Privacy Policy

1. Introduction
ReachNow appreciates the
trust you place in us and does not want to jeopardize that trust. We respect your privacy and are
committed to protecting the security of your personal information. This Technology Platform Privacy
Policy (“Privacy Policy”) describes how ReachNow LLC, d/b/a ReachNow, and its subsidiary and
affiliated entities (collectively “ReachNow”, “we”, “us”, and “our”)
collects, uses, transfers, and discloses information about you (“you” or “your”) while
using or accessing the ReachNow website, located at www.reachnow.com (the “Website”), the
ReachNow mobile application(s) (the “App”), the ReachNow Fleet Solutions Program (“Fleet
Solutions”
), the ReachNow Ride Services (“ReachNow Ride”) and other websites or
applications that link to or display this Privacy Policy (collectively, the “Technology
Platform”
). By accessing or using the Technology Platform, you hereby consent to the terms of
this Privacy Policy and the Technology Platform Terms of Use under the “About” tab of the applicable
App (the “Terms of Use”)
. If you do not consent to the terms of this Privacy Policy and the
Terms of Use, please do not use our Technology Platform, products or services. ReachNow’s services
(the “Services”) consist of any activity or service where we collect your information,
including but not limited to the following:

      1.1

ReachNow Free-Floating CarSharing Program

      : ReachNow provides free-floating car
      sharing services in certain cities in the United States by making BMW and MINI vehicles (including
      BMW electric vehicles) available to people who meet its membership criteria and are approved as
      members (

“ReachNow CarSharing”

      ). You must apply for membership, be authorized by ReachNow to
      become a member, and enter into a ReachNow Free-Floating CarSharing Program Membership Agreement
      with ReachNow (the

“Membership Agreement”

      ) before reserving or operating any ReachNow
      CarSharing vehicle. See the Membership Agreement under the “About” tab on the App or
    www.reachnow.com for more information about ReachNow CarSharing.
      1.2

ReachNow Fleet Solutions Program:

      ReachNow provides station-to-station car sharing
      services (the

“Fleet Solutions Program”

      or

“Fleet Solutions”

      ) at certain locations
      including but not limited to residential buildings and places of employment by making vehicles
      available to people who meet its Fleet Solutions membership criteria and are approved as Fleet
      Solutions members. You must apply for membership, be authorized by ReachNow to become a member, and
      enter into a ReachNow Fleet Solutions Addendum to ReachNow Free-Floating CarSharing Program
      Membership Agreement with ReachNow (the

“Fleet Solutions Addendum”

      ) before reserving or
      operating any Fleet Solutions vehicle. See the Fleet Solutions Addendum under the “About” tab on the
    App or www.reachnow.com for more information about Fleet Solutions.
      1.3

ReachNow Ride:

      ReachNow provides a ride sharing service (

“ReachNow Ride”

      )
      to passengers who are invited and approved to participate in ReachNow Ride using drivers employed by
      a third party entity to drive vehicles owned or leased by ReachNow. You must be invited and
      approved to participate in ReachNow Ride by ReachNow and you must enter into the ReachNow Ride
      Passenger Agreement with ReachNow (the

“ReachNow Ride Agreement”

      ) before using the ReachNow
      Ride services. See the Ride Passenger Agreement under the “About” tab on the App for more
    information about the ReachNow Ride.
2. What Information Does ReachNow Collect?
As part of evaluating your application to join ReachNow and
providing you with our products and Services, we, and third parties engaged by us,
obtain personally identifiable information about you including, but not limited to, your
first and last name, home or other physical address, email address, phone number, date
of birth, drivers’ license information, personal photo, and credit card information
(collectively, “Personal Information”). As part of the application process for
joining ReachNow CarSharing, we, or a third party engaged by us, will also run a Driver
Record Check (as defined in the Membership Agreement) on you. We may also collect
information from you as described in Section 6 below.
3. How Does ReachNow Use My Information?
Our primary goals in collecting Personal Information from you are
to: (a) enable us to approve or disapprove your membership status (on an ongoing basis)
in accordance with the Membership Criteria (as defined in the Membership Agreement); (b)
facilitate efficient transactions; and (c) provide you with information regarding
relevant products and services. We may also use information we collect from you to
improve or develop new products, services or websites; conduct research or analysis;
comply with legal requirements; or other purposes. We, or third parties engaged by us,
may store any information we collect from you.
4. What Information Does ReachNow Share?
We will share Personal Information with certain third parties in
order to process your application to join ReachNow and as part of providing you with our
products and Services. For example, we may share Personal Information with members of
the BMW Group (as defined below) or any subsidiaries of any member of the BMW Group who
may assist us in providing offers for products or services that may be of interest to
you. The “BMW Group” includes, but is not limited to, the following members: BMW AG,
BMW of North America, BMW Financial Services, BMW Bank of North America and BMW
Insurance Agency. If you use ReachNow Ride, we may share your Personal Information with
third party drivers employed by third party entities or transportation companies (each a
“Driver”) who use ReachNow to provide you with our Services. We may also share Personal
Information with non-affiliated companies that market our products and Services, who are
distinct entities and have their own privacy policies. We may also share information
about you and your reservation and use of ReachNow vehicles with law enforcement
officials or other third parties in connection with traffic and parking violation
citations; accident reports; tolls; and other citations, violations, fines, or similar
items and/or to comply with law or requests by law enforcement or governmental agencies.
We may also share Personal Information with non-affiliated companies that provide
services on our behalf (including, but not limited to, insurance companies, customer
support companies, mail fulfillment companies, or identification verification
companies). For example, we have engaged a third-party identification credentials
authentication company to verify the identification you submit to us and so we will
share information submitted by you including, but not limited to, the information
contained on, and an image of, your driver’s license and a comparison photo. Such
third-party identification credentials authorization company may store these images and
information. The third parties listed in this Section 4 are not exclusive. We may engage
other third parties to assist us with providing you with our products and services from
time to time, without notice to you, and we may share any and all information we collect
from you with such third parties subject to applicable law.
5. Confidentiality
In
certain areas of the Technology Platform you may choose to share Personal Information
with us. We may use this information for marketing research and other marketing and
service related purposes like sending brochures you request and keeping in touch by
email. Where required or permitted by law, we may share your Personal Information with
the BMW Group, our related companies, our business partners or others. We may transfer
information about you to a company that acquires the assets of ReachNow or one of our
business units, for example, as a result of a sale, merger, reorganization or
liquidation. Customer telephone calls may be recorded to protect you and our staff.
6. Registration and Personal Settings
ReachNow provides car sharing services in certain cities in the
United States to people who meet its Membership Criteria (as defined in the Membership
Agreement) and are approved as members. You must apply for membership, be authorized by
ReachNow and enter into a Membership Agreement with ReachNow before reserving,
operating, and riding in any ReachNow vehicle. As stated above, to use Fleet Solutions,
you must also enter into a Fleet Solutions Addendum and to use ReachNow Ride, you must
also enter into the ReachNow Ride Agreement. Registered members of ReachNow CarSharing,
the Fleet Solutions Program, and ReachNow Ride may access the reservation system and
correct or update their personal information by entering their login ID and password. To
edit, delete or add to information you have shared while visiting our Technology
Platform, log in and go to the Profile section. If you notify us that any information
you provided us (such as ZIP code or email address) has changed, we will endeavor to
correct or update your personal data. If your membership of ReachNow CarSharing, the
Fleet Solutions Program, or ReachNow Ride is terminated for any reason, we may keep the
information we have collected from you for a period of time to be determined in our sole
discretion subject to applicable law. Additionally, the information you include in a
registration or reservation request is secure while in transit to us.
7. How We Collect Information
We use browser cookies, web beacons, logs and other technologies
for analytics, functionality, convenience, marketing, security or other purposes
relating to your use of our Technology Platform or Services.7.1. Cookies:

      Cookies produce a luxury and convenience similar to that of
      memory seats. They save you the trouble of reentering certain information in some
      registration areas, help to deliver content specific information to you and track which
      sections of the site are most popular. The cookies we use are elements of data stored
      by your browser on your device. We use browser cookies to authenticate you; track your
      session; remember settings, location or preferences; for advertising and conversion
      tracking; or provide other functions. You may set your browser settings to reject
      cookies or to alert you when a cookie is placed on your device. The Help portion of
      your browser should explain how to configure your browser’s cookie handling. You may
    have limited functionality if you block browser cookies set by our websites.

7.2. Web Beacons

      : Web beacons are objects placed on web pages that allow
      us to determine whether and for how long you view web pages. We use web beacons for
      site traffic reporting, auditing and reporting, personalization, unique visitor counts,
      advertising, conversion tracking or other functions. Your web browser may have add-ons
      that may help you to manage web beacons. You may have limited functionality if you
    block web beacons set by our websites.

7.3. Third Party Service Providers

      : We may use third-party service
      providers to provide us information, analysis and reports about the use of our websites
      and to enable you to interact with us or other users of our products, services or
      websites. We may use various web technologies from Google, Facebook, Twitter,
    Optimizely or others.

7.4. Advertisements

      : We may use third-party service providers to provide
      us with advertising, marketing, conversion tracking or other information and services.
      We may use various web technologies from Microsoft Atlas, Rocket Fuel or others. You
      may find out more information about these technologies and your choices by using the
      Digital Advertising Alliance opt-out page located at www.aboutads.info/choices, the
      Network Advertising Initiative opt-out page located at
      www.networkadvertising.org/choices, or the Interactive Advertising Bureau EU page
    located at www.iab.net.

7.5. Logs

      : We use log information relating to Internet Protocol
      addresses, web requests, date and time of your request, operating systems, browser
      types, browser languages and cookies that may uniquely identify your browser or your
      device. We use this information to administer our systems; diagnose problems; provide
      analytics; enhance the functionality of our products, services or websites; or to make
    our products, services or websites more convenient, secure or efficient.

7.6. Other Automated Collection

      : We may also collect automated information
      through technologies built into our mobile application software. These technologies may
      gather information on how you interact with and use our products or services. ReachNow
      collects information that does not personally identify you such as device-specific
      information, including your IP address, web browser type, device type, operating system
      version, mobile device carrier, and unique device identifiers. We also may collect
      information about your usage of our Services, preferences, and interaction with certain
    features.

7.7. Location Information

      : While using Fleet Solutions, ReachNow Ride, and
      the Reserve Feature, we collect information about your location that may be precise or
      imprecise, such as the start and end locations of your trip and where you park. The
      precise location information that we collect may be Global Position System (GPS) data or
      geolocation data identified from nearby cell towers and Wi-Fi hotspots when you enable
      location-based features. We also collect location information that you manually enter
      (such as your, ZIP Code, city, state or latitude/longitude), or that is provided by your
      IP address. If you disable your location features, the accuracy of your location may be
      impacted, and we may not be able to provide you with requested Services. When using our
      ReachNow Ride and/or the Reserve Feature, we also collect information about your
      location through our drivers that includes the location of your pick up and drop off
    point as well as the length of your trip.

7.8 Employer/Residential Information.

      Through your use of the Fleet
      Solutions Program, we may receive Personal Information or information about you from
      your school, your employer, or the management of the residential building in which you
    live.

7.9 Call, Text and Address Book Information.

      We collect information about
      your communications via phone call and text messages with the Drivers (as defined in the
      ReachNow Ride Agreement) that you connect with using ReachNow Ride and valet agents you
      connect with using the Reserve Feature (as defined in the Membership Agreement). Such
      information may include the date and time of the communication, phone numbers, and/or
      content of messages. If you permit us to access your address book on your device, we
      may access, use and store this information to enable interactions that you initiate
    while using ReachNow Ride or for purposes stated at the time you provide consent.

7.10 Surveys and Feedback.

      From time to time, we may request information
      including Personal Information and/or feedback from you through a survey on our
      Technology Platform. Your participation in any survey is completely voluntary and you
      have a choice to provide us the requested information. We use the information collected
      by surveys and feedback to improve the functionality of our Technology Platform, enhance
      your experience with our Technology Platform, and optimize our provision of the Services
    to you.
8. Subscriptions/Newsletters
Except for communications related to registration or reservations
or in response to a specific request from you, you will only receive emails or mailings
from ReachNow if you have requested to be on our correspondence list. If you are
currently on our list and do not wish to receive further information from us, simply
click on the unsubscribe link at the bottom of the correspondence.
9. Links
Though our
Technology Platform may contain links to other sites or third party content, we are not
responsible for the content, links or privacy on any of those sites. We encourage you to
read the privacy policies of those third parties. ReachNow is not responsible or liable
for any information that you provide to or may be collected by such third parties.
10. Email Links
We may use
email links throughout the Technology Platform to allow you to contact us directly with
any questions or comments you may have. We read every message and try to reply promptly
to everyone. Information in the message may be used to respond directly to your
comments or questions. We may also file your comments to improve the Technology
Platform and programs, or review and discard the information.
11. California Residents
If
you are a California resident, California Civil Code Section 1798.83 permits you to
request from us once a year, free of charge, a list of all third parties to which we
have disclosed certain personally identifiable information as defined under California
law for such third parties’ direct marketing purposes in the preceding calendar year.
If you are a California resident and would like to make such a request, please email us
at info@reachnow.com or write us at the address noted below. The California Online
Privacy Protection Act (“CalOPPA”) requires ReachNow to disclose how it responds
to Do Not Track Signals. ReachNow does not respond to Do Not Track Signals. As noted
above, you may set your browser settings to reject cookies or web beacons but doing so
may hinder your experience on the Technology Platform. Please see the Help portion of
your browser for instructions on managing your security preferences.
12. Questions
ReachNow,
located at 2118 3rd Avenue, Seattle, WA 98121 is the data controller responsible for the
processing of your information. If you have further questions about our Privacy Policy,
the practices of our Technology Platform or your experience with our Technology
Platform, contact us at info@reachnow.com, 2118 3rd Avenue, Seattle, WA 98121, or (844)
732-2466.
13. Revisions
We may change
our Privacy Policy and/or Terms of Use on one or more occasions by posting a revised
policy on the Technology Platform. When we post changes, we will revise the Last
Updated date above. The revised version will be effective on the Effective Date above.
If the revised version includes substantial changes, we will attempt to provide you with
30 days’ prior notice by posting the revised version at least 30 days before the
Effective Date. We encourage you to frequently review this Privacy Policy and Terms of
Use for changes. Your continued use of the Technology Platform after we make changes is
deemed to be an acceptance of those changes to the Privacy Policy and Terms of Use.