Privacy Policy

At Boomerang Eats, your privacy is important to us. In this Privacy Policy, we tell you what
information we collect, share with others, and how we use it.

Scope of this Privacy Policy

Boomerang Eats (“Boomerang Eats,” “we,” “our,” and/or “us”) values the privacy of individuals who
use our website and mobile apps (collectively, our “Platform”). This privacy policy (the “Privacy
Policy”) explains how we collect, use, and share information from Boomerang Eats’ users (“Users”). It
applies to our customers (“Customers”), individuals who deliver products requested by Customers
through our Platform (“Couriers”), anyone who signs up to become a Courier (“Prospective
Couriers”), businesses selling products through our Platform (“Merchants”), and other partners
and/or end users who use our Platform to facilitate delivery and/or sale of products (“Partners”). By
using the Platform, you agree to the Privacy Policy and any future amendments and additions. Your
use of our Platform is also subject to our Terms of Use.

1. Information Boomerang Eats Collects From Users

Boomerang Eats collects information from its Users. The categories of information we collect are
described below in this Section 1.

A. Information You Provide Directly to Us

Customers

Sign Up and Profile Information. When you sign up and/or place an order through Boomerang Eats
as a Customer, you provide us with information, including, but not limited to your name, email
address, physical address, and phone number. If you sign up using your Facebook account, we
receive information including your name and email address. After registration, Customers can add
multiple delivery addresses to their profile. You may be required to provide us with a photograph.
Order Information. When you place an order, we collect information related to the order, which may
include items purchased, special instructions, date and time of order, and subtotal.
Feedback. We may ask you for feedback on your order, which may include rating of experience, the
applicable Merchant, and/or the applicable Courier.
Surveys. We may offer an opportunity to participate in surveys, promotions, or contests. When a
User participates, we may request certain information which may include name and email address.
Payment Information. When you add a payment card to your Boomerang Eats account, a third-party
payments service provider receives your card information. We do not store full payment card
information on our servers.

Active and Prospective Couriers

Sign Up and Profile Information. When you sign up to become a Courier, you may provide us with
certain information, including, but not limited to your legal name, date of birth, email address,
physical address, phone number, photo, vehicle information, and car insurance information. We
share this information with third-party providers who initiate background check reports on you.
Additional information about the third parties who run the background checks is provided in Section
C below. We may also collect information from you after sign up as is necessary to effectively
operate the Platform.
Surveys. We may offer an opportunity to participate in surveys, promotions, or contests. When a
User participates, we may request certain information which may include name and email address.
Payment Information. We receive information from Couriers to provide payment and for tax reporting
purposes, including but not limited to bank account and tax information.

Merchants and Partners

Profile Information. A Merchant who signs up for our Platform or a Partner who utilizes our Platform
provides us with certain information, including, but not limited to contact name, phone number, email
address, physical address, hours, and product information, including product details and price.
Payment Information. We may receive Merchants’ bank account information to provide payment as
well as any other information necessary to set up payment.

All Users

Communications. If you contact us directly, we may collect additional information about you. For
example, when you contact our Customer Support team, or text with us and our Couriers, we will
receive and may retain your name, email address, and the contents of any message or attachments
that you may send to us, as well as any other information you choose to provide.
Feedback. Customers and Couriers may be able to rate and review each other at the end of every
delivery. Customers may be able to see a Courier’s aggregate ratings during a delivery. After a
delivery, we may share feedback or comments that Customers provide with Couriers and/or
Merchants, but we will not identify the Customer. If you are a Customer and do not want a Courier to
know you provided certain feedback or comments, please do not include identifying information in
that feedback or those comments. We may also share with Couriers their aggregate ratings.
Customers may also provide us information and feedback related to your experience on the Platform,
including, but not limited to order reviews, merchant reviews and merchant ratings.

B. Information We Collect Automatically Through Your Use of the Platform

Location and Sensor Information. We receive a Customer’s location information when you’re using
the Boomerang Eats app, including when the app is in use in the foreground or background. We may
continuously collect location information and other motion-generated or orientation-generated mobile
sensor data from Couriers and Prospective Couriers when the Boomerang Eats app is in use in the
foreground or background in order to personalize the app experience, assist in finding available
markets and/or available delivery opportunities, offer delivery incentives, track the progress and
completion of deliveries, and other similar purposes. We also use this information for analytics
purposes. For information on your choices for sharing location information, please consult Section 6
on Your Choices.

Device Information. We receive information from Users’ devices, including IP address, web browser
type, mobile operating system version, phone carrier and manufacturer, unique device identifiers,
other information such as your device type and, if you register with your Facebook account, your
Facebook identifier.

Usage Information. We automatically receive information about your interactions with our Platform,
such as the pages you were visiting before accessing the Site or mobile application, or other content
you view, the products you search for or purchase, and the dates and times of your visits, to help us
understand how you use our Platform, help us improve our Platform, and provide you information
about our Platform, Merchants, and Partners.

Call and Text Information. We work with one or more third parties to facilitate phone calls and text
messages between Customers and Couriers who are delivering the Customers’ products. We
receive information about these communications including the date and time of the call or text
message, the parties’ phone numbers, and the content of the text messages. By using Boomerang
Eats services, including communicating with Boomerang Eats and your courier, you consent to the
receipt, recording, and monitoring by Boomerang Eats of text messages between you and Couriers
for quality assurance, customer service, security and fraud prevention. We do not record or have
access to the content of the phone calls between Customers and Couriers. We do record and/or
have access to the content of phone calls between Users and Boomerang Eats.

Information from Cookies and Similar Technologies. We and our service providers collect information
through the use of “cookies” and similar technologies to understand how you navigate through and
interact with our Platform, to learn what content is popular, for authentication and advertising
purposes, and to save your preferences. Cookies are small text files that web servers place on your
device; they are designed to store basic information and to help websites and apps recognize your
browser. We may use both session cookies and persistent cookies. A session cookie disappears
after you close your browser. A persistent cookie remains after you close your browser and may be
accessed every time you use our Platform. We also use cookies for data analytics purposes,
including from Google Analytics. You can find more information on how Google uses data from these
cookies at google.com/policies/privacy/partners. To prevent Google Analytics from using your
information for analytics, you may install the Google Analytics Opt-Out Browser Add-on. You should
consult your web browser to modify your cookie settings. Please note that if you delete or choose not
to accept cookies from us, you may be missing out on certain features of our Platform

Referrals. You may be able to refer Boomerang Eats to friends and other contacts. To help you do
this, we may request and you can grant us access to your mobile device address book. You can then
direct us to send referral text messages or referral emails to contacts you select in your address
book. We will use the data from your address book only to process your referral. By sending a
referral, you also consent to Boomerang Eats sending your public profile image to the contacts you
select to receive a referral link. By choosing to invite a friend you represent that you have received
the friend’s consent to provide his or her name and email address with Boomerang Eats. Boomerang
Eats will use that information to send an email inviting him or her to visit the Platform and will store
that information to track the success of the referral program. Boomerang Eats may also send
marketing emails.
Boomerang Eats users may not send, publish, or share any false, misleading, or deceptive
communications in connection with participation in the referral program. These actions may violate
various laws. In addition, Boomerang Eats users may not send any referral emails, text messages, or
other communications to children under the age of 13.

C. Personal Information from Publicly-Available Sources and Third Parties

Information We Receive From Partners. If you make a purchase through one of our Partners that
offers delivery with Boomerang Eats, we receive information about your purchase, including your
name, phone number, the product you purchased, and the delivery location.
Background Information on Couriers. Boomerang Eats works with third-party providers to perform
driving record and criminal background checks on Prospective Couriers and active Couriers, and in
some instances these third parties provide Prospective Couriers and active Couriers’ records to
Boomerang Eats as part of the background check process.

Information From Affiliates and Non-Affiliated Third Parties. We may collect information about you or
others through Boomerang Eats affiliates or through non-affiliated third parties. For example, you
may be able to access the Platform through a social networking account, such as Facebook. If you
access the Platform through your Facebook account, you may allow us to have access to certain
information in your Facebook profile. This may include your name, profile picture, gender, networks,
and/or email address and other information you allow to be imported from Facebook, which is
controlled in your Facebook privacy settings.

Social networking sites, such as Facebook, have their own policies for handling your information. For
a description of how these sites may use and disclose your information, including any information
you make public, please consult the sites’ privacy policies. We have no control over how any thirdparty site uses or discloses the personal information it collects about you.

We may also collect information about you or others through non-affiliated third parties. For example,
to the extent permitted by law, we may, in our sole discretion, ask for and collect supplemental
information from third parties, such as information about your credit from a credit bureau, or
information to verify your identity or trustworthiness, or for other fraud or safety protection purposes.
We may also collect demographic information, which may include information such as income,
marital status, spending habits, and other information pertaining to customers. We may combine
information that we collect from you through the Platform with information that we obtain from such
affiliated and non-affiliated third parties and information derived from any other products or services
we provide.

2. How We Use The Information We Collect From Users

We use the information collected from and about Users for the following business and commercial
purposes:

A. Provide services and features. Boomerang Eats uses the data we collect to provide, personalize,
improve, expand, and promote our Platform and other services. This includes using data to:

• Facilitate transactions, deliveries, and payments.
• Analyze how you use our Platform.
• Track and share progress of deliveries and orders.
• Notify you about progress of deliveries and orders.

B. Communications. Boomerang Eats uses the data we collect to communicate with you, either
directly or through one of our service providers, including for marketing and promotional purposes,
and to respond to any issues that may arise during deliveries.
Boomerang Eats also uses the data we collect to provide customer support, including but not limited
to responding to customer support questions or your requests, and investigating and addressing
User concerns.

C. Conduct research and development. Boomerang Eats may use the data we collect for testing,
analysis, product development, and machine learning to improve a user’s experience on the
Platform

D. Security and safety. We use the information we collect to help maintain the safety, security, and
integrity of our services, third parties, and Users. This includes using data to:

• Find and prevent fraud.
• Protect Users and the Boomerang Eats business.
• Provide account and network security

E. Maintain legal and regulatory compliance. Boomerang Eats may use the information we collect to
maintain legal and regulatory compliance. This includes using data to:

• Resolve disputes, to enforce any legal terms that govern your use of the Platform.
• Pay our taxes or fulfill our business obligations.
• Respond to requests by regulators, government entities, and official inquiries.

F. Boomerang Eats business purposes. We may aggregate and/or de-identify information collected
through the Platform. We may use de-identified or aggregated data for any purpose, including
without limitation for research and marketing purposes and may also share such data with any third
parties, including without limitation, advertisers, promotional partners, sponsors, event promoters,
and/or others.

3. How Boomerang Eats Shares Information It Collects From Users

A. Sharing between Customers and Couriers
To facilitate delivery of orders, Couriers and Customers may have access to certain information
about each other. When Couriers are offered delivery opportunities, they may be able to see the
Customer’s delivery location. Once a Courier accepts a delivery request from a Customer, the
Customer may see the Courier’s first name and last initial, photo, aggregate rating, real-time location
(which may reveal locations of other Customer to whom a Courier is providing a delivery), and/or
other information to identify the Courier, including, but not limited to the Courier’s license plate, and
color, make, and model of vehicle. Couriers may see the Customer’s first name and last initial, and
the Customer’s delivery address and/or real-time location. Boomerang Eats may allow Customers
and Couriers to call and text each other. Customer and Courier phone numbers are masked and,
only in rare instances, may they be able to see the other’s phone number. As described above,
Customers are able to see a Courier’s aggregate ratings during a delivery. After a delivery, we may
share feedback or comments that a Customer provides with a Courier, but we will not identify the
Customer. If you are a Customer and do not want a Courier to know you provided certain feedback
or comments, please do not include identifying information in that feedback or those comments. We
may also share with Couriers their aggregate ratings.

B. Sharing between Couriers and Merchants
Before a Courier picks up the delivery from the Merchant and/or Partner and during the delivery, the
Merchant and/or Partners may be able to see the Courier’s name, real-time location, and may be
able to communicate directly with the Courier.

C. Sharing between Customers and Merchants
We may share certain transactional details with Merchants from whom you’ve placed orders, such as
your name, phone number, email address, and/or any physical address associated with your account
or any delivery, with the Merchants from whom you’ve placed orders. Merchants may also have
access to your public profile image, your feedback, and/or order information, including your purchase
history and other information related to your orders with the particular Merchant. Such information
provided to Merchants is not subject to this Privacy Policy, but instead is subject to Merchant’s own
privacy policies which may allow Merchant to, among other things, send you marketing
communications and other promotional content.

D. Service Providers
We share your information with service providers that perform services on our behalf, including all of
the uses described in this Section 3. Some examples of service providers are third parties we use for
payment processing, advertising, marketing, and analytics.

E. Other Sharing
We may share your information with third parties in the following cases:

• Where disclosure is required or appropriate in order to comply with laws, regulations, legal
  process, or an agency or governmental request;
• With law enforcement officials, government authorities, or third parties, if we think doing so is
  necessary to protect the rights, property, or safety of Boomerang Eats, our Users, or the public;
• To protect the security or integrity of our Platform;
• To enforce our agreements, policies, and Terms of Use
• To respond to an emergency which we believe in good faith requires us to disclose information
  to assist in preventing the death or serious bodily injury of any person;
• To investigate and defend ourselves or others against any third-party claims or allegations;
• To provide information about the use of our Platform to Couriers, Merchants, Partners, or
  potential business partners in aggregated or de-identified form that cannot reasonably be used
  to identify you;
• While negotiating or in relation to a business transaction, such as a merger, sale of assets, or
  bankruptcy;
• Whenever you consent to the sharing, including without limitation when you use the social
  features of the Platform to (1) review, rate, and/or provide feedback on Merchants which will be
  available for viewing by other Users; (2) share the orders you’ve placed through the Platform
  with other Users, including, but not limited to designated favorite orders; and/or (3) share your
  favorite items/Merchants or lists of items/Merchants with other Users; and
• When you share certain information related to orders with other Users or non-Users, including,
  but not limited to (a) your cart; (b) the fees associated with your Order (e.g. to split payment with
  others); (c) the estimated time of delivery and progress of your Order; and/or (d) order
  destination.

4. Online Analytics & Interest-Based Advertising
We or third parties may place cookies, web beacons, or other tracking technologies on your
computer, mobile phone, or other device to collect information about your use of the Platform.
Cookies are small bits of data we store on the device (computer, mobile phone, tablet or any other
mobile device) that you use to access the Platform. We use cookies and other tracking technologies
to (a) inform, optimize, and serve marketing content based on past visits to our websites and other
sites, (b) report how our marketing content impressions, other uses of marketing services, and
interactions with these marketing impressions and marketing services are related to visits to our
websites, (c) help us understand how the Platform is being used, (d) let you navigate between pages
efficiently, (d) remember your preferences, and (e) generally improve your browsing experience. We
also allow other third parties (e.g., ad networks and ad servers such as Google Analytics) to serve
tailored marketing to you and to access their own cookies or other tracking technologies on your
computer, mobile phone, or other device you use to access the Platform. We neither have access to,
nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be
placed on your computer, mobile phone, or other device you use to access the Platform by nonaffiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties.
Those parties that use these technologies may offer you a way to opt out of targeted advertising as
described below. You may receive tailored advertising on your computer through a web browser.
Cookies may be associated with de-identified data linked to or derived from data you voluntarily have
submitted to us (e.g., your email address) that we may share with a service provider in hashed, nonhuman-readable form.

We and our third-party vendors may use Device IDs and other automated technologies (including
cookie identifiers on our website), along with other collected information, to deliver content or tailor
ads when you are on our Platform or on other devices, apps or websites. These ads may be based,
for instance, on the types of websites that you visit over time, the types of apps you have on your
device, or de-identified information about you and your likely interests, based on your activities off of
our Platform. This type of advertising is often called “interest-based” or “personalized” advertising—
and when it occurs on mobile apps, “cross-app” advertising.

Partners that we or others work with to do the above may track your activities over time (including
across different apps or websites) by collecting information through automated means, and they may
use this information, and other information they receive from us or other sources, to deliver
advertisements to you. If you are interested in more information about tailored browser advertising
and how you can generally control cookies from being put on your computer to deliver tailored
marketing, you may visit the Network Advertising Initiative’s Consumer Opt-Out Link and/or
the Digital Advertising Alliance’s Consumer Opt-Out Link to opt-out of receiving tailored advertising
from companies that participate in those programs. To opt out of Google Analytics for Display
Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page.
You can also opt out of cross-app advertising by following in the instructions for your operating
system, (iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices).
Please note that to the extent advertising technology is integrated into the Platform, you may still
receive advertising content even if you opt out of tailored advertising. In that case, the advertising
content will just not be tailored to your interests. Also, we do not control any of the above opt-out
links and are not responsible for any choices you make using these mechanisms or the continued
availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when
you visit this opt-out page, or you subsequently erase your cookies, use a different computer or
change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is
available on NAI’s and DAA’s websites, accessible by the above links.

5. Your Choices
In addition to other choices described in this Privacy Policy and in the Platform, you have other
choices regarding your information:

Profile Information. You can update your profile information through your profile settings. If you need
to change the email address associated with your account, please contact us via the appropriate
email address on the website and the app

Location Information. While you can prevent your device from sharing location information at any
time through your device’s operating system settings, Customer and Courier location is core to our
Platform and without it, you may not be able to successfully use our Platform.

Email Subscriptions. You can always unsubscribe from our promotional emails via the link provided
in the emails. Even if you opt out from receiving promotional messages from us, you will continue to
receive administrative messages from us.

Account Deletion. If you would like to delete your Boomerang Eats account, please contact us
through the appropriate email address on the website and the app with your request. If you choose to
delete your account, we will delete it for you, but may retain certain information to collect any fees
owed, resolve disputes, troubleshoot problems, analyze usage of the Platform, assist with any
investigations, prevent fraud, enforce our Terms of Use, or take other actions as required or
permitted by law and/or regulations

6. Third-Party Links
Our Platform may contain links to other websites, products, or services that we do not have control
over. Please be aware that we are not responsible for the privacy practices of such third parties. We
encourage you to read their privacy policies before giving them your information.

7. Data Security
We are committed to protecting your information. We use administrative, logical, physical and
managerial measures to safeguard your personal information against loss, theft and unauthorized
access, use and modification. Unfortunately, no security measures can be 100% secure, so we
cannot guarantee the security of Users’ data. While we do our best to protect your information, you
are also responsible for protecting your information by, for example, protecting your account
credentials. If you have any reason to believe that your account has been compromised, please
notify us immediately through our Help Center

8. Children’s Privacy
Boomerang Eats is not directed to children, and we do not knowingly collect personal information
from children under 13. If you believe that a child under the age of 13 has given us personal
information, please contact us via the appropriate email address on the website and the app .

9. Consent to Transfer
Our computer systems are currently based in the United States, so your personal data will be
processed by us in the United States, however, we may move the location of our systems where data
protection and privacy regulations may not offer the same level of protection as in other parts of the
world. If you create an account with the Platform as a visitor from outside the United States, by using
the Platform, you agree to this Privacy Policy and you consent to the transfer of all such information
to the United States, which may not offer a level of protection equivalent to that required in certain
other countries, and to the processing of that information as described in this Privacy Policy

10. Privacy Information for California Residents
Under the California Consumer Privacy Act or CCPA, and subject to exceptions, California residents
have certain rights regarding their data, including:

• The right to know the categories of Personal Information we’ve collected and the categories of
  sources from which we got the information (see Section 1 and the chart below).
• The right to know the business purposes for sharing Personal Information (see Section 2 and
  the chart below).
• The right to know the categories of third parties with whom we’ve shared Personal Information
  (see Section 3 and the chart below).
• The right to access the specific pieces of Personal Information we’ve collected and the right to
  delete your information.
• The right to opt out of having your Personal Information sold. Boomerang Eats does not sell or
  rent Personal Information to third parties, as we understand that term to be defined by the CCPA
  and its implementing regulations.

Categories of Personal Information under the California Consumer Privacy Act
Personal Information
Source of Personal Information
Purpose of Collecting Personal Information
To Whom We Disclose Personal Information

Identifiers such as a name, address, unique personal identifier, email, phone number.
Information you provide to us; Information we collect automatically; Information collected from third
parties.

See Sections 2 A, B, C, D, E, F above.
See Sections 3 A, B, C, D, E above.

Protected Classifications under California and federal law, including gender, age and citizenship.
Information you provide to us; Information we collect automatically; Information collected from third
parties.

See Sections 2 A, B C, E above.
See Sections 3 A, B, C, D, E above.

Commercial information such as records of products or services purchased, obtained, or considered.
Information you provide to us; Information we collect automatically; Information collected from third
parties.

See Sections 2 A, B, C, D, E, F above.
See Sections 3 A, B, C, D, E above.

Internet or other electronic network activity information, including browsing history and search history.
Information you provide to us; Information we collect automatically; Information collected from third
parties.

See Sections 2 A, B, C, D, E, F above.
See Sections 3 D, E above.

Geolocation data that is sufficient to identify a precise physical location.
Information you provide to us; Information we collect automatically; Information collected from third
parties.

See Sections 2 A, B, C, D, E, F above.
See Sections 3 A, B, D, E above.

Sensory data, such as audio, electronic, visual, or other similar information.
Information you provide to us; Information we collect automatically; Information collected from third
parties.

See Sections 2 A, B, C, E above.
See Sections 3 D, E above.

Professional or employment-related information.
Information you provide to us; Information we collect automatically; Information collected from third
parties.

See Sections 2 A, B, C above.
See Sections 3 C, D, E above.

Education information.
Information you provide to us; Information we collect automatically; Information collected from third
parties.

See Sections 2 A, B, C above.
See Sections 3 C, D, E above.

Inferences about preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes.
Information you provide to us; Information we collect automatically; Information collected from third
parties.

See Sections 2 A, B, C, F above.
See Sections 3 C, D, E above.

California residents also have the right to not be discriminated against if they choose to exercise their
privacy rights.

As a California resident, you may exercise your right to know or your right to deletion emailing us at
the appropriate email address on the website and the app. Specifically, a California resident should
email us with the subject line “California Consumer Privacy Act Request”. We do not currently have a
reasonable method of verifying the identity of non-registered users to a reasonable degree of
certainty, as we do not maintain enough personal information to enable us to verify non-registered
users with sufficient certainty. Thus, we cannot honor the access or deletion requests of nonregistered users at this time.

Do-Not-Track Disclosure: We are committed to providing you with meaningful choices about the
information collected on our Platform for third party purposes. That is why we have provided the
ability to email us with your requests

California Law permits California residents to request certain information once per year regarding our
disclosure of “personal information” (as that term is defined under applicable California law) to third
parties for such third parties’ direct marketing purposes. To make such a request, please send written
notice, by certified mail or Federal Express (signature required), noting that you are making a
“California Privacy Request” to the following address:

2205 Church Street, Suite 102
Christiansted VI 00820

11. Nevada Residents
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable
information” for monetary consideration to a person for that person to license or sell such information
to additional persons. “Personally identifiable information” includes first and last name, address,
Boomerang HOME MENU PRIVACY POLICY TERMS AND CONDITIONS
email address, phone number, Social Security Number, or an identifier that allows a specific person
to be contacted either physically or online.

12. Other Important Information
Parts of the Platform may include third-party integrations such as Google Maps features and content,
including the Google Maps API(s). Your use of these services is subject to their respective privacy
policies such as the Google Privacy Policy.

13 Changes to Our Privacy Policy
We may make changes to this Privacy Policy from time to time. If we make any changes, we will
endeavor to revise the “Last Updated” date at the top of this Privacy Policy. If we make any material
changes, we will endeavor to let you know through the Platform, by email, or other communication.
We encourage Users to read this Privacy Policy periodically to stay up-to-date about our privacy
practices. As long as you use the Platform, you are agreeing to this Privacy Policy and any updates
we make to it.

14. Contact Information
Feel free to contact us at any time with any questions or comments about this Privacy Policy, your
personal information, our use and sharing practices, or your choices regarding your information by
contacting us at the appropriate email address on the website and the app