MROScanner Privacy Policy

Last updated: January 21, 2024

MROScanner exists to bridge the gap between Owners and Customers through technology-based solutions facilitating commerce involving equipment. By developing purpose-built software solutions for the aviation industry, we are empowering our Users to embrace new technologies as a catalyst to fuel their businesses. We process your personal and business information to run our Platform and provide our Users with the Services.

This Privacy Policy describes how MROScanner, for and on behalf of itself and its subsidiaries (collectively, “MROScanner”, “we”, or “us”) wants you to be familiar with how we collect, use, process and disclose your personal or business information. By accepting our Terms, and in some jurisdictions by acknowledging this Policy), you confirm that you have read and understand this Policy, including how and why we use your information. User consent for processing personal data is obtained during registration and can be withdrawn at any time by sending an email to info@mroscanner.com. Undefined terms in this Privacy Policy have the same definitions as in our Terms to which this forms an integral part. In this policy, we cover our privacy practices relating to your access to or use of our Services, or when you otherwise provide us with personal information.

Personal Information Collected

We collect three (3) categories of personal information – personal information you give us; personal information automatically collected from your use of the Services; and personal information from third-party sources.

1. Personal Information Given 

• Account Information. When you register for an Account with us, we require certain personal information to open your Account, such as your full legal name, e-mail address, phone number, password and other similar contact information.
• Profile Information. We may also ask you to provide additional profile information to use certain features of the MROScanner Services which may include street addresses, phone numbers, certification number, driver’s license number, date of insurance and issuing country and/or state/province, profile photos, employer, biography, and date of birth etc. Certain parts of your profile (like your profile photos, employer, city and biography) are to be a part of your public profile page and will be visible to Users when engaging with the Services.
• Equipment Information. MROScanner will collect all information you provide relating to Equipment onboarded, listed or transacted through the Services including, without limitation, the manufacturer, model, year, part number, serial number, manufacturer specifications and uploaded photos of the Equipment as well as pricing details, availability, equipment description and so forth.
• Booking Information. We collect information you provide in relation to Equipment booking reservation requests and fulfillment rates such as the type of Equipment, booking duration, listing details, part and serial number. To improve fulfillment rates, MROScanner may utilize Booking Information to automatically generate rental leads to post on reverse-style marketplace, The Rental Board, to notify local Owners of the Equipment request to assist with the completion of a Transaction using the Services.
• Payment Information. We collect your financial information which is provided in connection with: (a) Account setup, (b) a potential or actual Transaction through the Services and/or (c) any other payment processing for subscriptions and/or advertising. Payments may be processed and stored by one (1) or more third-party payment services providers or digital payments companies. Payment card information including account number and associated security code is required.
• Authentication Information. In some instances, we may ask you to provide us with certain personal or business identifiers including government-issued identifiers. Personal identifiers may include items such as a valid ID-card, driver’s licence, passport. Users may also be prompted to upload an identifying photograph in the form of a selfie or otherwise. Demographic information is also collected about you such as your date of birth, gender, etc. Other forms of information collected relate to social media account information and insurance information. Business identifiers include commercial documentation to verify the legal status of your business in your local jurisdiction. Where we request that you withhold certain information (such as obscuring or redacting all but the last four (4) digits of your payment numbers), please do so.
• Communications with MROScanner and Other Users. When you communicate with MROScanner in any way or use the Services to communicate with, or provide feedback to, other Users, we collect information about your communications, feedback and any other types of information you choose to provide.

2. Personal Information Automatically Collected when Using or Accessing our Services

• Usage Data. While you are using the MROScanner Platform, we automatically collect information about all of your interactions with the Services and other Users. Without limitation, this includes the pages or other content you view, your searches, booking requests or fulfillment, as applicable, and all other actions using the Services.
• Location Information. When you use certain features of the Services, we may collect information about your approximate __cpLocation (e.g., city/town associated with your IP address) or when you opt-in to use our __cpLocation sharing feature, the precise __cpLocation information of your mobile device. Keep in mind that most mobile devices allow you to control or disable the use of __cpLocation services by any application on your mobile device in the device’s settings menu. Transactions may be prohibited by MROScanner if __cpLocation data is not available to prevent cross-jurisdictional bookings.
• Log Data. We automatically collect log information when you use the Services, even if you have not created an MROScanner Account or logged in. That information includes, among other things: details about how you’ve used the Services, IP address, length of stay, frequency of visits, hardware and software information, unique device identifiers, device event information (e.g., crashes, browser type) and the page you’ve viewed or engaged with before or after you’ve used the Services.
• Transactional Information. In addition to the Booking Information you provide to us (as described in the ‘Personal Information Given’ section above), we also collect all forms of transactional information related to any Transaction which is requested and/or facilitated through the Services. Such information includes, but is not limited to, the date and time of your rental, amounts charged, type of Equipment, and all other related Transaction details.
• Commercial Information. User information regarding products or services you have purchased or considered purchasing, or other purchasing or spending histories or tendencies relating to the Services are automatically tracked and collected.
• Financial & Credit Information. MROScanner will automatically generate and collect financial and credit profile data of Users based on interactions with the Services including, without limitation, Transaction history (i.e. number of Transactions completed), total Account spend to date, approval status of any third-party payment lenders, number of Equipment damage claims, if any, collection actions and outstanding balances.
• Cookies & Similar Technology. When you access our Services, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, clear gifs, pixel tags, e-tags, “Flash cookies”, or other local storage provided by your browser or associated applications (collectively, “Cookies”).

3. Personal Information from Third-Party Sources

We collect personal data, with consent or as permitted by law, from the following third-party sources: 

• Third-Party Payment Providers. When you make an electronic payment directly to MROScanner, or through one (1) of our third-party payment providers, we may receive your personal information from these third (3^rd) parties for the purpose of receiving and processing that payment.
• Third-Party Data Providers. MROScanner purchases personal data from third-party companies that collect and aggregate personal data. These data providers collect personal data from a variety of sources, including directly from consumers, through devices and browsers, public records, news sources, and from other businesses and data brokers.
• Financial Institutions. MROScanner collects personal data from companies that offer financial products or services to consumers, like loans, financial or investment advice, or insurance, and has obtained your consent to share your data with MROScanner. This includes banks, mortgage lenders, loan brokers, some financial or investment advisors, insurance companies and debt collectors.
• Insurance Companies. Where permitted, MROScanner collects personal and business data from insurance companies who work with us to provide certain products through our Services.
• Public Records. MROScanner collects personal data which is sourced from public records made available by government entities and legal suppliers (e.g., courthouse reporters). This includes information on real property ownership and sales history, court filings, child and spousal support payments, and federally provided sanctions lists.

How MROScanner Uses Your Personal Information

We use, store and process your personal information to provide and improve our Services as well as to ensure a secure, safe and trusted experience. Without limitation, MROScanner may use your information:

To provide our Services. Including to:

• enable you to access and use the MROScanner Services
• monitor, review and provide customer support
• send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and the information requested by you at any telephone number, by placing a voice call or through text (SMS) or email messaging
• assist you during the Transactions
• enable the processing of Transactions and send notices about your Transactions
• personalize or customize your User experience
• enable you to communicate with other MROScanner Users, including by sending them messages or other information during the booking process
• to assess your use of the Services and to compile all Financial and Credit Information collected by MROScanner
• if you provide us, or our service providers, any information relating to other people in connection with the Services, we may use and store this information to facilitate your referral invitations; send your requests for reviews, for fraud detection and prevention and for any purpose you authorize at the time of collection
• administer referral programs, rewards, surveys, contests, or other promotional activities or sponsored events in which you participate
• collect and enforce against debts owing by you through the Services

To Improve our Services. We may use the personal information you provide to: (i) to analyze and improve the Services, (ii) to test, research, analyze and develop new products and services including, but not limited to, studying our User demographics of the Services, (iii) to monitor, review and improve customer service and internal business processes and (iv) to audit or investigate the use of our products and services by our Users.

To Send You Marketing & Promotional Communications. We may send you MROScanner-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the ‘Opt Out of Marketing Communications’ section below.

To Ensure a Secure, Safe & Trusted Experience, including to:

• verify your identity or authenticate information provided by you, including during account creation and password reset processes
• resolve disputes, collect fees, and troubleshoot problems
• detect, prevent, and/or remediate fraud, abuse, security incidents or other potentially harmful, prohibited or illegal activities
• detect, prevent or remediate violations of and enforce our Terms and Policies 
• manage and protect our information technology infrastructure
• conducting investigations and risk assessments
• conduct checks against databases and information sources (such as but not limited to public government databases)

To Comply with Law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities with requisite jurisdiction.

To Create Anonymous Data. We may create aggregated, de-identified or other anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third-parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

With Your Consent. In some cases, we may specifically ask for your consent to process your personal information. You may direct us to share your information or consent to it as described at the time of sharing.

We may also use your personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.

How MROScanner Discloses Your Personal Information

MROScanner may disclose the personal and/or business data we collect for any one (1) or more of the business purposes listed in the Use section above.

Profiles, Listings & Other Public Information

While an Owner is leveraging the Platform powered by MROScanner’s, your public listing page on any of our Services may include certain basic information such as:  (i) your Account details including User name or business name, (ii) company logo or your public profile photo, (iii) the local jurisdiction where your Equipment is located, (iv) your listing description, (v) your Equipment availability, (vi) Transaction-related information to allow our prospective Customers to evaluate reliability, responsiveness and reviews/feedback. Your public listing page may also include aggregated demand information (such as, without limitation, total Transactions completed on the Platform, available pieces of Equipment, fulfillment rates, cancellation rates and number of page views over a period of time). Our Services may also display the approximate geographic pick-up __cpLocation of your piece of Equipment.

Our Services allow your public profile and public listing pages to be included in search engines, in which case your public profile and public listing pages may be indexed by search engines and may be published as search results.

Owner Due Diligence on Customers

Customer information is not publicly searchable by other Users. However, when Customers submit booking requests to specific Owners through the Services, Customers consent to all commercially reasonable information being provided to an Owner to complete its own due diligence review of, without limitation, the Customer, the Equipment booking details and the Account profile including Financial and Credit Information prior to determining if the Owner will accept the booking request and complete the prospective Transaction. Such information may include Account Information, Profile Information, Authentication Information, Usage Data, Transactional Information and Commercial Information to provide the Owner with a snapshot of you or your business. Additionally, we may provide further details regarding your rating as a Customer, including the number of disputed charges, current arrears, number of claims, etc. You agree that this disclosure of your personal or business information by MROScanner to specific Owners in these circumstances is both necessary and reasonable to be afforded the convenience of skipping a formal credit application with each individual Owner utilizing our Services. If you do not agree to this fundamental term, then you will not be permitted to use the Services. By accepting the Terms, Owners agree to keep all personal data so disclosed by MROScanner strictly confidential, secure and not to use it for any purpose except for performing the Transaction and conducting their Equipment business.

Service Providers

We may share information with vendors and service providers who are engaged by, or working with, us in connection with the processing of payments, operation of our Services and customer support functions and who need access to such information to work with us (including, without limitation, web hosting, analytics, e-mail delivery, marketing, insurance companies, claims administrators, equipment registration databases, credit reporting bureaus and customer support services). In some cases, the service provider may be directly collecting the information from you on our behalf.

Professional Advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Business Transfers

We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Responding to Legal Requests, Preventing Harm & Protecting Our Rights

As noted above, we may disclose your personal information to courts, law enforcement, governmental or tax authorities, or third parties. We will make such disclosure to the extent we are required or permitted to do so by applicable law or we consider such disclosure is reasonably necessary to comply with our legal obligations or legal process, to respond to claims asserted against us and for safety purposes described above. We may also disclose your information in response to valid legal requests relating to criminal investigations or alleged or suspected illegal activity or any other activity that may expose MROScanner you, or any other user to legal liability or to protect the rights, property, or personal safety of MROScanner, our employees, our Users, or members of the public.

We may also disclose your personal information as described elsewhere in this Privacy Policy or as disclosed to you at the time of collection.

In the event of a data breach, we will promptly notify affected users and relevant authorities in accordance with GDPR requirements.

Your Preferences & Choices

Opting Out of Marketing Communications

You may opt out of marketing-related e-mails by following the opt-out or unsubscribe instructions at the bottom of the e-mail. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message or as described in the message.

Correct & Update

You can review, correct, update, and edit certain information that has been previously provided to us by you at any time by logging in to your Account and reviewing your Account settings and profile. You can also access or request a correction of your information by contacting us at info@mroscanner.com For your protection, we may need to verify your identity before implementing your request.

Account Closure

If you wish to close your account and request the deletion of your personal information, please send an e-mail to info@mroscanner.com.

Please note that we may be unable to delete information needed to comply with applicable laws, detect or prevent fraud, collect any fees owed, resolve disputes, assist with or process claims, troubleshoot problems, assist with any investigation, comply with audits and investigation, to enforce our Terms and Policies and take other actions reasonably necessary, permitted, or required by applicable law. There may also be residual information that will remain within our databases and other records, which will not be removed.

Targeted Online Advertising

Please note that we may work with companies that do not participate in the opt out mechanisms that we linked above. In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

Choosing Not to Share Your Personal Information

Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or we later delete it at your request), we may not be able to provide you with our Services. We may tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

We employ a number of technical, physical, and organizational measures designed to protect information against unauthorized access, destruction, or alteration while it is under our control. However, no method of transmission over the Internet, and no method of storing information, can be 100% secure. So, we cannot guarantee the security of your transmissions to us and of your information that we store.

Important Information

This section describes some additional important privacy information related to your use of our Services.

Cross Border Transfer

The Services are controlled and operated by us from Estonia. Your information may be used, stored and processed in any country where we or our service providers (for example cloud hosting provider) have facilities or in which we provide services and/or engage service providers. These __cpLocations may be outside of your state, province, or country of residence, and may have different and/or less protective data protection rules than those of your state, province, or country. As a result, this information may be subject to access requests from governments, courts, regulatory agencies, security authorities or law enforcement in those jurisdictions according to the laws in those jurisdictions.

Transfers of personal data outside the European Union are conducted in compliance with GDPR, ensuring appropriate safeguards and legal frameworks, such as Standard Contractual Clauses, are in place to protect the data.

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive information unless specifically requested (e.g., Social Security numbers, social insurance numbers, passports, information related to racial or ethnic origin, or health), on or through the Services or otherwise to us.

Children’s Privacy

Our websites are general audience websites, and our Services are not intended for anyone under the age of 18. We do not knowingly collect information from Users under the age of 18. If a child under the age of 18 has already provided us with information, his or her parent or guardian may contact us for the purpose of deleting this information or closing an account.

Signed In

If you sign into our Services using an e-mail address and password, your session will expire after 30 days. If you are using a public or shared computer, you should sign out and/or clear your Cookies when you are done using our Platform in order to protect your account and your information. If you do not sign out, you or any other user of the computer/browser you signed in on will be able to view and access your account.

Translations

Where MROScanner may have provided you with a version of this Privacy Policy in a language other than English, in case of any wording discrepancies between such version and the English version, the English wording takes precedence.

Changes to this Privacy Policy

We may change this Privacy Policy. Please take a look at the “Last Revised” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy. If you do not agree to these changes, you can contact us to close your Account and you will only be bound by the prior version of the Privacy Policy.

Contact

MROScanner welcomes your questions and comments about privacy, and what we do. Please feel free to contact us at our email address: info@mroscanner.com

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