Wagon Technologies LLC and its affiliates and subsidiaries (collectively, "Wagon," "we," "us," or "our") respect your privacy and are committed to being transparent about how we collect, use, disclose, and protect your information when you use our websites, mobile applications, connected vehicles, hosted dashboards, customer support channels, and related services (collectively, the "Services").
This Privacy Policy explains what information we collect, how we use it, when we disclose it, and the choices available to you. This Privacy Policy applies only to the Services and does not apply to third-party websites, apps, platforms, or services that may link to or integrate with the Services but are governed by their own privacy notices.
By using the Services, you acknowledge that Wagon may collect, use, disclose, and otherwise process your information as described in this Privacy Policy and our Terms of Use.
We may update this Privacy Policy from time to time. If we make material changes, we will post an updated version with a revised effective date and provide additional notice where required by law.
Information We Collect
The information we collect depends on how you interact with the Services, the products or vehicles you use, the permissions you grant, and the features available in your area.
1.1 Information You Provide to Us
We may collect information you provide directly to us, including:
- Your name, email address, mobile phone number, mailing address, date of birth, and account login credentials;
- Payment and billing information, such as payment card details, billing zip code, transaction details, and related billing information;
- Customer support communications, survey responses, contest or promotion entries, reviews, social media interactions, and other content you choose to submit;
- Business or employer information if you participate in a corporate, hospitality, resort, or other business-sponsored program;
- Information submitted in connection with claims, incidents, safety investigations, traffic or parking violations, or disputes;
- If enabled for Vehicle rental eligibility, information you provide when you use your phone or other device to photograph, record, or otherwise document the condition of the Vehicle in connection with the Services, including images, video, associated metadata (such as time, date, and location), and any related comments or descriptions you submit;
- If required for eligibility, fraud prevention, age verification, driver qualification, or compliance purposes, government-issued identification such as a driver’s license, passport, or state-issued identification card, including associated document details and images;
- If enabled for a particular feature, a selfie, photograph, or short video used to verify identity, confirm age, compare against your government-issued identification, or confirm compliance with ride or safety requirements;
- If you apply to work with us or serve as a fleet, charging, maintenance, or logistics provider, professional, tax, insurance, banking, licensing, and related onboarding information.
1.2 Information We Collect Automatically
When you use the Services, we and our service providers may automatically collect certain information, including:
- Device, browser, and network information such as IP address, device identifiers, operating system, app version, browser type, mobile carrier, language settings, and crash or diagnostic information;
- Usage information such as pages viewed, buttons clicked, ride or reservation activity, session timestamps, referral URLs, and interactions with features or content;
- Approximate location inferred from IP address;
- Precise location information from your mobile device, vehicle, Bluetooth, GPS, Wi-Fi, or similar technologies, where enabled or permitted;
- Vehicle telemetry and trip data, including reservation details, unlock and lock times, route information, start and end locations, travel direction, speed, braking or event logs, parking information, and vehicle status or health data;
- Cookie, pixel, SDK, log, and similar tracking data used for authentication, analytics, fraud prevention, performance monitoring, personalization, and advertising.
1.3 Vehicle Connectivity and Telematics Data
Wagon Vehicles may be equipped with connected hardware, telematics, sensors, or other IoT-enabled technology, and Wagon may automatically collect information from the Vehicle and associated systems including vehicle identifier, ignition status, unlock and lock events, battery level and charging status, speed, movement, route history, geofence entry or exit, parking location, vehicle diagnostics, fault codes, maintenance alerts, remote commands, and other operational or safety-related event data. Wagon uses this information to provide and secure the Services, monitor fleet availability and vehicle health, enforce ride, parking, and geofencing rules, detect misuse or unauthorized activity, investigate incidents and claims, recover lost or stolen Vehicles, improve safety, and support customer service, billing, and business operations.
Camera, Image, and Environmental Data
Wagon may collect photographs, video, image files, and related metadata (such as timestamps, geolocation, and device information) when you, a Vehicle, or the Services use a camera, image capture tool, or similar feature. This may include photographs or video of the Vehicle before, during, or after a rental; the place where a Vehicle is parked or returned; surrounding conditions; roadway, path, curb, or property conditions; and other safety- or service-related imagery. Wagon uses this information for ride completion, return verification, parking compliance, fleet management, safety review, damage assessment, claims handling, fraud prevention, dispute resolution, and service improvement.
If a feature requires identity verification, age verification, helmet verification, or similar safety verification, we may collect and process selfies or photographs for those purposes.
1.4 Information From Third Parties
We may receive information about you from third parties, including:
- Payment processors and fraud prevention providers;
- Identity verification providers and age-verification providers;
- Business partners, resorts, communities, hotels, golf courses, clubs, municipalities, public authorities, and platform partners through which you access the Services;
- Social media platforms or single-sign-on providers if you choose to connect or log in through them;
- Marketing, analytics, and advertising partners;
- Law enforcement, insurers, claims administrators, and other parties involved in an incident, dispute, or legal request.
How We Use Information
We use your information to provide, operate, maintain, and improve our Services, including:
2.1 Products, Services, and Customer Support
We use Personal Information to provide, maintain, and improve our services, such as to:
- Establish and maintain your account
- Deliver a vehicle to you that you have rented from us
- Confirm your identity
- Verify your eligibility to rent a vehicle from us
- Rent a vehicle to you
- Troubleshoot and resolve your questions or concerns
- Provide and operate our websites, mobile apps, and related features
- Track our vehicles’ location and availability
- Monitor vehicle health and statuses
- Process payments you make to us
- Provide services to you
- Comply with our agreements with you
- Enforce geofenced operating areas, no-drive zones, no-parking zones, or speed restrictions
- Review and compare rider-submitted photos, telemetry, timestamps, and related records in connection with damage claims, vehicle condition disputes, improper parking, policy violations, or incident investigations
- Detect unauthorized operation, tampering, theft, overdue rentals, or misuse of Vehicles and support recovery of Vehicles and related assets
- Administer resort, club, community, hospitality, or other hosted rental programs, including eligibility validation, billing support, ride reporting, and incident management
- Disclose information to a host venue or program sponsor as reasonably necessary to enforce local operating, parking, charging, access, and safety rules applicable to that venue or program.
2.2 Consumer Marketing Messages and Other Communications
Wagon may communicate with you about:
- Vehicle rental, purchase, or use
- Questions, complaints, or issues you may have
- Changes to our policies
- Your opinions about your experiences with us
- Third-party marketing offers (subject to your consent where required by law)
- Send to you information, news, updates, and offers about us or our services (subject to your consent where required by law)
- Conduct data analyses to better predict content and marketing offers that may interest you
- Personalize content, experiences, and marketing offers to you, including providing you reports, recommendations, and feedback based on your preferences
- Provide more relevant ads to you
2.3 Research and Innovation
- Improve vehicles, products, and services
- Develop new vehicles, products, and services
- Optimize or improve our products, services, and operations
- Help us understand how our products and services can better meet the needs of our customers and cities through statistical, demographic, and marketing analyses of our products and services, app and website use, rider activity, vehicle routes, and demographic trends, for research, analytical, and statistical purposes
2.4 Business Operations and Legal Compliance
- Manage and protect our networks, services, employees, and users
- Detect, investigate, take action regarding, and prevent illegal activities, misuse, suspected fraud, or situations involving potential threats to the safety or legal rights of any person or entity
- Comply with the law and fulfill lawful requests for information
- Permit you to update, edit, and manage your content
- Conduct research and perform data analyses to better understand our customers and how our vehicles, products, services, websites, and mobile apps are used
- Create pseudonymous, anonymous, and aggregate information about our customers’ use of our vehicles, products, services, websites, and mobile apps
- Use as evidence in litigation
- Investigate, enforce, and prevent violations of our policies and terms (including this Privacy Policy, our Terms of Use, and Rental Agreement)
- Establish, protect and defend our legal rights
- Confirm your identity
- Verify eligibility of job applicants
2.5 Transaction and Services Communications
Wagon may send you Transactional or Service-related Communications by email, text message, push notification, in-app message, or other means regarding your account, reservations, rentals, ride activity, receipts, support requests, safety alerts, incident follow-up, service announcements, vehicle availability, policy updates, or other operational matters. These communications are distinct from promotional marketing communications, and Wagon may send them even if you opt out of receiving marketing messages, to the extent permitted by law.
2.6 Legal Bases for Processing
Where applicable law requires a legal basis for processing, Wagon processes personal information on one or more of the following bases:
- performance of a contract with you;
- your consent;
- our legitimate interests, such as operating, securing, and improving the Services;
- compliance with legal obligations;
- protection of vital interests or public safety.
How We Disclose Information
We may disclose your information as follows:
3.1 Affiliates and Subsidiaries
We disclose information among the companies within the Wagon family of companies. Our "family of companies" includes companies related to us by common control or ownership. We disclose information within our corporate family as a normal part of business operations and to provide products and services.
3.2 Service Providers
We use a variety of third-party service providers to help us run our business and perform functions on our behalf, such as professional services (like law firms, consultants, accountants, and tax advisors), hosting, billing and payment processing, delivering push notifications, providing customer service, helping us prevent fraud, securing our systems, delivering app features, etc. For example, we disclose your information with companies we’ve hired to provide customer support or assist Wagon in protecting and securing our systems where access to your information is necessary to provide those services. And we could not provide our services without third parties that maintain, service, and manage our fleets of vehicles in all of the cities where we operate. In these cases, we require the third-party service provider to use adequate safeguards to protect the confidentiality of the information they receive and to use your information only for the purposes for which they have been granted access.
3.3 Business Partners
We disclose personal information with other companies that, among others, help us provide services to our customers, or reach potential customers with our marketing messages. Examples include:
- Platform Operators, Hosts, and Program Sponsors. If you access or use the Services through a hotel, resort, golf course, club, residential community, homeowners’ association, employer, event operator, property manager, hospitality operator, or other partner-sponsored arrangement, Wagon may disclose information to the applicable operator or sponsor as reasonably necessary to administer the program, confirm eligibility, support billing, provide reporting, investigate incidents, respond to claims or complaints, enforce applicable program rules, and operate the Services.
- Advertising and Digital Analytics Companies. We may disclose identifiers, device information, online activity, and similar data to analytics, attribution, advertising, and social media partners to measure engagement, improve campaigns, and personalize marketing, subject to your settings and applicable law.
- Joint Marketing Partners. We disclose information with partners with which we offer co-branded services or engage in joint marketing activities.
- Universities and Research Organizations. We may disclose aggregated, de-identified, or otherwise non-personally identifiable information for research, planning, reporting, sustainability, traffic analysis, or infrastructure purposes. We may also disclose limited data sets for research or operational purposes where permitted by law and subject to appropriate safeguards.
- Insurers, Claims Administrators, and Risk Management Partners. Wagon may disclose relevant information to insurers, insurance brokers, claims administrators, adjusters, investigators, legal counsel, roadside or emergency response providers, and other risk management partners in connection with accidents, injuries, property damage, theft, recovery efforts, insurance claims, litigation, or dispute resolution.
3.4 Law Enforcement, Courts, Regulatory Agencies, and Others
Wagon may disclose personal information where we believe in good faith that disclosure is necessary or appropriate to comply with applicable law, regulation, license requirements, insurance requirements, court order, subpoena, governmental request, or other legal process; to cooperate with law enforcement or regulatory authorities; to protect the rights, property, safety, or security of Wagon, our affiliates, our personnel, our users, our partners, or the public; to detect, investigate, prevent, or address fraud, misuse, theft, security incidents, privacy issues, or other unlawful or unauthorized conduct; or to enforce our agreements, terms, and policies.
3.5 Business Reorganization or Transaction
We may also share your information as part of a sale, merger, financing, change in control, or business restructuring. If a transfer for these reasons is subject to legal restrictions, we will comply with the law.
3.6 Blogs and Social Media
When you interact with us or post content about us on social media platforms – like Facebook, X, Instagram, LinkedIn, YouTube – any information that you submit through such features is not confidential and may be accessed by others. For example, if you submit a product review on one of our sites, we may display your review (along with the name provided, if any) on other Wagon sites and on third-party websites. If you provide a comment on our blog, other blog readers will be able to review your comments, and if you interact with us on our social media pages, your comments will be publicly available. So, please take care when using these features. If you’d like to request the removal of information that we have posted about you, please contact us.
Biometric, Selfie & Identity Verification Information
If Wagon uses selfie matching, age verification, identity verification, or similar technology, Wagon may collect photographs, scans, or related information to verify that:
- you are the person associated with the account;
- you meet minimum age or driver eligibility requirements;
- your government-issued identification appears valid and unexpired; or
- a safety or anti-fraud requirement has been met.
Where Wagon uses a third-party provider to perform identity, age, or document verification, Wagon may provide photographs, scans, identification data, and related information to that provider for verification on our behalf. Wagon does not use verification photographs or related identity verification information for unrelated advertising purposes. Wagon will retain such information only for so long as reasonably necessary for fraud prevention, eligibility verification, legal compliance, claims handling, dispute resolution, or other purposes described in this Privacy Policy, unless a different period is required by applicable law or disclosed in a supplemental notice.
How Long We Retain Information
We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain your account, complete transactions, comply with legal obligations, resolve disputes, enforce agreements, investigate incidents, and prevent fraud.
Retention periods vary by data type and legal or operational need. For example:
- Account and profile information may be kept for the life of the account and for a reasonable period afterward;
- Payment and transaction records may be retained for accounting, tax, audit, and dispute purposes;
- Support, safety, incident, and claims records may be kept as needed for investigations, legal compliance, and defense of claims;
- De-identified or aggregated information may be retained for analytics, research, and business purposes where it can no longer reasonably identify you.
When you delete your account, it may take us additional time to fully delete your information from our databases and system logs. We may also retain information from deleted accounts to prevent fraud, collect fees, enforce the Terms of Use, comply with our legal obligations, or enforce our legal rights.
Your Rights
Depending on where you live and subject to applicable law, you may have the right to request that Wagon:
- confirm whether we process certain personal information about you;
- provide access to certain personal information we maintain about you;
- correct inaccurate personal information;
- delete certain personal information, subject to legal and operational exceptions;
- provide a copy of certain personal information in a portable format, where required by law;
- allow you to opt out of certain marketing communications or, where applicable, certain targeted advertising, profiling, sale, or sharing activities as defined by applicable law; and
- permit you to withdraw consent where our processing is based on consent, without affecting the lawfulness of processing before withdrawal.
To exercise any available rights, please submit your request via email to privacy@wagon.rent or by using any privacy request mechanism we make available through the Services. We may take reasonable steps to verify your identity before responding to a request. We may deny or limit a request where permitted by law, including where we are unable to verify your identity or where an exception applies. If you are entitled to appeal a decision regarding your request under applicable law, Wagon will provide instructions on how to do so.
You may also opt out of promotional emails by using the unsubscribe link included in those communications. Even if you opt out of promotional communications, Wagon may still send you transactional or service-related messages as described in this Privacy Policy.
US State Specific Disclosures
Wagon may provide additional disclosures and rights notices where required by applicable state law. If Wagon is subject to a state privacy law that provides additional rights, Wagon will honor those obligations as required for residents of that jurisdiction.
Where required by applicable law, Wagon will provide the relevant notice, rights, and opt-out mechanisms for residents of those jurisdictions.
If you are a resident of a state that grants privacy rights, you may have additional rights, including rights to access, correction, deletion, portability, opt-out, and appeal, subject to applicable exceptions and verification requirements.
Children & Minimum User Requirements
Per the Terms of Use, the Services are not directed to children under 13 and Wagon does not knowingly collect personal information online from children under 13 without legally required consent. The use, rental, or operation of a Vehicle is limited to individuals who satisfy the minimum age, driver’s license, and eligibility requirements applicable to the specific Vehicle, program, or location, and who comply with our Terms of Use. If Wagon learns that personal information has been collected from a child in a manner inconsistent with applicable law, Wagon will take appropriate steps to delete or otherwise address that information.
Security & Security Incidents
Wagon uses reasonable administrative, technical, and physical safeguards designed to protect personal information. No method of transmission over the Internet or method of storage is completely secure, and Wagon cannot guarantee absolute security. If Wagon becomes aware of a security incident involving personal information, Wagon may investigate and take appropriate remedial measures. Where applicable law requires notice, Wagon will provide notice of a qualifying security incident in accordance with the timing and content requirements of applicable law.
Changes to This Privacy Policy
We may revise this Privacy Policy from time to time. If we make material changes, we will update the effective date above and provide notice as required by applicable law. Your continued use of the Services after the updated Privacy Policy becomes effective means the updated Policy will apply to your future use of the Services, to the extent permitted by law.
Contact Us
If you have questions about this Privacy Policy, would like to submit a privacy request, or need to contact us regarding your personal information, please contact us at:
WAGON
TECHNOLOGIES, LLC
Attn: Privacy / Legal
support@wagon.rent
(540) 215-4008