When you use MyWoosah, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices. This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. 

Overview: This overview applies to users of MyWoosah’s services, including users of MyWoosah’s app, website, features, or other services. 

This notice describes how MyWoosah, and its affiliates collect and use personal data. This notice applies to all users of our app, website, features, or other services unless covered by a separate privacy notice. 

This notice applies explicitly to: 

· Parents: individuals (families) who request or receive service through MyWoosah, including those who receive services in a shared capacity (see MyWoosah Share). 

· Care Providers: individuals who provide services to Parents (families) individually or through shared requests (see MyWoosah Share). 

This notice also governs MyWoosah’s other collections of personal data in connection with its services. For example, we may collect the contact information of individuals who subscribe via our website and mobile app but do not complete applications to be care providers; or other personal data connected with our matching technology and features. 

All those subject to this notice is referred to as “users” in this notice. In addition, please note the following: 

For California users: The California Consumer Privacy Act (CCPA) allows consumers in California to opt-out of certain sharing of their data. MyWoosah does not sell your data — we are not data brokers, and we don’t put your data on the open market. However, under the CCPA, some sharing of personal information necessary to provide you with personalized ads may be considered a “sale,” even if no money is exchanged. You may opt-out of such sharing. 

· If you opt out, MyWoosah will stop sharing your information with some of its advertising partners, and you will no longer receive personalized offers from MyWoosah on some sites or services. 

Questions, comments, and complaints about MyWoosah’s data practices can be submitted to 

Data collections and uses 

1. The data we collect 

MyWoosah collects personal data: 

· provided by users to MyWoosah, such as during account creation 

· created during the use of our services, such as location, app usage, and device data 

· from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities 

The following personal data is collected by or on behalf of MyWoosah: 

Data provided by users. This includes: 

· User profile: We collect data when users create or update their MyWoosah accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment, or banking information (including related payment verification information), social security number, and other identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of care providers, emergency contact information, user settings, and evidence of health or fitness to provide services using the MyWoosah app. 

· Background check and identity verification: To verify care providers’ eligibility to provide services through the MyWoosah app, we may collect information such as personal history or criminal record (where permitted by law), driver’s license status, known aliases and prior addresses, and right to work. This information may be collected by an authorized vendor on MyWoosah’s behalf. 

· We may also verify the identities of parents or service recipients by collecting photographs of their government-issued identification. 

· Demographic data: We may collect demographic data about users, including through user surveys. 

· User Content: We collect the data submitted by users when they contact MyWoosah customer experience, provide ratings or compliments for other users, or otherwise contact MyWoosah. This may include feedback, photographs, or other recordings collected by users, including audio or video recordings (such as from dashcams) submitted by users in connection with customer experience. This also includes metadata relating to the method you use to communicate with MyWoosah. 

2. Data created during the use of our services. This includes: 

· Location Data (Care Providers): We collect care providers’ and precise or approximate location data, including to enable our drive service, to enable drive service tracking and safety features, to prevent and detect fraud, and to satisfy legal requirements. MyWoosah collects this data when the MyWoosah app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device. 

· Location Data (Parents). We collect parent users’ precise or approximate location data to enable and enhance the use of our app, including to improve our services, facilitate service delivery, enable safety features, and prevent and detect fraud. 

· We collect such data from users’ mobile devices if they enable us to do so. (See “Choice and Transparency” below for information on how parents can enable location data collection). MyWoosah collects such data from the time a service is requested until it is finished (and may indicate such collection via an icon or notification on your mobile 

device, depending on your device’s operating system) and any time the app is running in the foreground (app open and on-screen) of their mobile device. 

· Parents may use the MyWoosah app without enabling MyWoosah to collect precise location data from their mobile devices. However, this may affect features in the MyWoosah app. For example, a user who has not enabled location data collection will have to manually enter their service address. In addition, the location data collected from a care provider during a drive service will be linked to the parent’s account, even if the parent has not enabled location data to be collected from their device, including for purposes of invoice generation, customer experience, fraud detection, insurance, and litigation. 

· Transaction Information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, payment transaction information (such as a restaurant’s or merchant’s name and location and amount of transaction), delivery information, date and time the service was provided, amount charged, distance traveled for drive service and payment method. 

· Usage Data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser. We may also collect data regarding the third-party sites or services used before interacting with our services, which we use for marketing. (Please see “How We Use Data” below for more information on how we market our services to users). 

· In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Notice. 

· Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data. 

· Communications data: We enable users to communicate with each other and MyWoosah through MyWoosah’s mobile app and website. For example, we enable care providers and parents to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, MyWoosah receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. MyWoosah may also use this data for customer support experience (including to resolve disputes between users), for safety and security purposes, to improve our services and features, and for analytics. 

3. Data from other sources. These include: 

· Users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s personal data from that user. 

· MyWoosah account owners who request services for or on behalf of other users or who enable such users to request or receive services through their accounts. 

· Users or others providing information in connection with claims or disputes. 

· vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements 

· insurance, vehicle, or financial services providers for care providers 

· publicly available sources 

· marketing service providers or data resellers whose data MyWoosah uses for marketing or research 

· law enforcement officials, public health officials, and other government authorities 

MyWoosah may combine the data collected from these sources with other data in its possession. 

1. How we use personal data 

MyWoosah uses personal data to enable reliable and convenient service delivery and other products and services. We also use such data: 

· to enhance the safety and security of our users and services 

· for customer experience 

· for research and development 

· to enable communications between users 

· to send marketing and non-marketing communications to users 

· in connection with legal proceedings 

MyWoosah does not sell or share user personal data with third parties for their direct marketing, except with users’ consent. 

We use personal data we collect: 

1. To provide our services. MyWoosah uses data to provide, personalize, maintain, and improve our services. 

This includes using data to: 

· create/update accounts 

· enable the delivery of services (such as using location data to facilitate our drive service), features that involve data sharing (such as ratings and compliments), and accessibility features to facilitate the use of our services by those with disabilities 

· process payments 

· track and share the progress of service deliveries 

· facilitate insurance, vehicle, invoicing, or financing solutions 

· perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends. 

MyWoosah performs the above activities, including the collection and use of location data for purposes of these activities, on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users. 

2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes: 

· verifying users’ identity and eligibility to provide services, including through reviews of background checks, where permitted by law, to help prevent the use of our services by unsafe care providers or parents. 

· using device, location, user profile, usage, and other data to prevent, detect, and combat fraud. This includes identifying fraudulent accounts or uses of our services, preventing the use of our services by unauthorized care providers, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts. 

· using user ratings, reported incidents, and other feedback to encourage compliance with our Terms of Use and as grounds for deactivating users with low ratings or who otherwise violated such terms. 

· sharing information regarding serious care provider safety incidents or compliance with local regulations with third parties, including other companies who enable users to request or provide services, or intermediaries who collect and report such information for multiple companies, to prevent care providers who may pose a safety risk to the platform or its users from using MyWoosah’s or those other companies’ services. We may also share with third parties, including those affected by such incidents, whether the incidents result in account deactivation. 

· using ratings, usage, and other data to prevent matching of parents and care providers for whom there is higher risk of conflict (for instance, because one user previously gave the other a one-star rating). 

MyWoosah performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users and or for purposes of the legitimate safety and security interests of MyWoosah or other parties, including users and members of the general public. 

3. Customer Experience. MyWoosah uses the information we collect (which may include call recordings) to provide customer experience, including to investigate and address user concerns and to monitor and improve our customer support responses and processes. 

MyWoosah performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users. 

4. Research and development. We may use personal data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easier-to-use, enhance the safety and security of our services, and develop new services and features. 

MyWoosah performs the above activities on the grounds that they are necessary to fulfil our obligations to users under our Terms of Use or other agreements with users in improving our existing services and features, or for purposes of MyWoosah’s legitimate interests developing new services and features. 

5. Enabling Communications Between Users. For example, a Care Provider may message or call a Parent to confirm a service location, a Parent may contact a Care Provider to provide service information. 

MyWoosah performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users. 

6. Marketing. MyWoosah may use personal data to market our services to our users. This includes sending users communications about MyWoosah services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may do so through various methods, including email, text messages, push notifications, in app communications and ads, and ads on third party platforms. 

We may also inform users about products and services offered by MyWoosah partners. For example, we may provide recommendations, promotions, or ads for MyWoosah partners based on users’ past services. Although we inform users about products and services offered by MyWoosah partners, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent. 

We may use the data we collect, including in combination with advertising partners’ data, to personalize and improve the marketing communications (including ads) that we send on and off MyWoosah’s app and website, including based on user location, use of MyWoosah’s services, and user preferences and settings. For example, we share user data (such as hashed email address, usage information, and device or user identifiers) with Facebook and TikTok to personalize and improve our ads for MyWoosah’s services. 

For information about how to opt out of certain marketing communications (including ads) from MyWoosah and its advertising partners, please see the section titled “Marketing choices.” 

MyWoosah performs the above activities on the grounds that they are necessary for purposes of MyWoosah’s legitimate interests in informing users about MyWoosah services and features or those offered by MyWoosah partners, or on the basis of user consent. See the sections titled “Choice and transparency” and “Marketing choices” for information on your choices regarding MyWoosah’s use of your data for marketing. 

7. Non-Marketing Communications. MyWoosah may use personal data to generate and provide users with invoices; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of MyWoosah or its partners. MyWoosah performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users, or for purposes of MyWoosah’s and its users’ legitimate interests in informing users about events that may have an impact on how they can use MyWoosah services. 

8. Legal Proceedings and Requirements. We may use personal data to investigate or address claims or disputes relating to use of MyWoosah’s services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement. 

MyWoosah performs the above activities on the grounds that they are necessary for purposes of MyWoosah’s legitimate interests in investigating and responding to claims and disputes relating to use of MyWoosah’s services and features, and or necessary for compliance with applicable legal requirements. 

9. Automated Decision-Making 

We use personal data to make automated decisions relating to use of our services. This includes: · enabling dynamic pricing, in which the price of a service, or the service fee for MyWoosah’s services. 

· matching available Care Providers to users requesting services. Users can be matched based on availability, proximity, and other factors such as likelihood to accept a service based on their past behavior or preferences. Please see here for further information about our matching process. 

· determining user ratings, and deactivating users with low ratings. For more information about how ratings are determined and used, please see the section below titled “Ratings look-up” for further information. 

· flagging users who are identified as having engaged in fraud, unsafe activity, or other activities that may harm MyWoosah, its users, and others. In some cases, such as when a user is determined to be abusing MyWoosah’s referral program or has submitted fraudulent documents, such behavior may result in automatic deactivation. 

· using Care provider location information, and communications between Parents and Care Providers, to identify payment earned or induced through fraud. For example, if we determine by using such information that a Care Provider is overestimating their time, we will not charge the Parent the corresponding additional charges and will adjust the amounts paid to the Care Provider to omit such additional charges. To object to such an adjustment, please contact MyWoosah customer Experience. 

· Using Care Provider data (such as location, rating and gender) and Parent data (such as rating, service type, and service location) to help avoid pairings of users that may result in increased risk of conflict. 

To object to a deactivation resulting from these processes, please contact MyWoosah Customer Experience. 

MyWoosah performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users, or on the grounds that they are necessary for purposes of the legitimate interests of MyWoosah, its users and others. 

1. Cookies and third-party technologies 

MyWoosah and its partners use cookies and other identification technologies on our app, website, emails, and online ads for purposes described in this notice. 

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. MyWoosah uses cookies and similar technologies for purposes such as: 

· authenticating users 

· remembering user preferences and settings 

· determining the popularity of content 

· delivering and measuring the effectiveness of advertising campaigns 

· analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services 

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services. 

1. Data sharing and Disclosure 

Some of MyWoosah’s services and features require that we share personal data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes. 

MyWoosah may share personal data: 

1. With other users 

This includes sharing: 

· Parent’s first name, rating, and service locations with care providers 

· Parent’s first name with other Parents in a Shared service. Parents in shared services may also see the service location of the other Parents. 

· for Care Providers, we may share data with the Parent(s), including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and service); average rating provided by users; total number of service requests completed; period of time since they signed up to be a Care Provider; contact information (if permitted by applicable laws); and Care Provider profile, including compliments and other feedback submitted by past users. 

· We also provide Parents with invoices containing information such as a breakdown of amounts charged, Care Provider first name, photo, and service locations. We also include other information on those invoices if required by law. 

· for those who participate in MyWoosah’s referral program, we share certain personal data of referred users, such as service request count, with the user who referred them, to the extent relevant to determining the referral bonus. 

2. At the User’s Request 

This includes sharing data with: 

· Other people at the user’s request. For example, we share a user’s location with a friend when requested by that user, or a user’s service information when they share a service with a friend. 

· MyWoosah business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, MyWoosah may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or other MyWoosah business partners and their users in connection with promotions, contests, or specialized services. 

· Emergency Services: We offer features that enable users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”. 

3. With the General Public 

Questions or comments from users submitted through public forums such as MyWoosah blog and MyWoosah social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user. 

4. With the MyWoosah Account Owner 

If a user requests services using an account owned by another party, we may share their service request information, including location and service data, with the owner of that account. This occurs, for example, when: 

· a Parent uses a service arranged by a friend or under a Shared Account 

5. With MyWoosah Subsidiaries and Affiliates 

We share personal data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, MyWoosah processes and stores such data in the United States on behalf of its international subsidiaries and affiliates. 

6. With MyWoosah Service Providers and Business Partners 

MyWoosah provides personal data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include: 

· payment processors and facilitators 

· background check and identity verification providers 

· cloud storage providers 

· Google, in connection with the use of Google Maps in MyWoosah’s app (see Google’s privacy policy for information on their collection and use of data) 

· social media companies, including Facebook and TikTok, in connection with MyWoosah’s use of their tools in MyWoosah’s app and website (see Facebook’s and TikTok’s privacy policies for information on their collection and use of data) 

· Marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness 

· research partners, including those performing surveys or research projects in partnership with MyWoosah or on MyWoosah’s behalf 

· vendors that assist MyWoosah to enhance the safety and security of its app 

· consultants, lawyers, accountants, and other professional service providers 

· insurance and financing partners 

· hotels 

7. For Legal Reasons or in the Event of a Dispute 

MyWoosah may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. 

This includes sharing personal data with law enforcement officials, public health officials, other government authorities, hotels, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect MyWoosah’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to use of another person’s credit card, we may be 

required by law to share your personal data, including service information, with the owner of that credit card. 

This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company. 

8. With Consent 

MyWoosah may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing. 

1. Data Retention and Deletion 

MyWoosah retains user data for as long as necessary for the purposes described above. 

Users may request deletion of their accounts at any time. MyWoosah may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy. 

MyWoosah retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, and the purposes for which we collected the data. 

Users may request deletion of their account at any time through the Menu > Settings > Delete Account section in the MyWoosah app. Following an account deletion request, MyWoosah deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to Care Providers, this generally means that we retain their account and data for a minimum of 7 years after a deletion request. For Parents, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons. 

1. Choice and Transparency 

MyWoosah enables users to access and or control data that MyWoosah collects, including through: 

· privacy settings 

· device permissions 

· in-app ratings pages 

· marketing choices 

MyWoosah also enables users to request access to or copies of their data, changes or updates to their accounts, or deletion of their accounts, or that MyWoosah restricts its processing of user personal data. 

1. Privacy Settings 

The Menu > Settings menu in the MyWoosah app allows users to set or update their preferences regarding location data collection and sharing, emergency data sharing, and notifications. 

· Location Data Collection (Parents) 

Parents can enable/disable MyWoosah to collect location data from their mobile devices through their device settings, which can be accessed via the Settings > Privacy > Location menu. 

· Share Live Location (Parents) 

Parents can enable/disable MyWoosah to share their real-time location data from their mobile devices with their Care Providers through their device settings, which can be accessed via the Settings > Privacy > Location menu. 

· Emergency Data Sharing 

Parents may enable MyWoosah to share real-time location data from their mobile devices with emergency police, fire, and ambulance services. Such data may include approximate location at the time the emergency call was placed; the parent’s name and phone number; location; and the Care Provider’s name. Parents may enable/disable this feature via the Menu > Settings > Location menu. 

· Notifications: Account and Service Updates 

MyWoosah provides users with service status notifications and updates related to activity on their account. These notifications are a necessary part of using the MyWoosah app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Menu > Settings > Notification Settings. 

· Notifications: Discounts and News 

Users may enable MyWoosah to send push notifications about discounts and news from MyWoosah. Push notifications may be enabled or disabled through the Menu > Settings > Notification Settings in the MyWoosah app. 

2. Device Permissions 

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider. 

3. In-App Ratings Pages 

After every service, Care Providers and Parents are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, Parent ratings are available to Care Providers from whom they request services, and Care Provider ratings are available to their Parents. This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for Care Providers and Parents. 

Care Providers can see their average rating in the main menu of the MyWoosah app. 

Care Providers can see their average rating in their profile in the MyWoosah app. 

4. Marketing Choices 

Users may opt out of certain marketing communications (including ads) and use of their data for marketing in the following ways: 

· Ad Settings: These settings enable users to choose whether their data is shared with MyWoosah’s advertising partners to deliver personalized ads, and or to measure the effectiveness of such ads. 

· Marketing Emails and Messages: To opt out of receiving marketing emails from MyWoosah, or for instructions on how to set your preferences regarding whether to receive marketing SMS or push notifications from MyWoosah, contact our Customer Experience team. Users may also opt out of receiving emails and other messages from MyWoosah by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for rides or information about their account. 

· Cookies and Related Technologies: For information on how to opt out of personalized ads using cookies and related technologies, please contact our Customer Experience team. 

5. User Personal Data Requests 

MyWoosah provides users with a variety of ways to learn about, control, and submit questions and comments about MyWoosah’s handling of their personal data. 

· Accessing Data: Users can access data including their profile data and trip or order history through the MyWoosah app or via MyWoosah’s website. 

· Changing or Updating Data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in MyWoosah’s app or profile portal. 

· Deleting Data: Users may request deletion of their account at any time through the Menu > Settings > Delete Account section in the MyWoosah app. 

· Objections, Restrictions, and Complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. This includes objecting to our use of personal data that is based on MyWoosah’s legitimate interests. MyWoosah may continue to process data after such objection or request to the extent required or permitted by law. 

· In addition, depending on their location, users may have the right to file a complaint relating to MyWoosah’s handling of their personal data with the data protection authority. 

1. Updates to this notice 

We may occasionally update this notice. 

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the MyWoosah app or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.