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PRIVACY POLICY

Version 1.2 - Last Updated: March 10, 2026

This Privacy Policy explains how Rental Commerce Inc. d/b/a Cloud of Goods ("Cloud of Goods," "CoG," "we," "us," or "our") collects, uses, discloses, stores, transfers, and otherwise processes personal information when you access or use our website, applications, booking tools, marketplace, customer support channels, communications, and related services (collectively, the "Platform").

This Privacy Policy is intended to provide a global baseline notice. Additional rights and disclosures may apply depending on where you live, including in the European Economic Area ("EEA"), United Kingdom ("UK"), Canada, Québec, Mexico, Australia, California, and other jurisdictions.

By using the Platform, you acknowledge that your personal information will be handled as described in this Privacy Policy.

1. WHO WE ARE

Cloud of Goods operates an online marketplace and technology platform that helps customers discover, compare, request, reserve, rent, and pay for equipment and related services offered by independent third-party rental partners, suppliers, merchants, and equipment owners ("Partners").

For most Platform activities, Cloud of Goods determines the purposes and means of certain personal information processing described in this Privacy Policy and acts as a controller, business, or equivalent responsible organization under applicable law.

In some situations, Cloud of Goods and a Partner may independently determine how personal information is processed for their respective business purposes. Partners may also process your information under their own privacy policies.

Contact Information

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information we collect when you:

  1. visit or use the Platform;
  2. create an account;
  3. place or attempt to place a booking;
  4. communicate with us by email, phone, chat, SMS, social media, or customer support channels;
  5. interact with our marketing communications;
  6. participate in promotions, surveys, reviews, or feedback requests; or
  7. otherwise interact with us in a commercial or business context.

This Privacy Policy does not apply to:

  1. information processed solely on behalf of a Partner where the Partner is independently responsible for such processing;
  2. third-party websites, apps, payment processors, or services not controlled by us; or
  3. employee, applicant, or contractor data, unless specifically stated.

3. PERSONAL INFORMATION WE COLLECT

Depending on how you interact with the Platform, we may collect the following categories of personal information.

3.1 Identifiers and Contact Information.

We may collect:

  1. name;
  2. email address;
  3. phone number;
  4. billing address;
  5. delivery or pickup address;
  6. account username or login credentials;
  7. customer ID or booking ID;
  8. IP address and device identifiers.

3.2 Transaction and Booking Information.

We may collect:

  1. booking details;
  2. equipment selections;
  3. rental dates and times;
  4. delivery and pickup details;
  5. order history;
  6. payment status;
  7. refund, credit, and chargeback information;
  8. claims, disputes, and issue-resolution records.

3.3 Payment Information.

We may collect limited payment-related information, such as:

  1. payment method type;
  2. billing details;
  3. partial card information such as last four digits where available;
  4. payment processor transaction references.

Full payment card numbers are generally processed by our third-party payment processors, not stored by Cloud of Goods except where necessary and lawful.

3.4 Communications and Support Information.

We may collect:

  1. customer service requests;
  2. call recordings where permitted by law;
  3. chat transcripts;
  4. emails and SMS messages;
  5. complaint details;
  6. survey responses;
  7. review content;
  8. attachments, photos, or documents you send us.

3.5 Device, Usage, and Technical Information.

We may collect:

  1. browser type;
  2. device type;
  3. operating system;
  4. IP address;
  5. approximate location inferred from IP;
  6. pages viewed;
  7. clicks, sessions, referral URLs, and timestamps;
  8. app usage data;
  9. cookies and similar technology data;
  10. crash logs and diagnostics.

3.6 Marketing and Preferences Information.

We may collect:

  1. language preferences;
  2. saved items or browsing behavior;
  3. communication preferences;
  4. campaign engagement data such as opens and clicks;
  5. promotional redemptions;
  6. interests inferred from interactions where permitted by law.

3.7 Identity Verification and Fraud Prevention Information.

Where necessary, we may collect or receive:

  1. fraud screening results;
  2. account verification information;
  3. transaction risk signals;
  4. security flags;
  5. limited government-issued ID data where required by law or reasonably necessary for fraud prevention, dispute handling, or safety.

3.8 Sensitive or Special Category Data.

We do not seek to collect sensitive or special category personal information unless reasonably necessary and lawful.

Depending on the service context, users may voluntarily disclose information that may be considered sensitive under some laws, such as:

  1. mobility-related needs;
  2. medical-adjacent equipment needs;
  3. child-related equipment requirements;
  4. accessibility requirements.

Please avoid sending sensitive personal information unless it is necessary for your request.

Where required by law, we will obtain consent or provide additional notices before processing sensitive personal information.

4. SOURCES OF PERSONAL INFORMATION

We collect personal information from the following sources:

  1. Directly from you, when you create an account, place a booking, contact support, submit forms, or otherwise interact with us;
  2. From Partners, when they fulfill bookings, report delivery/pickup details, communicate regarding claims, or share booking-related information;
  3. From payment processors, fraud-prevention providers, analytics vendors, customer support providers, and other service providers;
  4. Automatically from your device or browser, through cookies, SDKs, logs, pixels, and similar technologies;
  5. From third-party platforms, if you interact with our ads, social pages, integrations, or marketing campaigns;
  6. From publicly available sources, to the extent lawful and relevant for fraud prevention, compliance, or business operations.

5. HOW WE USE PERSONAL INFORMATION

We use personal information for the following purposes, as permitted by law:

5.1 To Provide the Platform and Services.

We use personal information to:

  1. create and manage accounts;
  2. facilitate bookings and reservations;
  3. communicate with customers and Partners;
  4. arrange delivery, pickup, and support workflows;
  5. process payments, refunds, and credits;
  6. administer optional protection products;
  7. provide customer support.

5.2 To Operate and Improve the Platform.

We use personal information to:

  1. maintain, analyze, secure, and improve the Platform;
  2. troubleshoot errors and technical issues;
  3. develop new features;
  4. personalize user experience where permitted;
  5. understand product usage and performance.

5.3 For Safety, Fraud Prevention, and Security.

We use personal information to:

  1. detect and prevent fraud, abuse, theft, and unauthorized activity;
  2. verify transactions;
  3. investigate disputes, incidents, and complaints;
  4. enforce our agreements and policies;
  5. protect users, Partners, Cloud of Goods, and the public.

5.4 For Communications and Marketing.

We use personal information to:

  1. send transactional messages;
  2. send support responses;
  3. send service notices and policy updates;
  4. send newsletters, promotions, or marketing communications where permitted;
  5. measure the effectiveness of campaigns;
  6. tailor content and offers where permitted by law.

5.5 For Legal and Compliance Purposes.

We use personal information to:

  1. comply with legal obligations;
  2. respond to lawful requests, subpoenas, court orders, and investigations;
  3. establish, exercise, or defend legal claims;
  4. meet tax, accounting, audit, and recordkeeping obligations.

5.6 For Business Operations.

We use personal information to:

  1. conduct internal reporting and analytics;
  2. manage vendor relationships;
  3. support mergers, acquisitions, financing, asset sales, or similar transactions;
  4. maintain records and administrative controls.

Where required by applicable law, including in the EEA and UK, we rely on one or more of the following legal bases:

  1. Performance of a contract: to provide the Platform, process bookings, provide support, and manage transactions;
  2. Legitimate interests: to operate, improve, secure, analyze, market, and administer the Platform, provided such interests are not overridden by your rights;
  3. Consent: where required, such as for certain cookies, certain direct marketing, or certain sensitive-data processing;
  4. Legal obligation: to comply with applicable law, tax, accounting, consumer, and regulatory requirements;
  5. Vital interests: where necessary to protect someone's life or physical safety;
  6. Public interest or legal claims: where authorized by law.

You may withdraw consent where processing is based on consent, but withdrawal does not affect prior lawful processing.

7. COOKIES AND SIMILAR TECHNOLOGIES

We and our service providers may use cookies, pixels, web beacons, SDKs, local storage, and similar technologies to:

  1. operate and secure the Platform;
  2. remember preferences;
  3. analyze traffic and usage;
  4. measure campaign performance;
  5. personalize content and offers;
  6. support advertising and retargeting, where permitted.

Depending on your location, we may provide a cookie banner, consent manager, or preference center allowing you to accept, reject, or adjust non-essential cookie settings.

You can also manage cookies through your browser settings, although some Platform features may not function properly if cookies are disabled.

If Cloud of Goods uses third-party ad-tech or cross-context behavioral advertising tools, additional opt-out or consent rights may apply under local law.

8. WHEN WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information to the following categories of recipients:

8.1 Partners.

We disclose personal information to the Partner fulfilling your booking, including as needed to:

  1. confirm and manage the reservation;
  2. coordinate delivery and pickup;
  3. resolve disputes or claims;
  4. comply with legal obligations.

8.2 Service Providers and Vendors.

We disclose personal information to vendors and service providers that support our business, such as:

  1. payment processors;
  2. cloud hosting providers;
  3. analytics providers;
  4. customer support platforms;
  5. communication providers;
  6. fraud-prevention and security vendors;
  7. marketing and email providers;
  8. software and IT providers.

8.3 Professional Advisors and Corporate Transaction Parties.

We may disclose information to:

  1. lawyers;
  2. auditors;
  3. insurers;
  4. consultants;
  5. lenders or investors;
  6. acquirers or counterparties in a merger, financing, sale, reorganization, or similar transaction.

8.4 Government, Regulators, and Legal Authorities.

We may disclose information if reasonably necessary to:

  1. comply with legal process;
  2. respond to lawful requests;
  3. protect rights, property, or safety;
  4. investigate fraud or illegal conduct;
  5. enforce our agreements.

8.5 With Your Direction or Consent.

We may disclose information where you ask us to do so, direct us to do so, or consent to such disclosure.

9. SALE, SHARING, AND TARGETED ADVERTISING DISCLOSURES

Because privacy laws use the terms "sell," "share," and "targeted advertising" differently, this section should be read broadly.

Cloud of Goods does not sell personal information for money in the ordinary sense.

However, if we use third-party advertising, analytics, pixels, audience-matching tools, or similar technologies, certain disclosures may be considered a "sale," "sharing," or "targeted advertising" under some laws, even if no money changes hands.

Where required by law, we will provide:

  1. notice of those practices;
  2. a method to opt out of sale, sharing, or targeted advertising;
  3. consent options where required;
  4. a mechanism to honor applicable browser-based or device-based preference signals where legally required.

If your actual technical setup does not involve such tools, this section may be narrowed during final legal implementation.

10. INTERNATIONAL DATA TRANSFERS

Cloud of Goods may process and store personal information in the United States and other countries where we or our service providers operate.

These countries may have data protection laws that differ from those in your home country.

Where required by law, we will use appropriate safeguards for cross-border transfers, such as:

  1. contractual safeguards;
  2. standard contractual clauses or equivalent mechanisms;
  3. adequacy decisions where recognized;
  4. additional technical or organizational measures where appropriate.

By using the Platform, you understand that your personal information may be transferred internationally, subject to applicable legal protections.

11. DATA RETENTION

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

  1. provide services and support;
  2. maintain accounts and transaction records;
  3. comply with legal, tax, accounting, and regulatory obligations;
  4. resolve disputes;
  5. prevent fraud and abuse;
  6. enforce agreements;
  7. support internal business operations.

Retention periods vary depending on the type of information, the nature of the relationship, legal requirements, and operational needs.

When we no longer need personal information, we will delete, de-identify, anonymize, or securely destroy it, unless continued retention is required or permitted by law.

12. DATA SECURITY

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

However, no internet, transmission, storage, or security system is completely secure. We cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your credentials and for using secure devices and networks.

13. YOUR PRIVACY RIGHTS

Depending on where you live, you may have legal rights regarding your personal information, subject to exceptions and limitations under law.

These rights may include the right to:

  1. know whether we process your personal information;
  2. access your personal information;
  3. receive a copy of your personal information;
  4. correct inaccurate personal information;
  5. delete personal information;
  6. object to or restrict certain processing;
  7. withdraw consent;
  8. opt out of marketing communications;
  9. opt out of sale, sharing, or targeted advertising;
  10. limit certain uses of sensitive personal information where applicable;
  11. request portability of certain information;
  12. not be discriminated against for exercising your rights;
  13. lodge a complaint with a regulator or supervisory authority.

To exercise applicable rights, contact us using the details in this Privacy Policy. We may need to verify your identity before responding.

You may also designate an authorized agent where permitted by law.

14. MARKETING COMMUNICATIONS

You may opt out of promotional emails by using the unsubscribe link in the message or by contacting us.

You may still receive transactional or service-related communications, including booking confirmations, support messages, security notices, and policy updates.

SMS or push communications may be subject to separate consent and opt-out mechanisms.

15. CHILDREN'S PRIVACY

The Platform is not directed to children, and we do not knowingly collect personal information directly from children under the age required by applicable law without appropriate authorization.

If you believe a child has provided personal information in violation of applicable law, contact us so we can investigate and take appropriate action.

16. THIRD-PARTY WEBSITES AND SERVICES

The Platform may contain links to third-party websites or integrate with third-party services.

We are not responsible for the privacy, security, or data practices of third parties. Their practices are governed by their own policies and terms.

We encourage you to review third-party privacy notices before interacting with them.

17. AUTOMATED DECISION-MAKING AND PROFILING

Cloud of Goods may use automated tools for fraud detection, risk scoring, marketing optimization, analytics, and operational efficiency.

We do not use solely automated decision-making that produces legal or similarly significant effects on individuals unless lawful and appropriately disclosed.

Where required by law, you may have the right to request human review or additional information about such processing.

18. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in law, technology, business practices, or Platform features.

If we make material changes, we will provide notice as required by law, such as by posting an updated policy, changing the effective date, or providing additional notice through the Platform or by email.

Your continued use of the Platform after an update means the updated Privacy Policy applies, to the extent permitted by law.

19. HOW TO CONTACT US

For questions, requests, or complaints about this Privacy Policy or our privacy practices, contact:

REGION-SPECIFIC PRIVACY DISCLOSURES

The following sections provide additional information for individuals in specific jurisdictions.

20. EUROPEAN ECONOMIC AREA (EEA) AND UNITED KINGDOM

If you are located in the EEA or UK, the following additional terms apply.

20.1 Controller

Cloud of Goods is the controller for the processing described in this Privacy Policy, except where another party is clearly identified as independently responsible.

20.2 Legal Bases

We rely on the legal bases described in Section 6.

20.3 Your Rights

Subject to applicable law, you may have the right to:

  1. access your personal data;
  2. rectify inaccurate personal data;
  3. erase personal data;
  4. restrict processing;
  5. object to processing based on legitimate interests;
  6. data portability;
  7. withdraw consent;
  8. lodge a complaint with your local supervisory authority.

20.4 International Transfers

Where personal data is transferred outside the EEA or UK, we will use recognized safeguards where required, such as standard contractual clauses or the UK equivalent.

20.5 Representatives

If required by applicable law, Cloud of Goods may designate an EU representative and/or UK representative. If appointed, their contact details will be posted here or in a supplemental notice.

20.6 Supervisory Authority Complaints

You may lodge a complaint with your local supervisory authority, though we encourage you to contact us first so we can attempt to resolve your concern.

21. CANADA

If you are in Canada, the following additional terms apply.

We collect, use, and disclose personal information for purposes a reasonable person would consider appropriate in the circumstances.

Where required, we obtain meaningful consent for the collection, use, and disclosure of personal information.

You may request access to, or correction of, your personal information, subject to legal exceptions.

If you are not satisfied with our response, you may have the right to complain to the Office of the Privacy Commissioner of Canada or a relevant provincial authority.

If you are in Québec, see the Québec-specific section below.

22. QUÉBEC

If you are in Québec, the following additional terms apply.

We are committed to providing a clear and simple privacy notice concerning personal information collected through technological means.

Subject to applicable law, Québec residents may have rights relating to:

  1. access;
  2. rectification;
  3. withdrawal of consent where applicable;
  4. complaints about privacy practices;
  5. information about automated decision-making where applicable;
  6. data portability where required by law.

If required by law, Cloud of Goods will identify the person exercising the highest authority over privacy compliance or the designated privacy officer.

23. MEXICO

If you are in Mexico, the following additional terms apply.

Cloud of Goods will process personal data in accordance with applicable Mexican data protection law and provide a privacy notice describing:

  1. what data we collect;
  2. the purposes of processing;
  3. transfers;
  4. rights available to you;
  5. the method for exercising those rights.

Subject to applicable law, you may have ARCO rights, meaning the right to:

  1. access your personal data;
  2. rectify inaccurate or incomplete data;
  3. cancel data where appropriate; and
  4. object to certain processing.

You may also revoke consent where permitted by law.

24. AUSTRALIA

If you are in Australia, the following additional terms apply.

We handle personal information in accordance with applicable Australian privacy law, including the Australian Privacy Principles where applicable.

You may request access to, or correction of, your personal information, subject to legal exceptions.

If we disclose personal information overseas, we take reasonable steps where required by law to ensure overseas recipients handle the information consistently with applicable privacy requirements.

If you have a privacy complaint, contact us first. If you are not satisfied, you may have rights to escalate the matter to the Office of the Australian Information Commissioner.

25. CALIFORNIA AND OTHER U.S. STATE PRIVACY RIGHTS

If you are a California resident, or if similar state laws apply to you, the following additional disclosures may apply.

25.1 Categories of Personal Information Collected

In the past 12 months, we may have collected the categories described in Section 3, including identifiers, commercial information, internet activity, geolocation derived from IP, communications, payment-related information, and in limited cases sensitive information where lawful and necessary.

25.2 Purposes

We use personal information for the purposes described in Section 5.

25.3 Disclosure Categories

We may disclose personal information to Partners, service providers, contractors, analytics vendors, fraud-prevention providers, advisors, and authorities as described in Section 8.

25.4 Sale / Sharing / Targeted Advertising

Depending on our actual technical implementation, use of certain cookies, pixels, or ad-tech tools may constitute "sale" or "sharing" under California law. If applicable, we will provide required notice and opt-out mechanisms.

25.5 Your Rights

Subject to legal limitations, you may have the right to:

  1. know what personal information we collect, use, disclose, sell, or share;
  2. access specific pieces of personal information;
  3. request deletion;
  4. request correction;
  5. opt out of sale or sharing;
  6. limit certain uses of sensitive personal information where applicable;
  7. not be discriminated against for exercising privacy rights.

To exercise these rights, contact us using the details above.

26. DO NOT TRACK AND PREFERENCE SIGNALS

Some browsers and devices offer "Do Not Track" or similar privacy preference signals.

Because standards are evolving, Cloud of Goods may not respond to all such signals unless required by law.

Where legally required, we will honor recognized opt-out preference signals for sale/sharing or targeted advertising.

27. BUSINESS CONTACTS

If you interact with us as a representative of a business, Partner, vendor, or prospective commercial relationship, we may process your professional contact information for contract negotiation, onboarding, administration, security, and business communications.

28. RETENTION OF DE-IDENTIFIED OR AGGREGATED DATA

We may de-identify, anonymize, or aggregate information so that it no longer reasonably identifies you.

We may use and disclose such information for lawful business purposes, including analytics, service improvement, research, reporting, and commercial insights, subject to applicable law.

29. ACCESSIBILITY AND LOCAL LANGUAGE VERSIONS

If you need this Privacy Policy in an accessible format or in a local-language version required by law, please contact us.

Where a local-language version is required by law, Cloud of Goods may provide such version, and that version may control for users in that jurisdiction to the extent required.