Privacy Policy

1. Overview and Scope

Overview

This Privacy Policy (this “Policy”) and applicable supporting procedures are designed to provide you, our customers and users (“you”, “Customer”) with Tint Technologies Inc.’s and its subsidiaries’ (“Tint”, “we”, “us”, “our”) documented and formalized process for protecting individuals’ privacy. Respect for the privacy of personal and other information is fundamental to us. This Policy describes our collection of Personal Information from users of our website (“website” or “Site”), our Platform, as well as all related applications, widgets, software, tools, and other services provided by us and on which a link to this Policy is displayed (together with the Site, our “Service”). This Policy also describes our use and disclosure of such information.

Scope

This Policy and supporting procedures cover the privacy of all data collected by Tint in its interaction with individuals in its business operations.

2. Personal Information

As used in this Policy, “Personal Information” is information that specifically identifies an individual, such as an individual’s name, telephone number, or email address. Personal Information also includes information about an individual’s activities, such as information about his or her activity on the Site or credit history, and demographic information, such as date of birth, gender, address, geographic area, and preferences, when any of this information is linked to Personal Information that identifies that individual.

Personal Information does not include “aggregate” or other non-personally identifiable information. “Aggregate” information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed. We may use and disclose aggregate information, and other non-personally identifiable information, for various purposes.

3. Collection of Information

Passive Information Collection

When you use the Service, some information may be automatically collected, such as your IP address, browser type, system type, the content and pages that you access on the Site, “referring URL” (i.e., the page from which you navigated to the Site), the pages you navigate to on the Site, and from which you leave the Site, as well as the time you spend on the Site.

We collect this information passively using technologies such as standard server logs, cookies, and clear GIFs (also known as “Web beacons”). We use passively-collected information to administer, operate, and improve the Site and our other services and systems, and to provide services and content that are tailored to you. If we link or associate any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Policy. Otherwise, we use information collected by passive means in a non-personally identifiable form only.

Also, please be aware that third parties may set cookies on your hard drive or use other means of passively collecting information about your use of their services or content. We do not have access to, or control over, these third-party means of passive data collection.

Collection of Voluntarily Provided Information

We may collect Personal Information that our users provide to us in a variety of ways through our Service. For instance, when you request information about our services or otherwise communicate with us, we collect the Personal Information that is provided to us. We may collect Personal Information such as name, e-mail address, city, state, country, other demographic information, and your interests and preferences in these manners.

Information from Other Sources

We may receive information about you, including Personal Information, from third parties, and may combine this information with other Personal Information we maintain about you. If we do so, this Policy governs any combined information that we keep in a personally-identifiable format.

4. Use of Personal Information

We use Personal Information to: provide services and information that you request; enhance, improve, operate, and maintain the Site and Service, our programs, services, website, and other systems; prevent fraudulent use of our Site and Service; tailor your user experience; maintain a record of our dealings with you; and, for other administrative purposes. In connection with our insurance programs, we also use Personal Information to: administer and service coverage; evaluate and adjust premiums and underwriting factors; investigate, evaluate, and adjudicate claims; verify compliance with program terms; and detect and prevent fraud or misrepresentation.

We may also use the Personal Information you provide to contact you regarding our products and services. We allow you to opt-out from receiving marketing communications from us as described in the “Choice” section below.

5. Disclosure of Personal Information

We will not disclose your Personal Information to third parties without your consent, other than as described in this Policy. We may disclose Personal Information to third-party service providers (e.g., data storage and processing facilities) that assist us in our work. We limit the Personal Information provided to these service providers to that which is reasonably necessary for them to perform their functions.

We may also disclose Personal Information if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.

In addition, information about our users, including Personal Information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Information could be transferred to third parties as one of our business assets. In connection with our insurance programs, we may also disclose Personal Information to the following categories of recipients, to the extent reasonably necessary to administer coverage, adjust or pay claims, comply with legal obligations, or operate our programs: (i) insurance carriers, reinsurers, and affiliated underwriting entities; (ii) claims administrators, independent adjusters, repair networks, and other claims-handling vendors; (iii) data and analytics providers used in underwriting, fraud detection, or program administration (such as vehicle data services and telematics data processors); (iv) platform partners through which coverage is distributed or from which vehicle and usage data is obtained; and (v) regulators, law enforcement, and government authorities as required by applicable law.

6. Use of Cookies

By using our website, you agree to allow cookies to be stored on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media.

You can manage cookies through your browser settings and any cookie controls we make available, and you can opt out of non-essential cookies. We also honor recognized opt-out preference signals, including the Global Privacy Control (GPC). We do not sell your Personal Information, and we do not use cookies or similar technologies to share your Personal Information with third parties for their own marketing or for cross-context behavioral advertising.

7. Customer End User Information

Customers decide the types of data that they wish to send to Tint for use with our Service. Specifically, Customers may send to Tint Personal Information provided by Customer end users, such as email addresses, location, age or demographic data; Customers may send us information about specific end user behavior on Customer websites; Customers may send us information about the form of payment, orders, and claim or claim status.

The Service allows Customers the ability to pass end user data into and, at each Customer’s direction, out of the Service, including to certain third-party applications and services, and from one application or service to another. Tint may also store this end user data at the instruction of our Customer. Tint is not responsible for inspecting the end user data that it collects, and collects end user data under the direction of its Customers when providing our Service.

If applicable, each of our Customers must have its own policy or policies regarding the collection and use of end user information. This Policy does not apply to our Customer’s collection of end user data, nor does it apply to websites, applications, or services that display or link to different privacy statements. We recommend that you review the policies of our Customers through whom your information may be collected and submitted to us. Tint is not responsible for our Customers’ privacy policies nor for their actions with respect to their use of their own end user information.

8. Insurance Program Participants

This section applies to individuals who enroll in or participate in an insurance program administered by Tint Embedded Insurance Services, LLC or its affiliates (each, a “Program Participant”). When you enroll in a program, we collect and use information about you and your covered property directly in order to administer your coverage. The following describes that data collection and use.

Categories of Information Collected

In connection with your enrollment and participation in a program, we may collect the following categories of information: (i) identity and contact information (e.g. name, email address, mailing address, phone number); (ii) covered property information (e.g. vehicle information records, real property information and records); (iii) platform account and usage data obtained from third-party platforms through which a program is distributed or on which covered property is listed, including trip history, booking activity, utilization statistics, odometer readings, and listing status; (iv) telematics and location-adjacent data, where applicable to your plan, including driving behavior, distance traveled, and device connectivity status, collected via approved telematics devices or third-party telematics service providers; (v) photos, inspection images, and visual documentation submitted by you or obtained from platform accounts in connection with claims or program administration; (vi) claims and loss information, including incident details, repair estimates, supporting documentation, police reports, and communications related to a claim; (vii) payment and billing information; and (viii) communications and correspondence with us related to your coverage.

How We Use Program Participant Information

We use information collected from Program Participants to: enroll and onboard you into the applicable program; calculate and adjust premiums based on underwriting factors including vehicle value, utilization, and mileage; administer and service your coverage; issue certificates of insurance, ID cards, and other program documents; investigate, evaluate, and adjudicate claims; verify compliance with program terms and conditions; detect and prevent fraud, misrepresentation, and coverage abuse; comply with legal, regulatory, and contractual obligations (including electronic insurance verification reporting to state motor vehicle authorities); and communicate with you about your coverage, including notices required or permitted under your program terms.

Sharing of Program Participant Information

In addition to the disclosures described in Section 5 above, we may share Program Participant information with the following categories of recipients: (i) insurance carriers and reinsurers underwriting the applicable program; (ii) affiliated program entities (including Embedded Technology Collective, LLC and Tint Embedded Insurance Services, LLC); (iii) claims administrators, independent adjusters, repair facilities, and other claims-handling vendors; (iv) data and analytics service providers used in underwriting, premium adjustment, or fraud detection, including vehicle valuation services, telematics data processors, and identity or driving record verification providers; (v) platform partners (such as Turo) through which a program is distributed or from which covered property or usage data is obtained, to the extent necessary for program administration; and (vi) state motor vehicle authorities and other regulators, as required by applicable law or program terms, including for electronic insurance verification reporting.

Third-Party Platform Data

Where a program is offered in connection with a third-party platform (such as a vehicle-sharing or peer-to-peer rental platform), we may obtain data about you and your covered property from that platform on an ongoing basis during your enrollment. This may include account information, vehicle and listing details, trip history, photos, inspection records, odometer data, and utilization statistics. By enrolling in a program and authorizing the applicable platform connection, you consent to our collection and use of such platform data for program administration purposes as described in this section. In addition, by enrolling in a program you expressly consent to our collection of data from a third-party platform, including but not limited to trip records, booking history, inspection photos, odometer readings, and other account or vehicle data, at any time that we determine such data is reasonably necessary to investigate, evaluate, or adjudicate a claim, including after a claim has been submitted. This consent to claims-related data collection is ongoing and is not limited to data that existed at the time of enrollment. You further consent to our sharing of any such platform data, together with other Program Participant information, with the insurance carrier or carriers underwriting the applicable program, reinsurers, and any claims administrator or independent adjuster engaged in connection with the claim, to the extent reasonably necessary to evaluate coverage, determine liability, and administer the claim.

Retention of Program Participant Information

We retain Program Participant information for as long as necessary to fulfill the purposes described in this section, comply with applicable legal and regulatory requirements, and defend against potential legal claims. In general: enrollment and coverage records are retained for a minimum of five (5) years following the end of the policy period in which the record was created; claims records are retained for a minimum of seven (7) years following final resolution of the claim; telematics and platform usage data are retained for a minimum of one (1) year following cancellation of coverage or the end of the audit period specified in your program terms, whichever is later. We may retain records for longer periods where required by law or where a claim or dispute remains unresolved.

Your U.S. State Privacy Rights

Depending on your state of residence, you may have rights under applicable U.S. state privacy laws, subject to exceptions (including for information we handle as a licensed insurance producer or third-party administrator, which may be exempt). These rights may include the right to know or access the Personal Information we hold about you; to correct or delete it; to obtain a portable copy; to opt out of the sale or sharing of Personal Information and of certain profiling; and to limit the use of Sensitive Personal Information. We collect the following categories of Sensitive Personal Information: driver’s license number and precise geolocation. We use Sensitive Personal Information only to administer coverage, adjust and pay claims, verify identity and eligibility, and detect and prevent fraud, and not for purposes that would require offering a right to limit beyond those uses. Tint does not sell Personal Information, and does not share Personal Information with third parties for their own marketing or for cross-context behavioral advertising. We honor recognized opt-out preference signals, including the Global Privacy Control (GPC). To exercise any of these rights, or to appeal a denial of a request, contact us at contact@tint.ai; you may use an authorized agent, and we will verify your request and respond within the timeframes required by applicable law. We will not discriminate against you for exercising your rights.

9. Insurance Information Privacy (GLBA Notice)

This section applies to nonpublic personal information (“NPI”) we collect about individuals in connection with the insurance products and related programs we distribute, administer, or service, including in our capacity as a licensed insurance producer and third-party administrator. We provide this notice consistent with the Gramm-Leach-Bliley Act and applicable state insurance privacy laws. It supplements the rest of this Policy; to the extent it conflicts with another section with respect to NPI, this section controls.

Information we collect

To provide, administer, and service coverage and to process claims and payments, we collect NPI such as identity and contact information; information about the covered person and property; coverage, enrollment, premium, and billing information; claims and loss information; and information we receive from you, from the program or platform through which coverage is offered, from insurers and other program partners, and from consumer-, vehicle-, or driving-record and verification services.

How we use it

We use NPI to enroll, rate, and administer coverage; issue program documents; investigate, evaluate, adjudicate, and pay claims; process premiums and payments; detect and prevent fraud; service your account and communicate with you; and comply with our legal, regulatory, and contractual obligations.

How we share it

We share NPI only as permitted by law and as necessary to deliver and administer the products and programs, including with the insurers, reinsurers, and underwriting entities for the applicable program; claims administrators, adjusters, repair networks, and other claims-handling and payment vendors; service providers that perform functions on our behalf; program and platform partners as needed for program administration; and regulators, law enforcement, and other authorities as required by law. We require those who receive NPI from us to protect it and to use it only for the purposes for which it was disclosed.

We do not sell NPI, and we do not share NPI with nonaffiliated third parties for their own marketing. We disclose NPI only as described above to administer your coverage and process your transactions, and as otherwise permitted or required by law; accordingly, no opt-out is required for these disclosures.

How we protect it

We maintain administrative, technical, and physical safeguards designed to protect NPI, consistent with applicable insurance data-security requirements, and we limit access to those who need it to perform their roles.

Former customers

We continue to apply these practices to NPI about former customers and program participants for as long as we retain it.

Health information

Where we collect nonpublic personal health information, we do not disclose it without authorization except as permitted or required by law.

Questions

To ask about our insurance information privacy practices, contact us at contact@tint.ai or at the address in the “Contacting Us” section.

10. Data Retention

We retain Personal Information only for as long as necessary to fulfill the purposes described in this Policy, to comply with our legal, regulatory, and contractual obligations, and to establish, exercise, or defend legal claims. Retention periods vary by the type of data and the context in which it was collected; specific retention periods for insurance program data are described in the Insurance Program Participants section above.

11. Choice

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us by sending us an email or by writing to us at the address given at the end of this Policy.

12. Links

For your convenience, the Site may contain links to other websites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this Policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties.

13. Children

Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. We do not knowingly collect Personal Information from children under the age of 13 without obtaining parental consent.

14. International Visitors

Our Site and Service is hosted in the United States and is generally intended for United States visitors. If you visit from the European Union or other regions with laws governing data collection and use that may differ from United States law, please be aware that you are transferring Personal Information to the United States. The United States does not have the same data protection laws as the European Union and some other regions. By providing Personal Information to us, your Personal Information will be transferred to and processed in the United States, as further described in the “International Privacy Rights” section below and in accordance with this Policy.

15. International Privacy Rights (EEA, UK, and Canada)

If you are located in the European Economic Area, the United Kingdom, or Canada, the following additional terms apply to our processing of your Personal Information.

Legal bases

We process your Personal Information as necessary to perform a contract with you or to take steps at your request; to comply with our legal obligations; for our legitimate interests in operating, securing, and improving our Service and programs (balanced against your rights); and, where required, with your consent.

Your rights

Subject to applicable law, you may request access to, correction of, or deletion of your Personal Information; object to or request restriction of certain processing; request a portable copy; and, where processing is based on consent, withdraw consent at any time. You may also lodge a complaint with your local supervisory authority.

International transfers

When we transfer Personal Information from these regions to the United States, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum. You may request a copy of the relevant safeguards by contacting us.

Contact and representative

To exercise your rights, or to reach our data protection contact or EU/UK representative, contact us at contact@tint.ai or at the address in the “Contacting Us” section.

16. Security

Tint protects the Personal Information it collects with reasonable and appropriate physical, electronic, and procedural safeguards. We use reasonable security measures that are designed to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any Personal Information or other information. You transmit information to us at your own risk.

17. Testimonials

We may display personal testimonials of satisfied Customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us. If you provide us with comments or feedback, we may collect your name and email address, as well as any other content included in the email to send you a reply and improve our Service.

18. Change to This Policy

We may occasionally change or update this Policy. When we do, we will also revise the date at the beginning of this Policy. Your continued use of the Service after such changes will be subject to the then-current policy. We encourage you to periodically review this Policy to stay informed about how we collect, use, and disclose Personal Information.

19. Contacting Us

If you have any questions, comments, or concerns about this Policy or your information, please contact us at contact@tint.ai; or, if you prefer to use mail:

Tint Technologies Inc.
Attention: Legal
2261 Market Street #4427
San Francisco, CA 94114

If you have a complaint that we have breached this Policy, and you attempted in good faith to resolve the complaint through our customer service process but the complaint was not resolved by us within a reasonable amount of time, then you may enforce this Policy against us.

20. Privacy Policy Administration

Ownership and Review

Tint owns this Policy and is responsible for reviewing this Policy for updates annually, or following major changes to Tint’s compliance environment.

Monitoring and Enforcement

Tint periodically monitors adherence to this Policy to help ensure compliance with applicable laws, requirements, and contractual agreements that apply to Customer & consumer data. Tint may also establish enforcement mechanisms, including disciplinary actions, to help ensure compliance with this Policy.

Last Updated

This Policy was last updated in August 2026.