Privacy Policy

Last Updated: October 17, 2025

Effective Date: October 17, 2025


Introduction

Welcome to the Driver App (the “App”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application designed for delivery drivers. This App is operated by 11916408 CANADA LIMITED (“we,” “us,” or “our”).

By using the App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use the App.


1. Information We Collect

We collect several types of information from and about users of our App to provide delivery management services to drivers and their employers.

1.1 Personal Information

Account Information: When you create an account or are onboarded as a driver, we collect: - Full name - Email address - Phone number (optional, for emergency contact purposes) - User ID (internal identifier) - Role and permissions assigned by your employer

Authentication Data: - Login credentials (email and password) - Authentication tokens for maintaining your session - Login history and timestamps

1.2 Location Information

Continuous GPS Tracking: We collect precise location information continuously during active deliveries, including: - Latitude and longitude coordinates - Precise GPS location with high accuracy - Speed data - Your travel speed in kilometers per hour or miles per hour - Timestamps - Exact time of each location data point - Tracking frequency - Location data collected every 5-50 seconds depending on battery conservation settings: - High accuracy mode: approximately every 5 seconds - Balanced mode: approximately every 10 seconds - Power save mode: approximately every 50 seconds

Background Location Tracking: Location data is collected continuously during active deliveries even when the App is closed, running in the background, or when your screen is locked. This background tracking continues when you: - Navigate away from the App to use other applications (GPS navigation, messaging, etc.) - Switch to other apps to check delivery details or communicate with dispatchers - Lock your screen or place your device in your pocket - Receive phone calls or text messages - Use navigation apps like Google Maps or Waze for directions

Trip and Halt Data: We also collect information about: - Complete route paths for each delivery - Stop locations where your vehicle halts during deliveries - Duration of halts and stops - Start and end points of delivery routes

1.3 Photos, Videos, and Documents

Camera and Photo Library: We collect photos and videos that you capture or select, including: - Delivery documents - Photos of Bills of Lading, shipping documents, and receipts - Tank readings - Photos of fuel tank gauges and measurements - Vehicle meters - Odometer readings and vehicle dashboard displays - Customer signatures - Signature images captured as proof of delivery - Delivery conditions - Photos documenting the condition of delivery locations - Other documentation - Any other photos or videos you capture related to deliveries

All captured media files are stored locally on your device and uploaded to our servers for business record-keeping.

1.4 Delivery and Business Data

Delivery Information: - Unique delivery identifiers - Delivery dates, scheduled times, and actual completion times - Delivery status (scheduled, in progress, completed, synced) - Odometer readings (start and end values) - Driver notes and comments about deliveries - Special delivery instructions

Customer and Location Data: - Customer names and business names - Delivery addresses (complete street addresses) - Store codes and identifiers - Customer contact information provided for deliveries

Product and Transaction Data: - Product types and specifications (fuel types, variants) - Quantities delivered (gross gallons, net gallons) - Bill of Lading numbers - Tank reading measurements (water content, start/end levels) - Loading and unloading details - Terminal and rack information

Vehicle Information: - Truck and trailer identifiers - Odometer readings - Trip duration and mileage

1.5 Device and Technical Information

Bluetooth and Printer Information: - Bluetooth device names and addresses (only for connected thermal printers) - Printer model and connection status - Print job information

Network and Connectivity: - Network connection status (online/offline) - Internet connectivity state

App Usage and Preferences: - Theme preference (light/dark mode) - Font size settings (small/medium/large) - Biometric authentication settings (enabled/disabled) - Last synchronization timestamps - Feature usage and interaction data

1.6 Biometric Information

If you choose to enable biometric authentication (fingerprint or face recognition) for app access: - Type: Fingerprint scan or facial recognition data - Storage: Biometric data is processed and stored by your device’s operating system, not by our App - Purpose: Optional convenience feature for unlocking the App - Control: You can enable or disable this feature at any time in app settings


2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Delivery Operations and Management

2.2 Business Record-Keeping and Compliance

2.3 Mileage Reimbursement and Payroll

2.4 Account Management and Authentication

2.5 Communication and Support

2.6 App Functionality and User Experience

2.7 Safety and Security

2.8 Analytics and Business Intelligence

Note: We do not use your information for advertising purposes or sell your information to third parties for marketing.


3. Background Location Collection - Important Disclosure

3.1 Why We Collect Location in the Background

This App collects precise location data continuously during active deliveries, even when the App is closed or not in use.

Background location tracking is essential for our App to accurately record complete delivery routes. Delivery drivers frequently switch between multiple applications during their work, including: - GPS navigation apps (Google Maps, Waze) for turn-by-turn directions - Messaging apps to communicate with dispatchers and customers - Phone calls with delivery contacts - Camera apps for capturing delivery documents - Other work-related tools

Without background location tracking, we would miss significant portions of delivery routes, resulting in: - Incomplete mileage records affecting driver reimbursement accuracy - Inability to verify deliveries were completed at correct customer locations - Gaps in route data needed for performance analysis and route optimization - Inadequate documentation for DOT compliance and business requirements - Unreliable proof of delivery for dispute resolution

3.2 When Location Tracking Occurs

Location tracking is only active during scheduled delivery periods, specifically: - From the moment you start an active delivery - Throughout the entire delivery route (typically 4-8 hours per shift) - Until you complete or cancel the delivery

Location tracking is NOT active when: - You are not assigned to any deliveries - You have completed all assigned deliveries for the day - You are off-duty or not working - You have logged out of the App

3.3 How to Control Location Tracking

Stop Location Tracking: - End your active delivery in the App - Complete all assigned deliveries - Log out of the App

Manage Location Permissions: - You can manage location permissions through your device settings (Settings > Apps > Driver App > Permissions) - Note: Denying location permission will prevent the App from functioning properly, as route tracking is a core requirement

3.4 Battery Impact and Conservation

Continuous GPS tracking uses battery power. The App provides three battery conservation modes to help you manage battery usage:

You can select your preferred battery conservation mode in the App settings based on your device’s battery capacity and shift length.


4. Information Sharing and Disclosure

4.1 Within Your Organization

Your information is shared with authorized personnel at your employer/organization, including:

All personnel with access to your data are bound by confidentiality obligations and company policies restricting data use to legitimate business purposes.

4.2 Service Providers and Backend Infrastructure

We share your information with our backend server infrastructure and hosting providers to: - Store and process delivery data, location logs, photos, and business records - Maintain database systems and file storage - Provide server infrastructure and network services - Ensure data backup and disaster recovery

Our service providers are contractually obligated to: - Use your information only for providing services to us - Implement appropriate security measures to protect your data - Not disclose your information to third parties - Comply with applicable data protection laws

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including to:

4.4 Business Transfers

If we are involved in a merger, acquisition, asset sale, bankruptcy, or other business transaction, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice in the App of any change in ownership or uses of your personal information.

We may share your information with third parties when we have your explicit consent to do so.

4.6 What We DO NOT Do

We do not: - Sell your personal information to third parties - Share your data with advertising networks or data brokers - Use third-party analytics services that track you across other apps or websites - Share your location data with anyone other than your employer/organization - Disclose your information for marketing purposes without your consent


5. Data Storage and Security

5.1 Where Your Information is Stored

Local Device Storage: Delivery data, location logs, photos, and app settings are temporarily stored on your mobile device in the App’s private storage area until successfully synced with our servers. This local storage includes: - SQLite database containing deliveries, trip logs, customer information, and settings - Document files (photos and videos) in the App’s document directory - User preferences and settings

Server Storage: Once synced, your data is stored on our secure backend servers with the following security measures: - Industry-standard data center facilities with physical security controls - Network security including firewalls and intrusion detection systems - Access controls limiting data access to authorized personnel only - Regular security assessments and vulnerability testing - Encrypted data transmission (see Section 5.2)

Geographic Location: Our servers are located in United States. By using the App, you consent to the transfer of your information to these locations.

5.2 Security Measures

We implement appropriate technical and organizational security measures to protect your information:

Data Transmission Security: - All data transmitted between your device and our servers uses HTTPS encryption (TLS/SSL) - Encrypted communication channels for all API requests and responses - Secure authentication using bearer tokens

Access Controls: - Role-based access controls limiting who can view or modify data - Multi-factor authentication for administrative access - Regular review and audit of user access permissions - Immediate access revocation when employees leave or change roles

Authentication Security: - Secure password requirements - Password hashing using industry-standard algorithms - Session timeout after periods of inactivity - Optional biometric authentication (fingerprint/face recognition)

Database Security: - Database access restricted to authorized application servers - Database activity logging and monitoring - Regular database backups with secure storage - Data integrity checks and validation

Application Security: - Input validation to prevent injection attacks - Protection against common vulnerabilities (OWASP Mobile Top 10) - Regular security updates and patches - Code review and security testing

Monitoring and Response: - Security monitoring for unusual activity or potential threats - Incident response procedures for security breaches - Regular security audits and assessments - Employee security training and awareness programs

5.3 Security Limitations

Important Notice: While we strive to protect your personal information, no security system is impenetrable. Please be aware:

If you believe your account has been compromised or you notice suspicious activity, please contact us immediately at [security email].

5.4 Data Retention

We retain your information for the following periods:

Active Account Data: - Account Information: Retained indefinitely for business operations and compliance requirements - Active Delivery Data: Retained indefinitely for business operations and compliance requirements

Historical Data: - Delivery Records: Retained for 7 years from delivery completion date per business record-keeping requirements and regulatory compliance - Location Data (Trip Logs): Retained for 7 years from trip completion for mileage verification, audit purposes, and compliance - Photos and Documents: Retained for 7 years from capture date for business records, compliance, and legal requirements - Transaction Records: Retained for 7 years per financial record-keeping and tax compliance requirements

Temporary Data: - Session Tokens: Expired and deleted after logout or session expiration - Cached Data: Automatically cleaned up after successful synchronization with servers - Error Logs: Retained for 90 days for debugging and support purposes

After Account Termination: - Upon request or employment termination, personal identifiers (name, email, phone) are removed or anonymized - Business records (deliveries, locations, documents) may be retained in anonymized form per legal and compliance requirements - Data deletion is completed within 30 days of request, subject to legal retention requirements

Legal Obligations: Certain data may be retained longer if required by law, regulatory requirements, legal holds, ongoing investigations, or to resolve disputes, even after you request deletion.


6. Your Rights and Choices

You have certain rights regarding your personal information. The availability and scope of these rights may vary depending on your location.

6.1 Access Your Information

Right to Access: You have the right to access your personal information collected by the App.

How to Access: - View your account information, delivery history, and settings within the App (Settings > Account) - View your location history for completed deliveries (Delivery Details > Route Map) - View captured photos and documents (Delivery Details > Documents) - Request a complete copy of your data by contacting us at [email protected]

We will provide your data in a structured, commonly used format within 30 days of your request.

6.2 Correct Your Information

Right to Correction: You have the right to correct inaccurate or incomplete personal information.

How to Correct: - Update your name, email, phone number, and preferences directly in app settings (Settings > Account) - Contact your supervisor or dispatcher to correct delivery-related information - Email us at [email protected] for assistance with corrections

We will process correction requests within 15 business days.

6.3 Delete Your Information

Right to Deletion: You have the right to request deletion of your personal information, subject to certain limitations.

How to Request Deletion: 1. Email your deletion request to [email protected] with subject line “Data Deletion Request” 2. Include your full name, email address, and user ID in your request 3. We will verify your identity before processing the request 4. Deletion will be completed within 30 days of verification

Limitations on Deletion: We may retain certain information even after a deletion request if required for: - Legal obligations (tax records, employment records, regulatory compliance) - Business record-keeping requirements (delivery documentation retained for 7 years) - Ongoing legal matters, investigations, or disputes - Legitimate business purposes (fraud prevention, security, audit)

When deletion is not possible due to legal requirements, we will anonymize your personal identifiers (name, email) while retaining necessary business records.

6.4 Control Location Tracking

Stop Location Tracking: - Complete or cancel your active delivery in the App - Log out of the App when off-duty - Location is only tracked during active delivery periods

Manage Location Permissions: - Android: Settings > Apps > Driver App > Permissions > Location - iOS: Settings > Driver App > Location

Note: Denying location permissions will prevent core app functionality (route tracking, delivery completion), but you can still access other features like viewing past deliveries and account settings.

6.5 Control Biometric Authentication

Enable or Disable: - Navigate to Settings > Security > Biometric Authentication - Toggle fingerprint/face recognition on or off at any time - Disabling biometric authentication will not affect other app features

Note: Biometric data is stored and processed by your device’s operating system, not by our App.

6.6 Control Photo Library Access

Manage Photo Permissions: - Android: Settings > Apps > Driver App > Permissions > Storage/Photos - iOS: Settings > Driver App > Photos

You can: - Allow access to select photos only (iOS 14+) - Deny gallery access and still use camera to capture photos directly - Revoke permission to save photos to your gallery

6.7 Manage Bluetooth Access

Manage Bluetooth Permissions: - Android: Settings > Apps > Driver App > Permissions > Nearby devices/Bluetooth - iOS: Settings > Driver App > Bluetooth

Note: Denying Bluetooth permission will prevent receipt printing functionality but will not affect other app features.

6.8 Manage App Preferences

Customize Your Experience: - Theme Mode: Settings > Appearance > Theme (Light/Dark/System) - Font Size: Settings > Appearance > Font Size (Small/Medium/Large) - Battery Conservation: Settings > Location > Battery Mode

6.9 Log Out and End Session

Log Out: - Select Settings > Log Out - Logging out will: - Stop location tracking immediately - End your session and require re-authentication - Keep local data on device until next sync (or you can clear data)

Clear Local Data: - Settings > Advanced > Clear Local Data - This will delete all locally stored deliveries, trip logs, and photos that haven’t been synced to the server


7. Children’s Privacy

Age Restriction: Our App is not directed to individuals under the age of 18. The App is designed for delivery drivers, which requires being of legal working age (typically 18 or older depending on jurisdiction and DOT requirements).

No Knowing Collection: We do not knowingly collect personal information from children under 18. If we learn that we have collected information from a child under 18, we will delete that information immediately.

Parental Notice: If you believe your child has provided us with personal information without your consent, please contact us immediately at [email protected] and we will take steps to remove such information.


8. International Data Transfers

Data Transfer: If you are located outside United States, please be aware that your information may be transferred to, stored, and processed in United States.

Different Privacy Laws: These countries may have data protection laws that are different from the laws of your country. By using the App, you consent to the transfer of your information to these countries.

Safeguards: When we transfer data internationally, we ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable laws, including: - Standard contractual clauses approved by relevant authorities - Adequacy decisions where applicable - Other lawful transfer mechanisms


9. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

9.1 Right to Know

You have the right to know: - What personal information we collect about you - The categories of sources from which information is collected - The business or commercial purposes for collecting information - The categories of third parties with whom we share information - The specific pieces of personal information we have collected about you

9.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions for business record-keeping and legal requirements.

9.3 Right to Opt-Out of Sale

We do not sell personal information. We have not sold personal information in the past 12 months and do not have plans to sell personal information in the future.

9.4 Right to Non-Discrimination

You have the right to not receive discriminatory treatment for exercising your CCPA privacy rights. We will not: - Deny you goods or services - Charge different prices or rates - Provide different quality of services - Suggest you will receive different prices or quality of services

9.5 How to Exercise Your Rights

To exercise your CCPA rights: 1. Email your request to [email protected] with subject line “California Privacy Rights Request” 2. Specify which right you wish to exercise (access, deletion, etc.) 3. Provide your full name, email address, and user ID for verification 4. We will respond within 45 days of receiving your verified request

Authorized Agent: You may designate an authorized agent to make requests on your behalf. We will require written proof of authorization.

9.6 California Categories Collected

We collect the following categories of personal information:

Category Examples Collected?
Identifiers Name, email, phone, user ID YES
Personal information (Cal. Civ. Code § 1798.80(e)) Name, address, phone YES
Protected characteristics Age, employment status NO
Commercial information Transaction history, delivery records YES
Biometric information Fingerprint/face recognition (device only) YES (optional)
Internet/network activity App usage, interactions YES
Geolocation data Precise GPS location YES
Sensory information Photos, videos, audio (if applicable) YES
Professional information Driver role, permissions YES
Education information None NO
Inferences Performance metrics, analytics YES

10. Changes to This Privacy Policy

10.1 Policy Updates

We may update this Privacy Policy from time to time to reflect changes in: - Our data practices - Legal or regulatory requirements - App features and functionality - Company policies

10.2 Notification of Changes

When we make changes to this Privacy Policy, we will: - Update the “Last Updated” date at the top of this Privacy Policy - Notify you through the App with an in-app notification - Send you an email notification if the changes are material - Require you to review and accept the updated Privacy Policy before continuing to use the App (for material changes)

10.3 Material Changes

Material changes that will trigger notification and acceptance requirements include: - New categories of personal information collected - New purposes for using personal information - Sharing data with new categories of third parties - Changes to data retention periods - Changes to your rights or how to exercise them

10.4 Review Recommendation

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of the App after changes are posted constitutes your acceptance of the updated Privacy Policy.


11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

General Privacy Inquiries

Email: [email protected] Subject Line: Privacy Inquiry - Driver App

Mailing Address: 11916408 CANADA LIMITED Attn: Privacy Officer 116 John Brabson Crescent Guelph ON N1G 0G7 Canada

Data Deletion Requests

Email: [email protected] Subject Line: Data Deletion Request - Driver App

Include in your request: - Full name - Email address associated with your account - User ID (if known) - Reason for deletion (optional)

Security Concerns

Email: [email protected] Subject Line: Security Concern - Driver App

Use this contact for: - Suspected account compromise - Reporting security vulnerabilities - Suspicious activity or unauthorized access

Response Time

We will respond to your inquiry within: - General inquiries: 5-7 business days - Privacy rights requests: 30 days (CCPA), 1 month (GDPR) - Security concerns: 24-48 hours - Data deletion requests: 30 days after verification


12. Additional Information

12.1 Third-Party Services

No Third-Party Tracking: This App does not integrate third-party analytics services (such as Google Analytics, Firebase Analytics, Mixpanel, etc.) or advertising networks that track you across other apps or websites.

Backend Services: Our backend infrastructure is provided by [specify hosting provider, e.g., AWS, Google Cloud, Azure]. Data is transmitted securely and stored in compliance with their security standards and data protection agreements.

12.2 Cookies and Similar Technologies

Mobile App - No Web Cookies: As a native mobile application, we do not use web browser cookies. However, we do store data locally on your device using: - SQLite database: For delivery data, trip logs, and settings - SharedPreferences / UserDefaults: For user preferences and session management - File storage: For photos and documents

This local storage is necessary for app functionality and offline capabilities.

The App may contain links to third-party services such as: - Navigation apps (Google Maps, Waze) - Phone dialer and messaging apps - External websites or resources

We are not responsible for the privacy practices of these third-party services. We encourage you to read their privacy policies before using them.

12.4 Do Not Track Signals

The App does not respond to “Do Not Track” signals from web browsers as it is a native mobile application, not a web-based service. However, you can control data collection through device permissions as described in Section 6 (Your Rights and Choices).

12.5 Data Breach Notification

In the event of a data breach that affects your personal information, we will: - Notify affected users via email within 72 hours of discovery (as required by GDPR) - Notify relevant supervisory authorities as required by law - Provide information about the breach, affected data, and steps taken to address it - Offer guidance on steps you can take to protect yourself

12.6 Employee Access and Training

Access to your personal information is limited to: - Employees, contractors, and agents who need access to perform their job functions - Individuals who are bound by confidentiality obligations - Personnel who have received data protection training

We conduct regular training on privacy and data protection practices for all personnel with access to personal information.


Glossary of Terms

Personal Information: Information that identifies, relates to, describes, or could reasonably be linked with you or your device.

Precise Location: GPS coordinates with accuracy typically within 5-50 meters.

Background Collection: Collection of data when the App is not actively displayed on your screen, including when closed, minimized, or screen is locked.

Bearer Token: An authentication credential that allows the App to access the server on your behalf without repeatedly asking for your password.

Biometric Authentication: Using fingerprint or facial recognition to unlock the App.

Synchronization (Sync): The process of transferring data from your device to our servers.

Trip Log: A record of GPS location points collected during a delivery route.

Proof of Delivery: Documentation (photos, signatures, timestamps, locations) confirming delivery completion.

Bill of Lading: A legal document providing details about a fuel shipment.

DOT: Department of Transportation (U.S. federal agency regulating transportation safety).


Summary - Quick Reference

What We Collect: - Personal info (name, email, phone) - Precise GPS location (continuous, including background) - Photos and documents (delivery proof) - Customer addresses and delivery details - Device info (Bluetooth printers)

Why We Collect It: - Manage delivery operations - Track routes for mileage reimbursement - Provide proof of delivery - Comply with regulations - Support drivers in completing deliveries

Who We Share With: - Your employer/organization (authorized personnel) - Our backend servers (for storage and processing) - Legal authorities (when required by law) - NO advertising networks or data brokers

Your Choices: - Access your data through app settings - Correct your information in settings - Request deletion by emailing [email protected] - Stop location tracking by ending deliveries - Manage permissions through device settings

Questions? Email: [email protected]


Last Updated: October 17, 2025

Effective Date: October 17, 2025

Version: 1.0


By using the Driver App, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.