.
Twisted Road welcomes your questions and comments about privacy, and what we do. Please feel free to contact us at email@example.com. If you need to reach us by mail in regards to privacy questions, please write to us at 1001 Green Bay Road, Suite 300, Winnetka, IL 60093.