This Privacy Policy ("Policy") describes the manner in which Aston Ventures Inc., a Delaware corporation, doing business as BoRo USA ("BoRo," "Company," "we," "us," or "our"), collects, uses, discloses, retains, and otherwise processes Personal Data in connection with the operation of BoRo's mobile applications, websites, and related services (collectively, the "Services"). This Policy forms part of, and is incorporated by reference into, BoRo's Terms of Service. Capitalized terms not otherwise defined herein have the meanings assigned to them in the Terms of Service.
1Scope; Role of the Company
For purposes of applicable data protection laws, BoRo acts as a data controller (or equivalent role) with respect to Personal Data processed in connection with the Services, except where BoRo acts as a processor on behalf of another party pursuant to a written agreement. This Policy applies solely to Personal Data processed by BoRo in its capacity as a controller and does not apply to: (a) third-party websites, applications, or services accessible through the Services; (b) independent third-party payment processors, identity verification providers, or analytics providers acting as separate controllers; or (c) offline activities unrelated to the Services.
2Jurisdictional Applicability
This Policy is intended to address obligations arising under applicable privacy and data protection laws, including, without limitation: (a) United States federal and state privacy laws (including the CCPA/CPRA); (b) the Children's Online Privacy Protection Act ("COPPA"); (c) the General Data Protection Regulation (EU) 2016/679 ("GDPR"); and (d) the UK General Data Protection Regulation ("UK GDPR"). Nothing in this Policy shall be construed to create rights or obligations beyond those mandated by applicable law.
3Eligibility; Children's Data
3.1 Children Under 13
The Services are not directed to children under the age of 13. BoRo does not knowingly collect Personal Data from children under 13. If such data is identified, it will be deleted in accordance with applicable law.
3.2 Minors Aged 13–17
Users between the ages of 13 and 17 may access the Services only with verifiable parental or legal guardian consent, in compliance with COPPA and applicable state law. The parent or legal guardian is the contracting party; the parent or legal guardian is financially responsible; Personal Data of minors is not sold or shared; and targeted advertising to minors is prohibited.
4Categories of Personal Data Processed
Subject to applicable law, BoRo may process the following categories of Personal Data:
- Identifiers and Contact Information. Including name, email address, telephone number (including mobile telephone number), and account credentials.
- Account and Profile Information. Including optional profile images, preferences, and account settings.
- Transactional and Commercial Information. Including listings, pricing, availability, rental lifecycle events, transaction metadata, and dispute records.
- Media and Evidence. Including photos and videos uploaded for listing, verification, inspection, or dispute resolution purposes.
- Payment-Related Metadata. Processed by third-party payment processors. BoRo does not store full payment card numbers or CVV data.
- Identity Verification Information. Processed by third-party verification providers, including government-issued identification images and verification outcomes. BoRo does not retain biometric templates.
- Geolocation Data. Collected on a permission-based basis solely for safety, verification, and enforcement purposes.
- Device, Network, and Technical Data. Including IP address, device identifiers, operating system, application version, logs, and diagnostics.
- Usage and Interaction Data. Including timestamps, feature usage, audit logs, and engagement metrics.
- Communications Data. Including in-app messages, SMS/text messages, attachments, timestamps, and delivery indicators.
5Purposes of Processing
BoRo processes Personal Data for purposes including, without limitation: providing and operating the Services; verifying identity, eligibility, and parental consent; processing transactions and authorization holds; delivering text messages and account communications you have consented to receive; enforcing marketplace and rental lifecycle rules; detecting, preventing, and investigating fraud or abuse; resolving disputes, claims, and safety incidents; providing customer support; improving, securing, and maintaining the Services; and complying with legal and regulatory obligations.
6Automated Processing
BoRo may utilize automated systems, including algorithms, in connection with search ranking, recommendations, pricing guidance, and trust and safety assessments. Where required by applicable law, individuals may request human review of automated decisions producing legal or similarly significant effects.
7Legal Bases for Processing (EEA/UK)
Where GDPR or UK GDPR applies, BoRo processes Personal Data on one or more of the following legal bases: performance of a contract; legitimate interests; consent; and compliance with legal obligations.
8Disclosure of Personal Data
BoRo discloses Personal Data only as necessary and proportionate to: payment processors; identity verification providers; cloud infrastructure and hosting providers; analytics and messaging providers (including BoRo's A2P text-messaging platform vendor); insurance, claims, and risk partners; and professional advisors and customer support vendors. All such disclosures are subject to contractual confidentiality and data protection obligations.
BoRo does not sell Personal Data and does not engage in cross-context behavioral advertising. BoRo does not sell, rent, or share mobile telephone numbers or SMS consent with third parties or affiliates for their own marketing or promotional purposes. Mobile opt-in information is shared only with BoRo's messaging service providers strictly as necessary to operate the Messaging Program described in Section 16.
9International Transfers
Personal Data may be transferred to, and processed in, the United States and other jurisdictions. Where required, such transfers are conducted pursuant to Standard Contractual Clauses or other lawful transfer mechanisms. BoRo will designate an EU or UK representative or Data Protection Officer if and when required by applicable law.
10Data Retention
Personal Data is retained only for so long as reasonably necessary to fulfill the purposes described herein, including compliance with legal, accounting, and risk management obligations, unless a longer retention period is required or permitted by law.
11Individual Rights
Subject to applicable law and verification requirements, individuals may exercise rights relating to their Personal Data, including rights of access, correction, deletion, portability, objection, and restriction. BoRo may deny or limit requests where permitted by law.
12Security
BoRo maintains administrative, technical, and organizational measures designed to protect Personal Data. However, no system can be guaranteed to be completely secure, and BoRo disclaims any such guarantee to the maximum extent permitted by law.
13Incentives
BoRo may offer referral credits or promotional incentives, including through the BoRo Eko referral program. Participation is voluntary, and the value of any incentive is reasonably related to the associated benefit.
14Cookies and Tracking Technologies
BoRo and its service providers may use cookies, software development kits, pixels, and similar technologies to operate, secure, and analyze the Services. You may control certain tracking technologies through your browser or device settings. Where required by applicable law, BoRo will obtain consent before deploying non-essential tracking technologies.
15Modifications
BoRo may modify this Policy from time to time. BoRo will post the updated Policy with a revised effective date and, where required by law, provide additional notice. Continued use of the Services following any update constitutes acceptance of the revised Policy.
16SMS / Text Messaging Program Privacy
16.1 Mobile Information Collection and Use
If you provide your mobile telephone number and consent to receive text messages, BoRo collects and processes your mobile number and messaging consent solely to operate its application-to-person ("A2P") text messaging program (the "Messaging Program"), which may include one-time verification codes, account and transaction notifications, rental confirmations and reminders, referral program updates, customer-care communications, and periodic promotional messages.
16.2 No Sale or Sharing of Mobile Information for Third-Party Marketing
BoRo does not sell, rent, or share mobile telephone numbers, text-messaging opt-in data, or SMS consent with third parties or affiliates for their own marketing or promotional purposes. No mobile information obtained through the SMS opt-in process is shared with third parties or affiliates for marketing purposes. Mobile information is shared only with BoRo's messaging service providers (including its A2P messaging platform vendor) strictly as necessary to transmit messages you have consented to receive, and as otherwise required to comply with applicable law.
16.3 Message Frequency
Message frequency varies and depends on your activity on the Services, including the number and status of your rental transactions. BoRo does not guarantee any particular number of messages.
16.4 Message and Data Rates
Message and data rates may apply to each message sent or received in connection with the Messaging Program, in accordance with the rate plan you maintain with your wireless carrier. You are solely responsible for all such charges.
16.5 Opt-Out and Help
You may opt out of the Messaging Program at any time by replying STOP to any text message you receive from BoRo, after which BoRo will cease sending promotional and non-essential messages to that number. You may request assistance by replying HELP or by contacting BoRo at support@borousa.com. BoRo may continue to send transactional, security, or account-related messages to the extent necessary to complete pending rental transactions, protect account security, or comply with applicable law. Your use of the Messaging Program is also governed by Section 14A of the Terms of Service.
17Contact Information
Privacy Inquiries: privacy@borousa.com
Security Issues: security@borousa.com
Mailing Address:
Aston Ventures Inc., a Delaware Corporation, d/b/a BoRo USA
8 The Green, Ste. 23301, Dover, DE 19901
© 2026 Aston Ventures Inc., a Delaware Corporation d/b/a BoRo USA. All Rights Reserved.