Privacy

Last updated: May 13th, 2025

At GoVyrl, Inc., we respect your privacy. Please read this Privacy Policy carefully to learn how we collect, use, share, and otherwise process your information (“Personal Information”), and to learn about any potential rights you may have regarding your Personal Information.

This Privacy Policy applies to GoVyrl, Inc. (“Carro,” “we,” “us,” or “our”), and it explains how we collect, use, and share Personal Information gathered on our subdomains and websites at getcarro.com (the “Website”) or through the applicable services (“Services”). By continuing to use this Website, or otherwise affirmatively assenting to this Privacy Policy, you agree we can process your Personal Information in accordance with this Privacy Policy. A reference to “Carro,” “we,” “us,” or “our” is a reference to GoVyrl, Inc., and our relevant affiliates involved in the collection, use, sharing, or other processing of Personal Information.

This Privacy Policy does not apply to the extent we process Personal Information in the role of a processor or service provider on behalf of a Retailer, as defined below. In such cases, we process Personal Information on their behalf and in accordance with their instructions. To understand how a Supplier or Retailer may process your information, please refer to their respective privacy policy.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact information provided at the end of this Privacy Policy.

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1. Information We Collect

If you are a merchant using Carro to offer goods (a “Supplier”) for sale on e-commerce websites, mobile apps, and other platforms (a “Retailer”), or a Retailer engaged with us, we may collect and use your Personal Information to provide you with the use of our Services. We also collect some information from individuals who visit our Website or use our Services but are not Retailers or Suppliers (a “Consumer(s)”). A reference to “you” or “your” within this Privacy Policy is a reference to a Supplier, Retailer, and/or Consumer, depending on the context.

Information You Give Us. You may give us information about you. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, if you choose to connect your Supplier account or Retailer e-commerce platform with Carro), or communicate with us in any other way. The categories of information include:

• Identifiers such as real name, address, email address, Internet Protocol address, account name, or other similar identifiers.
• Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, address, telephone number, education, employment, employment history, or similar identifiers.
• Commercial information such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement, interactions with our Services, interactions with our APIs, and communications and responses through our Services.
• Professional or employment-related information.
• Education information.
• Inferences drawn from the above categories of information.

The categories of sensitive information include:

• Account log-in, in combination with any required security or access code, password, or credentials allowing access to the account.
• Contents of mail, email, and text messages, unless we are the intended recipient of the communication.

Information We Automatically Collect. Like many website operators, we collect information that your browser sends whenever you visit our website. We may use cookies and other tracking technologies to collect some of this information.

The categories of information include:

• Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
• Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.
• Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services.

Information We Collect From Third Parties. From time to time, we may obtain information about you from third-party sources, such as public databases, public profiles on social media platforms, and third-party data providers

If you access our Website through third parties (e.g., Facebook or Google), or if you share content from our Websites to a third-party social media service, the third-party service will send us certain information about you if the third-party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.

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2. How We Use Personal Information

We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:

• To provide you with the Services, which includes:
  - maintaining and servicing accounts,
  - providing customer service,
  - processing and fulfilling orders and transactions,
  - verifying customer information,
  - processing payments,
  - recommending or providing financing solutions, such as rapid-advances to meet heavy order demands (e.g., Black Friday / Cyber Monday), and,
  - providing advertising or marketing services to you.

• To provide analytic services, such as analyzing Retailer usage and improving services offered.
  
• To refine and improve our Services.
• To share with third-party marketing platforms (e.g., AppLovin, Google Ads, Facebook Ads) to provide tailored advertising on our Websites and other websites that you may visit.
• For market research and project planning.
• For detecting and protecting against error, fraud or other criminal activity.
• To enforce compliance with our Terms and applicable law, and to protect the rights and safety of our Retailers, Supplier, and other third parties, as well as our own. This may include developing tools and algorithms that help us monitor the use of our Services and prevent violations.

Marketing. We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Information” section below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).

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3. How We Share Personal Information

Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our Services. These third parties help us to:

• Run, operate, and maintain our Website through third-party platforms and software tools;
• Perform content moderation and crash analytics;
• Run email messaging campaigns; 
• Perform marketing analytics;
• Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
• Administer promotions, including eligibility;
• Provide payment attribution; and,
• Provide technical and customer support.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like credit card number, with us, but may share limited information with us related to your purchase, like your zip code.

Between Retailers and Suppliers. We may share the information of Retailers and Suppliers with other Retailers and Suppliers in our network. We may share this information with Retailers and Suppliers through avenues such as the Carro browser dashboard, the Carro application dashboard, or through tools and APIs that may integrate with our Services.

Third Party Marketing and Advertising Organizations. Through website cookies, which you may manage through our cookie banner, or other tracking technologies, we share your information with third party marketing and advertising partners, such as AppLovin, Google, Facebook, Instagram, and YouTube, to provide tailored advertising on our Website and other websites that you may visit.

Third Party Links and Websites. Our Website may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including meeting law enforcement requirements. We may be under a duty to disclose or share your Personal Information in order to comply with any legal obligation, to enforce or apply our Terms and other agreements, to protect our rights, property, or safety, or the protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Deidentified and Aggregate Data. We may aggregate or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. We reserve the right to make use of any such aggregated data as we see fit.

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4. Your Privacy Choices

Email Marketing.

• From Retailers or Suppliers: If you no longer want to receive email marketing from a Retailer or Supplier, please unsubscribe directly from that Retailer or Supplier’s email list.
• From Carro: If you no longer want to receive email marketing from us, you may opt out of receiving any, or all, of these communications by following the unsubscribe instructions provided in any email we send. You will still continue to receive service-related messages concerning our Services.

Exercising Your Privacy Rights: We have listed the privacy rights for several jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws.

A. Privacy Rights & Additional Disclosures for Certain U.S. Residents

Several jurisdictions grant state residents certain rights and disclosures. We provide the following information to further help you understand your potential privacy rights. If you would like to exercise any rights or inquire as to whether such rights are available to you, please email us at privacy@getcarro.com. 

Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us at the Contact Information below.

Request for Information or Deletion. Residents of certain U.S. states have the right to know whether we are processing your Personal Information, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide you:

• The categories of Personal Information we collect about you.
• The categories of sources from which your Personal Information is collected.
• The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your Personal Information, and the categories of Personal Information disclosed for such purpose(s).
• The categories of third parties with whom we share your Personal Information.
• The categories of Personal Information we have sold, if any, about you and the categories of third parties to whom your Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was sold.
• The specific pieces of Personal Information we have collected about you.

In addition, you may have the right to request we delete your Personal Information.

Request for Correction. Residents of certain U.S. states have the right to request the correction or rectification of inaccurate information in the resident’s Personal Information. 

Request for Portable Data. Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their Personal Information that allows the data to be transmitted to another entity.

Opting Out of Cookies and Sale/Sharing Using Online Tracking Technologies. Our use of online tracking technologies may be considered a “sale” / “sharing” under applicable law. Residents of certain U.S. states may have the right to opt out of being tracked by these third parties. If you wish to opt out of our use of online tracking technologies, please use our cookie banner to indicate your preferences.

Do Not Sell or Share My Personal Information. Residents of certain U.S. states have the right to opt out of the sale or sharing of the consumer’s Personal Information. We do not sell your Personal Information, but we may use your Personal Information to provide personalized or targeted advertising. If you wish to opt out of this sharing, please contact us at the contact information below or submit a request online.

Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive Personal Information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive Personal Information for any purpose other than providing our goods or services to you, or as otherwise minimally permitted under applicable law.

Right to Equal Service & Price. You have the right to receive equal service and price, even if you exercise a privacy right.

Automated Processing & Profiling. Residents of certain U.S. states have the right to opt out of the processing of Personal Information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Verification Process for Exercising Rights. To protect our consumers’ privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your Personal Information. As part of our verification process, we may request you to submit additional information.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information at the bottom of this Privacy Policy and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Appeal Process. If we do not decide to act in response to your request to exercise a right, we may provide a timely response detailing the reasons for not taking the action and, depending on your jurisdiction, any rights that you may have to appeal our decision.

B. Privacy Rights & Additional Disclosures for EEA, UK, and Swiss Individuals

Privacy Rights. If you are from the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have the right, under certain circumstances, to:

• Access your Personal Information;
• Correct inaccurate Personal Information;
• Request erasure of your Personal Information without undue delay;
• Request the restricted processing of your Personal Information;
• Request portability of the Personal Information that you have given us; and
• To object to the processing of your Personal Information, including the ability to object to automated processing and/or profiling.

Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information at the bottom of this Privacy Policy.

International Transfers. Any data that you provide to us may be accessed, shared or processed by our offices, located in the United States, and service providers located in the United States and abroad, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract). This may entail a transfer of your Personal Information across international borders, including, but not limited to, transfers from within the EEA to the United States. The data protections standards may differ and be lower than the standards enforced in your jurisdiction.

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5. Children's Privacy

This Website is not directed at individuals under the age of 16. We do not knowingly collect Personal Information from children under 16. If you become aware that a child has provided us with Personal Information, please contact us at the Contact Information below. If we become aware that a child under 16 has provided us with Personal Information, we will take steps to delete such information.

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6. Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

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7. Cookies

To make our Website and Services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve the Website. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

You may wish to restrict the use of cookies. Please be aware that some of the features of our Website may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

• Cookie settings in Chrome
• Cookie settings in Firefox
• Cookie settings in Microsoft Edge
• Cookie settings in Safari web and iOS

Personalized Advertising. We may also use targeted advertising cookies, such as Google Ads, to deliver tailored advertising on our Website and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

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8. Change of Control

Personal Information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your Personal Information.

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9. Data Retention and Security

We implement a variety of security measures to maintain the safety of your Personal Information when you enter, submit, or access your personal information. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be appropriate technical and organizational measures to protect the confidentiality, security, and integrity of Personal Information obtained through the Website, we cannot ensure or warrant the security of any information you transmit to us.

We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of Services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law, and the statute of limitations.

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10. Policy Changes

We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the date located at the top. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Website. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you.

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11. Contact Information

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please contact us by postal mail or email at:

GoVyrl, Inc.
Attn. Privacy Officer
privacy@getcarro.com

8605 Santa Monica Blvd #379929 

West Hollywood, CA 90069-4109

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