Privacy Policy

Last Updated: November 2025

Comet One LLC, doing business as CarFlow ("we," "us," or "our"), is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website and services.

1. Information We Collect

1.1 Personal Information You Provide

We collect information that you voluntarily provide when you:

• Fill out application forms
• Create an account or sign up for services
• Contact us via email, phone, or SMS
• Subscribe to our communications

This information may include:

• Full name
• Date of birth
• Email address
• Phone number
• Mailing address
• Driver's license number and information
• Social Security Number or ITIN
• Employment and income information
• Banking information for payments
• Insurance information

1.2 Information We Collect Automatically

When you visit our website, we may automatically collect:

• IP address
• Browser type and version
• Device information
• Operating system
• Pages visited and time spent on pages
• Referring website addresses
• Clickstream data

1.3 Information from Third Parties

We may receive information about you from:

• Credit bureaus and credit reporting agencies
• Identity verification services
• Employment verification services
• Insurance providers
• Vehicle history report providers
• Public records

2. How We Use Your Information

We use the collected information for the following purposes:

2.1 Service Delivery

• Processing and evaluating your rental application
• Verifying your identity and eligibility
• Creating and managing your account
• Processing payments and maintaining payment records
• Managing the rent-to-own agreement
• Coordinating vehicle pickup and delivery

2.2 Communication

• Sending payment reminders and account notifications
• Responding to your inquiries and requests
• Providing customer support
• Sending service updates and important notices
• Sending marketing and promotional communications (with your consent)

2.3 Business Operations

• Improving our services and customer experience
• Conducting analytics and market research
• Detecting and preventing fraud
• Complying with legal obligations
• Enforcing our Terms and Conditions
• Protecting our rights and property

3. SMS/Text Messaging

By providing your phone number and opting in to SMS communications, you consent to receive text messages from CarFlow, including:

• Payment reminders and notifications
• Account updates and alerts
• Service-related messages
• Marketing and promotional offers (you may opt out)

Opt-Out Instructions:

• Text STOP to any message to unsubscribe from all messages
• Text HELP for assistance
• Standard message and data rates may apply
• Message frequency varies

We use Twilio and other third-party services to deliver SMS messages. These providers may have access to your phone number and message content solely for the purpose of delivering our messages.

4. How We Share Your Information

We may share your information with the following parties:

Party	Purpose
Service Providers	Payment processors, SMS providers, credit reporting agencies, background check services
Financial Institutions	Banks, lenders, and credit bureaus for credit reporting and payment processing
Insurance Companies	To verify insurance coverage and process claims
Legal Authorities	When required by law, court order, or legal process
Business Transfers	In connection with a merger, acquisition, or sale of assets

We do NOT sell your personal information to third parties for their marketing purposes.

5. Data Security

We implement industry-standard security measures to protect your information, including:

• Encryption of sensitive data (SSL/TLS)
• Secure servers and databases
• Access controls and authentication
• Regular security audits and updates
• Employee training on data protection

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Your Privacy Rights

6.1 California Residents (CCPA)

If you are a California resident, you have the following rights:

• Right to Know: Request information about the personal data we collect, use, and share
• Right to Delete: Request deletion of your personal information (subject to legal exceptions)
• Right to Opt-Out: Opt out of the sale of personal information (we do not sell personal data)
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights

6.2 General Rights

All users have the right to:

• Access the personal information we hold about you
• Correct inaccurate or incomplete information
• Opt out of marketing communications
• Request portability of your data
• Lodge a complaint with a supervisory authority

To exercise these rights, please contact us using the information provided at the end of this policy.

7. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services to you
• Comply with legal obligations (e.g., tax records, credit reporting)
• Resolve disputes and enforce agreements
• Maintain business records

Typically, we retain:

• Active account information: Duration of agreement plus 7 years
• Payment records: 7 years (IRS requirement)
• Credit reporting data: As required by Fair Credit Reporting Act
• Marketing communications: Until you opt out plus 2 years

8. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child, we will take steps to delete it promptly.

9. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to read their privacy policies before providing any information.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Remember your preferences
• Analyze website traffic and usage
• Improve user experience
• Deliver targeted advertising (with your consent)

You can control cookies through your browser settings. However, disabling cookies may affect website functionality.

11. Do Not Track Signals

Some browsers have a "Do Not Track" feature. Currently, we do not respond to Do Not Track signals, as there is no industry standard for how to interpret them.

12. International Users

Our services are primarily intended for users in California and the United States. If you access our services from outside the U.S., your information may be transferred to, stored, and processed in the United States, which may have different data protection laws than your country.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be effective upon posting to our website. We will notify you of material changes via:

• Email notification
• SMS message (if opted in)
• Prominent notice on our website

Your continued use of our services after changes are posted constitutes acceptance of the updated policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

15. Fair Credit Reporting Act (FCRA) Notice

We may obtain consumer reports (including credit reports) about you from consumer reporting agencies for purposes of evaluating your application and ongoing account review. Under the FCRA, you have the right to:

• Know if information in your file has been used against you
• Access your credit report from consumer reporting agencies
• Dispute incomplete or inaccurate information
• Limit "prescreened" offers of credit and insurance