Driver Privacy Notice

As referenced in connection with your Motor Carrier's use of the Secrul Services, this Driver Privacy Notice describes how SECRUL ("Secrul," "we," "us") collects and processes your personal information in connection with shipments that are booked, verified, or tracked through the Secrul platform and applications (the "Services").

In this Notice, "your Carrier" means the motor carrier or other company that employs or otherwise engages you to perform shipments. Secrul provides technology to shippers, freight brokers, and carriers; we are not your employer, and this Notice does not create an employment relationship.

1. WHAT PERSONAL INFORMATION DOES SECRUL COLLECT?

• Identity information: your name, phone number, and email; your driver's license or other photo ID submitted by you or your Carrier; and your photograph.
• Facial verification information: with your consent, a scan of your face geometry derived from your photograph, your photo ID, or a check-in photo, used to confirm that the driver at pickup is you (see Section 4).
• Check-in and shipment events: QR-code check-in scans at pickup and drop-off (with time and place), shipment progress events, and shipment documents such as bills of lading and proof-of-delivery photos.
• Location data: precise geolocation of the device running the Secrul application — or of telematics sources your Carrier connects — during active shipments, including coordinates, timestamps, speed, route progress, and geofence events.
• Usage and device information: app interactions, errors and event failures, and security and access logs.
• Information from your Carrier and shipment counterparties: dispatch assignments, eligibility and compliance documents your Carrier provides, and check-in confirmations or incident reports from shippers, brokers, and facilities.

2. FOR WHAT PURPOSES DOES SECRUL USE MY INFORMATION?

• to verify your identity and your eligibility to perform a shipment, and to confirm that the correct carrier, driver, and equipment arrive at pickup;
• to detect and prevent fraud, cargo theft, identity spoofing, and unauthorized re-brokering;
• to provide live tracking, status, and proof of pickup and delivery to your Carrier and to the shipper or broker on the load;
• to support your safety and the safety of others;
• to provide support, and to maintain and improve the Services;
• to comply with legal obligations and to enforce agreements, including supporting insurance claims or dispute resolution.

3. LOCATION DATA — WHEN AND HOW

Location is collected only in connection with active shipments: from shipment start or check-in until delivery confirmation or trip end. The application indicates when tracking is active. We do not track your location outside active shipments. You can manage location permissions in your device settings; disabling them may prevent you from performing shipments that require verified tracking. Where your Carrier connects its own telematics systems, your Carrier's policies also govern that data.

4. PHOTOS AND FACIAL VERIFICATION — USE AND RETENTION

Secrul may ask you to provide a photograph and may derive a scan of your face geometry or similar identifiers ("Facial Verification Information") from your photograph, your photo ID, or a photo taken at check-in, for identification purposes — including to confirm that it is you performing the shipment, that your credentials are not misused, and to identify and address fraud, theft, and other incidents.

• Consent: before we collect Facial Verification Information, we will tell you in writing that it is being collected, the specific purpose, and how long it will be kept, and we will obtain your written consent, which you may sign electronically in the application. If you do not consent, we will not collect Facial Verification Information; you may be unable to perform shipments that require facial verification, and alternative verification may be available at the discretion of the requesting party.
• Not used for app sign-in, advertising, or marketing: facial verification is used solely to verify your identity in connection with shipments. It is not used to sign in to your Secrul account (app sign-in uses your credentials and, optionally, the Face ID or Touch ID feature built into your device), and it is never used for advertising or marketing.
• Retention and destruction: Facial Verification Information is deleted within 30 days after it is generated for identification purposes, unless a specific fraud or theft investigation or a legal obligation requires a longer period, in which case it is deleted promptly once that purpose is satisfied — and in any event no later than 24 months after your last interaction with the Services. Photographs are retained while you use the Services and thereafter as permitted by law. This Notice serves as our public written policy on the retention and destruction of biometric identifiers, and it incorporates our security-incident response protocol: if a security incident affects Facial Verification Information, we will investigate and contain it and notify affected drivers and regulators as applicable law requires.
• No sale; limited disclosure: we do not sell, lease, or trade Facial Verification Information. Verification is performed by Secrul — directly or through service providers acting on our behalf under contract, who may use Facial Verification Information only to perform services for us, may not use it for their own purposes (including training their systems), and must protect and delete it as described in this Notice. Beyond that, we disclose Facial Verification Information only with your consent or as required by law. We store and transmit it using the reasonable standard of care within our industry and in a manner that is the same as or more protective than the manner in which we store our other confidential and sensitive information.

5. DOES SECRUL SHARE MY INFORMATION?

• Your Carrier: shipment status and location during its loads, check-in confirmations, verification outcomes, and incidents, which your Carrier may use for its operations, safety programs, and compliance.
• Shipment counterparties: the shipper, broker, or receiving facility on a load may see your first name, photograph, equipment details, and live location and status for that shipment, to verify pickup and monitor delivery.
• Service providers: hosting, database, and other service providers that process information on our behalf under contract and may not use it for their own purposes.
• Legal and protection: when we believe disclosure is appropriate to comply with the law, enforce agreements, or protect the rights, property, or safety of Secrul, our users, you, or others (for example, insurance claims or law-enforcement requests).
• Business transfers: in a merger, acquisition, or sale of assets, subject to the promises of the pre-existing notice.
• Upon your request or with your authorization.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

6. HOW SECURE IS MY INFORMATION?

We protect personal information in transit with encryption and maintain physical, electronic, and procedural safeguards for its storage and disclosure. Access to driver data is limited to personnel and providers who need it for the purposes above. Protect your own login and device access, and sign out of shared devices.

7. HOW LONG DOES SECRUL KEEP MY INFORMATION?

We keep personal information for as long as needed for the purposes described in this Notice — including shipment records needed for disputes, claims, tax, and accounting — or as required or permitted by law. Facial Verification Information is retained only as described in Section 4. Location history is retained as part of the shipment record.

8. WHAT RIGHTS AND CHOICES DO I HAVE?

To the extent provided by applicable law, you may request access to, correction of, a portable copy of, or deletion of your personal information by contacting hello@secrul.com (or through your Carrier). If you have a Secrul account, you can also delete your account and associated personal data directly in the Secrul app (Settings > Account > Delete Account). We may ask you to verify your identity, and we respond within the timeframe required by law. Where you have provided consent, you may revoke it; revoking consent may affect your ability to perform shipments that require verification. We will not discriminate against you for exercising your rights.

9. ADDITIONAL STATE-SPECIFIC DISCLOSURES (CALIFORNIA)

The categories of personal information we collect in connection with the Services — and will have collected in the preceding 12 months once the Services are in operation — are: identifiers (name, contact details, government-issued ID); professional information (eligibility and compliance information related to shipments); internet or other electronic network activity (app usage); precise geolocation (during active shipments); biometric information (Facial Verification Information, with consent); visual information (photographs, document photos); and audio information if you call support. We disclose these categories for business purposes to the parties described in Section 5. We do not sell or share personal information as defined by the CCPA, and we do not use or disclose sensitive personal information for purposes other than those the CCPA expressly permits. To the extent provided by applicable law, you may exercise rights to know, access, correct, delete, and obtain a copy of your information, and to appeal a denial, via hello@secrul.com; we will not discriminate against you for doing so.

10. CONTACT, NOTICES, AND REVISIONS

If you have questions or concerns about your privacy in connection with the Services, contact hello@secrul.com. This Notice will change as our Services evolve; the "Last Updated" date reflects the current version, and material changes will be communicated through the application or your Carrier before they take effect. We will not materially change our practices to make them less protective of personal information collected in the past without your consent.

SECRUL · 3685 Elkhorn Blvd #1421, North Highlands, CA 95660