Privacy Policy

1. Introduction

Welcome to ETow. We respect your privacy and are committed to protecting your personal data. This policy explains how we collect, use, store, and share your information when you use ETow's platform — including roadside assistance dispatch, junk vehicle marketplace, shop service booking, fleet management, driver profiles, affiliate and referral programs, loyalty rewards, wholesaler portal and bill of sale delivery, manual invoicing, customer CRM contacts, gateway developer sandbox, and all associated AI-powered features.

2. Data We Collect

We collect the following categories of information:

2.1 Identity & Contact Data

• Full name, email address, phone number
• Profile photo and cover photo (drivers)
• Custom username and public profile content (drivers)
• Digital signatures captured during transactions (bill of sale, shop invoices)
• Government-issued ID photos captured during junk vehicle sales

2.2 Driver-Specific Data

• Driver's license number and license document
• Commercial insurance provider, policy number, and insurance document
• Vehicle registration documents
• Tow vehicle details (year, make, model, type, capacity tier)
• Fleet vehicle information and GPS data
• Shop address, GPS coordinates, shop service offerings, and shop operating hours
• Tire inventory data (brand, size, condition, quantity, price) for shops offering tire services
• Bank account details (routing and account numbers, stored securely for payouts)
• Stripe account and customer IDs
• Saved digital signature for bill of sale pre-fill
• Social media and website URLs (optional, for public profile)

2.3 Location Data

• Real-time GPS coordinates of drivers during active service hours
• Customer pickup and destination addresses
• Shop location coordinates for map display and routing
• Service zone polygon coordinates (driver-defined service areas)
• Vehicle location data for fleet tracking

2.4 Transaction & Financial Data

• Service request details, pricing, and payment records
• Driver earnings, commission history, and payout records
• Junk vehicle listing fees, sale prices, and marketplace transactions
• Shop service deposits, invoices, and payment method selections
• Stripe payment intent IDs and subscription IDs
• Customer wallet balances and wallet transaction history
• Promo code usage and discount history
• Affiliate earnings, referral records, and payout history
• Loyalty points balance and transaction history
• Fleet driver payroll records, shift logs, and expense receipts
• Mileage log entries for tax and reimbursement purposes

2.5 Vehicle & Marketplace Data

• Vehicle year, make, model, photos, and videos submitted for junk listings
• VIN scan history including lien status results, risk levels, junk value estimates, and catalytic converter counts
• Bill of sale records including seller/buyer names, sale price, payment method, and HTML document snapshots
• Vehicle damage claim details, photos, incident dates, and resolution records
• Video inspection notes and recorded session metadata
• Pickup scheduling dates and tow arrangement notes

2.6 Technical & Usage Data

• IP address, browser type, device type, and user agent string
• Session identifiers and page view history
• Referring URLs and time spent on platform pages
• Push notification subscription endpoints and device tokens (browser push, Firebase/FCM)
• In-app notification read status and action history
• Fuel price search queries — GPS coordinates used to look up nearby gas prices (all 50 states)
• Traffic intelligence queries and route data
• PWA installation status and device platform (iOS, Android, Desktop)

2.8 Preferred Driver Network Data

• Preferred driver link requests, acceptance/decline status, and commission rates agreed upon
• Tow job dispatch history between shops and their preferred drivers
• Commission payout records between shop owners and tow drivers

2.9 Shop Waitlist Data

• Customer name, phone, and email provided when joining a shop's waitlist
• Vehicle details submitted at waitlist check-in
• Queue position, status (waiting, notified, served, no-show), and join method (manual, QR, online)
• Notification timestamps for waitlist turn alerts

2.10 Wholesaler Portal, Manual Invoices & CRM Contacts

• Wholesaler account business name, contact name, email, phone, address, and dealer license number
• Wholesaler link requests and approval status between wholesalers and driver/shop accounts
• Wholesaler bill of sale records — buyer/seller names, vehicle details, sale price, title and ID photos, signatures, and the email address documents were sent to
• Manual invoice records — bill-to name, email, phone, address, line items, totals, payment method, and email delivery status
• Driver CRM contact records — customer name, company, contact details, address, date of birth, ID number and issuing state, photo ID images, notes, tags, and transaction history
• Photo-ID scan extraction data (name and address only) processed by AI to pre-fill CRM contact records

2.7 Communications Data

• In-platform messages between customers, drivers, and fleet managers
• Junk vehicle chat messages between buyers and sellers
• Fleet broadcast and direct messages
• Shop service chat messages
• Support chat conversations
• AI phone receptionist call transcripts — speech-to-text transcriptions of incoming calls, conversation history, AI-generated call summaries, and actions taken (bookings, transfers, payment links sent) stored for admin review and quality assurance
• AI chatbot conversation transcripts — full chat history between users and the integrated AI chatbot, including escalation tickets when transferred to human support
• Caller phone numbers auto-detected from incoming calls (used for booking, payment link delivery, and account lookup — never asked from the caller)

3. How We Use Your Data

We use your data to:

• Provide and maintain roadside assistance dispatch and real-time tracking
• Operate the junk vehicle marketplace including listings, offers, video inspections, pickup scheduling, and bill of sale generation
• Facilitate shop service bookings, deposits, status updates, and final invoicing
• Match customers with nearby qualified drivers using the 5-tier vehicle classification system
• Process payments, manage subscriptions, and distribute driver payouts
• Operate the customer wallet, loyalty rewards, promo code system, and referral/affiliate programs
• Display driver public profiles with ratings, reviews, and shop service offerings
• Manage fleet operations including vehicle tracking, shift logging, payroll, and communications
• Provide AI-powered features: traffic intelligence, route optimization, VIN scanning, junk value estimation, 1099 tax form generation, earnings forecasting, and intelligent driver matching
• Deliver push notifications, email alerts, and in-app notifications for service updates and platform activity
• Facilitate vehicle damage claim documentation and communication
• Track page views and platform analytics for product improvement
• Manage advertising and sponsorship placements including quick-link banners and dashboard ads
• Comply with legal obligations, prevent fraud, and protect platform security
• Generate 1099 forms and support tax compliance for drivers

4. Data Sharing

We share your data only when necessary:

• Service Providers: Stripe (payments), Firebase (push notifications), cloud hosting and storage providers, AI inference services
• Between Users: Customer and driver contact/location data is shared as needed to fulfill service requests (e.g., driver sees customer pickup location; customer sees driver name and photo)
• Junk Vehicle Transactions: Buyer and seller names, contact info, and vehicle details are shared between transacting parties for deal execution
• Fleet Managers: Fleet manager accounts have visibility into their fleet drivers' location, shift status, and performance data
• Public Driver Profiles: Profile information a driver marks as public (name, bio, ratings, shop services, social links) is accessible to all platform users and the public web
• Sponsors & Advertisers: Aggregate, anonymized analytics data may be shared with advertising partners. Individual user data is never sold to advertisers
• Legal Requirements: When required by law, subpoena, or to protect the rights and safety of users
• Business Transfers: In the event of a merger, acquisition, or asset sale

We do NOT sell your personal data to third parties.

5. Data Security

We implement appropriate technical and organizational measures to secure your data including encryption in transit (TLS), encrypted storage, access controls, and role-based data visibility. Payment data is handled exclusively through Stripe's PCI-compliant infrastructure. However, no internet transmission is completely secure and we cannot guarantee absolute security.

Push notification endpoints and device tokens are stored securely and automatically deactivated when subscriptions are revoked or expire. Digital signatures and ID photos captured during transactions are stored securely and access is restricted to the parties involved in the transaction and platform administrators.

6. Your Rights

You have the right to:

• Access and review your personal data
• Correct inaccurate or incomplete data
• Request deletion of your account and associated data (subject to legal retention requirements)
• Object to or restrict certain types of processing
• Request a portable copy of your data
• Withdraw consent at any time (where processing is based on consent)
• Opt out of marketing communications while retaining transactional alerts
• Manage push notification permissions through your device or browser settings

To exercise any of these rights, contact us at privacy@etow.com. We will respond within 30 days.

7. Data Retention

• Driver license, insurance, and registration documents: retained for 7 years for regulatory compliance
• Service request and payment records: retained for 3 years for tax and legal purposes
• Bill of sale records: retained for 7 years
• Vehicle damage claim records: retained for 5 years
• Push notification subscriptions: retained while active; automatically marked inactive on revocation
• Page view and analytics data: retained for 2 years in aggregate
• Fleet shift logs and payroll records: retained for 3 years
• Junk vehicle listings and transaction records: retained for 5 years

8. Cookies & Tracking Technologies

We use cookies and similar technologies (localStorage, session storage, device fingerprinting) to maintain session state, analyze platform usage, and support features like push notification preferences. You can control cookie behavior through your browser settings, though disabling certain cookies may affect platform functionality.

9. Children's Privacy

ETow is not intended for users under 18 years of age. We do not knowingly collect personal data from anyone under 18. If we become aware that a minor has provided personal information, we will delete it promptly.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email or in-platform notification. Continued use of the platform after changes constitutes acceptance of the updated policy.

10.5 Department & Motor Club Data (CJI Minimization)

Department and Motor Club accounts involve specialized data handling practices for dispatch and rotation management.

CJI-Minimized Data Handling

• No CJI Storage: Raw Criminal Justice Information transmitted from CAD systems is never stored on ETow servers
• Minimum Dispatch Data: Only the minimum data required for dispatch assignment is retained (pickup location, vehicle description, priority level, tow type)
• Payload Hashing: A SHA-256 hash of the raw CAD payload is stored for audit trail verification without retaining the actual content
• CJI Minimization Flag: Every dispatch record includes a confirmation flag that CJI minimization was applied

Department-Specific Data

• Department Member Profiles: Name, email, agency name, role, badge number, phone, and duty status
• CAD Adapter Configurations: API key hashes (not raw keys), IP allowlists, OAuth client IDs, and auth methods
• Dispatch Audit Logs: Action type, actor, IP address, timestamp, and non-CJI metadata for every dispatch event
• Rotation Applications: Business verification documents, insurance certificates, inspection results, and background check statuses submitted by tow companies
• Driver Link Records: Department-driver link status, initiated date, and response date
• Gateway Developer Sandbox: Sandbox adapter configurations (tagged non-production) and test dispatch payloads used by motor club/department developer teams to validate normalized vendor data before production activation

Data Retention for Department Records

• Dispatch audit logs are retained indefinitely for compliance and legal audit purposes
• Rotation application documents are retained for the duration of the driver's participation plus the department's required retention period
• Department member profiles are retained while the account is active and may be archived upon deactivation
• Raw CAD payloads are discarded immediately after processing; only hashed references and minimized data persist

11. Contact Us

For questions about this Privacy Policy or to exercise your rights, contact us at: