service, we collect information about these communications, including the participants’ phone numbers, the date and time, and the contents of SMS messages. For security purposes, we may also monitor or record the contents of phone calls made through the LugIt Platform, but we will always let you know we are about to do so before the call begins.

Address Book Contacts. You may set your device permissions to grant LugIt access to your contact lists and direct LugIt to access your contact list, for example to help you refer friends to LugIt. If you do this, we will access and store the names and contact information of the people in your address book.

Cookies, Analytics, and Third-Party Technologies. We collect information through the use of “cookies”, tracking pixels, data analytics tools like Google Analytics, SDKs, and other third-party technologies to understand how you navigate through the LugIt Platform and interact with LugIt advertisements, to make your LugIt experience safer, to learn what content is popular, to improve your site experience, to serve you better ads on other sites, 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 the LugIt Platform. You should consult your web browser(s) to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may miss out on certain features of the LugIt Platform.

C. Information We Collect from Third Parties

Third-Party Services. Third-party services provide us with information needed for core aspects of the LugIt Platform, as well as for additional services, programs, loyalty benefits, and promotions that can enhance your LugIt experience. These third-party services include background check providers, insurance partners, financial service providers, marketing providers, and other businesses. We obtain the following information about you from these third-party services:

• Information to make the LugIt Platform safer, like background check information for Transporters.

• Information about your participation in third-party programs that provide things like insurance coverage and financial instruments, such as insurance, payment, transaction, and fraud detection information.

• Information to operationalize loyalty and promotional programs or applications, services, or features you choose to connect or link to your LugIt account, such as information about your use of such programs, applications, services, or features; and

• Information about you provided by specific services, such as demographic and market segment information.

  Enterprise Programs. If you use LugIt through your employer or other organization that participates in one of our LugIt Business enterprise programs, we will collect information about you from those parties, such as your name and contact information.

Concierge Service. Sometimes another business or entity may order you a LugIt Ship. If an organization has ordered a Ship for you using our Concierge service, they will provide us your contact information and the pickup and drop-off location of your Ship.

Referral Programs. Friends help friends use the LugIt Platform. If someone refers you to LugIt, we will collect information about you from that referral including your name and contact information.

Other Users and Sources. Other users or public or third-party sources such as law enforcement, insurers, media, or pedestrians may provide us information about you, for example as part of an investigation into an incident or to provide you support.

How We Use Your Information

We use your personal information to:

• Provide the LugIt Platform.

• Maintain the security and safety of the LugIt Platform and its users.

• Build and maintain the LugIt community.

• Provide customer support.

• Improve the LugIt Platform; and

• Respond to legal proceedings and obligations.

  Providing the LugIt Platform. We use your personal information to provide an intuitive, useful, efficient, and worthwhile experience on our platform. To do this, we use your personal information to:

• Verify your identity and maintain your account, settings, and preferences.

• Connect you to your Ships and track their progress.

• Calculate prices and process payments.

• Allow Shippers and Transporters to connect regarding their Ship and to choose to share

  their location with others.

• Communicate with you about your Ships and experience.

• Collect feedback regarding your experience.

• Facilitate additional services and programs with third parties; and

• Operate contests, sweepstakes, and other promotions.

  Maintaining the Security and Safety of the LugIt Platform and its Users. Providing you a secure and safe experience drives our platform, both on the road and on our apps. To do this, we use your personal information to:

• Authenticate users.

• Verify that Transporters and their vehicles meet safety requirements.

• Investigate and resolve incidents, accidents, and insurance claims.

• Encourage safe Transporting behavior and avoid unsafe activities.

• Find and prevent fraud; and

• Block and remove unsafe or fraudulent users from the LugIt Platform.
Building and Maintaining the LugIt Community. LugIt works to be a positive part of the

community. We use your personal information to:

• Communicate with you about events, promotions, elections, and campaigns.

• Personalize and provide content, experiences, communications, and advertising to promote

  and grow the LugIt Platform; and

• Help facilitate donations you choose to make through the LugIt Platform.

  Providing Customer Support. We work hard to provide the best experience possible, including supporting you when you need it. To do this, we use your personal information to:

• Investigate and assist you in resolving questions or issues you have regarding the LugIt Platform; and

• Provide you support or respond to you.
  Improving the LugIt Platform. We are always working to improve your experience and provide

  you with new and helpful features. To do this, we use your personal information to:

• Perform research, testing, and analysis.

• Develop new products, features, partnerships, and services.

• Prevent, find, and resolve software or hardware bugs and issues; and

• Monitor and improve our operations and processes, including security practices,

  algorithms, and other modeling.

  Responding to Legal Proceedings and Requirements. Sometimes the law, government entities, or other regulatory bodies impose demands and obligations on us with respect to the services we seek to provide. In such a circumstance, we may use your personal information to respond to those demands or obligations.

  How We Share Your Information

  We do not sell your personal information. To make the LugIt Platform work, we may need to share your personal information with other users, third parties, and service providers. This section explains when and why we share your information.

  A. Sharing Between LugIt Users

  Shippers, Transporters, and receivers.

  Shipper information shared with Transporter: Upon receiving a Ship request, we share with the Transporter the Shipper’s pickup location, name, profile photo, rating, Shipper statistics (like approximate number of Ships and years as a Shipper), and information the Shipper includes in their Shipper profile (like preferred pronouns). Upon pickup and during the Ship, we share with the Transporter the Shipper’s destination and any additional stops the Shipper inputs into the LugIt app. Once the Ship is finished, we also eventually share the Shipper’s rating and feedback with the

Transporter. (We remove the Shipper’s identity associated with ratings and feedback when we share it with Transporters, but a Transporter may be able to identify the Shipper that provided the rating or feedback.)

Transporter information shared with Shipper and Receivers: Upon a Transporter accepting a requested Ship, we will share with the Shipper the Transporter’s name, profile photo, preferred pronouns, rating, real-time location, and the vehicle make, model, color, and license plate, as well as other information in the Transporter’s LugIt profile, such as information Transporters choose to add and Transporter statistics (like approximate number of Ships and years as a Transporter).

Although we help Shippers, Transporters and Receivers to communicate with one another to arrange a pickup, we do not share your actual phone number or other contact information with other users. If you report a lost or found item to us, we will seek to connect you with the relevant Shipper or Transporter, including sharing actual contact information with your consent.

Ships Requested or Paid for by Others. Some Ships you take may be requested or paid for by others. If you take one of those Ships using your LugIt Business Profile account, a code or coupon, a subsidized program (e.g., transit or government), or a corporate credit card linked to another account, or another user otherwise requests or pays for a Ship for you, we may share some or all of your Ship details with that other party, including the date, time, charge, rating given, region of trip, and pick up and drop off location of your Ship.

Referral Programs. If you refer someone to the LugIt Platform, we will let them know that you generated the referral. If another user referred you, we may share information about your use of the LugIt Platform with that user. For example, a referral source may receive a bonus when you join the LugIt Platform or complete a certain number of Ships and would receive such information.

B. Sharing with Third-Party Service Providers for Business Purposes

Depending on whether you’re a Shipper or a Transporter, LugIt may share the following categories of your personal information for a business purpose (as we have done for the preceding 12 months) to provide you with a variety of the LugIt Platform’s features and services:

• Personal identifiers, such as your name, address, email address, phone number, date of birth, government identification number (such as social security number), Transporter’s license information, vehicle information, and car insurance information.

• Financial information, such as bank routing numbers, tax information, and any other payment information you provide us.

• Commercial information, such as Ship information, Transporter/Shipper statistics and feedback, and Transporter/Shipper transaction history.

• Internet or other electronic network activity information, such as your IP address, type of browser, version of operating system, carrier and/or manufacturer, device identifiers, and mobile advertising identifiers; and

• Location data.

  We disclose those categories of personal information to service providers to fulfill the following business purposes:

• Maintaining and servicing your LugIt account.

• Processing or fulfilling Ships.

• Providing you customer service.

• Processing Shipper transactions.

• Processing Transporter applications and payments.

• Verifying the identity of users.

• Detecting and preventing fraud.

• Processing insurance claims.

• Providing Transporter loyalty and promotional programs.

• Providing marketing and advertising services to LugIt.

• Providing financing.

• Providing requested emergency services.

• Providing analytics services to LugIt; and

• Undertaking internal research to develop the LugIt Platform.

  C. For Legal Reasons and to Protect the LugIt Platform

  We may share your personal information in response to a legal obligation, or if we have determined that sharing your personal information is reasonably necessary or appropriate to:

• Comply with any applicable federal, state, or local law or regulation, civil, criminal, or regulatory inquiry, investigation or legal process, or enforceable governmental request.

• Respond to legal process (such as a search warrant, subpoena, summons, or court order).

• Enforce our Terms of Service.

• Cooperate with law enforcement agencies concerning conduct or activity that we

  reasonably and in good faith believe may violate federal, state, or local law; or

• Exercise or defend legal claims, protect against harm to our rights, property, interests, or safety or the rights, property, interests, or safety of you, third parties, or the public as

  required or permitted by law.

  D. In Connection with Sale or Merger

  We may share your personal information while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.

  E. Upon Your Further Direction

  With your permission or upon your direction, we may disclose your personal information to interact with a third party or for other purposes.

  How We Store and Protect Your Information

  We retain your information for as long as necessary to provide you and our other users the LugIt Platform. This means we keep your profile information for as long as you maintain an account. We retain transactional information such as Ships and payments for at least seven years to ensure we can perform legitimate business functions, such as accounting for tax obligations. If you request account deletion, we will delete your information as set forth in the “Deleting Your Account” section below.

We take reasonable and appropriate measures designed to protect your personal information. But no security measures can be 100% effective, and we cannot guarantee the security of your information, including against unauthorized intrusions or acts by third parties.

Your Rights and Choices Regarding Your Data

As explained more below, LugIt provides ways for you to access and delete your personal information as well as exercise other data rights that give you certain control over your personal information.

A. All Users

Email Subscriptions. You can always unsubscribe from our commercial or promotional emails by clicking unsubscribe in those messages. We will still send you transactional and relational emails about your use of the LugIt Platform.

Text Messages. You can opt out of receiving commercial or promotional text messages by texting the word END to our texting number from the mobile device receiving the messages. You may also opt out of receiving all texts from LugIt (including transactional or relational messages) by texting the word STOPALL to our texting number from the mobile device receiving the messages. Note that opting out of receiving all texts may impact your use of the LugIt Platform. Transporters can also opt out of Transporter-specific messages by texting STOP in response to a Transporter SMS. To re-enable texts, you can text START in response to an unsubscribe confirmation SMS.

Push Notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the LugIt Platform (such as receiving a notification that your Ship has arrived).

Profile Information. You can review and edit certain account information you have chosen to add to your profile by logging in to your account settings and profile.

Location Information. You can prevent your device from sharing location information through your device’s system settings. But if you do, this may impact LugIt’s ability to provide you our full range of features and services.

Cookie Tracking. You can modify your cookie settings on your browser, but if you delete or choose not to accept our cookies, you may be missing out on certain features of the LugIt Platform.

Do Not Track. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. The LugIt Platform does not currently support Do Not Track requests currently.

Deleting Your Account. If you would like to delete your LugIt account, please visit our privacy homepage. In some cases, we will be unable to delete your account, such as if there is an issue with your account related to trust, safety, or fraud. When we delete your account, we may retain certain information for legitimate business purposes or to comply with legal or regulatory obligations. For example, we may retain your information to resolve open insurance claims, or we

may be obligated to retain your information as part of an open legal claim. When we retain such data, we do so in ways designed to prevent its use for other purposes.

B. California Residents

The California Consumer Privacy Act provides some California residents with the additional rights listed below. To exercise these rights see the “Exercising Your California Privacy Rights” section or visit our privacy homepage. For metrics regarding rights requests, see here.

Right to Know. You have the right to know and see what data we have collected about you over the past 12 months, including:

• The categories of personal information we have collected about you.

• The categories of sources from which the personal information is collected.

• The business or commercial purpose for collecting your personal information.

• The categories of third parties with whom we have shared your personal information; and

• The specific pieces of personal information we have collected about you.

  Right to Delete. You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same). There are a number of exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

• Complete your transaction.

• Provide you a good or service.

• Perform a contract between us and you.

• Protect your security and prosecute those responsible for breaching it.

• Fix our system in the case of a bug.

• Protect the free speech rights of you or other users.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §

  1546 et seq.).

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public

  interests that adheres to all other applicable ethics and privacy laws.

• Comply with a legal obligation; or

• Make other internal and lawful uses of the information that are compatible with the context

  in which you provided it.

  Other Rights. You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.

  Exercising Your California Privacy Rights. To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us using one of the following methods:

  Website: You may visit our privacy homepage to authenticate and exercise rights via our website.

Email webform: You may write to us to exercise rights.

To respond to some rights, we will need to verify your request either by asking you to log in and authenticate your account or otherwise verify your identity by providing information about yourself or your account. Authorized agents can make a request on your behalf if you have given them legal power of attorney, or we are provided proof of signed permission, verification of your identity, and confirmation that you provided the agent permission to submit the request.

Response Timing and Format. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

Children’s Data

LugIt is not directed to children, and we don’t knowingly collect personal information from children under the age of 13. If we find out that a child under 13 has given us personal information, we will take steps to delete that information. If you believe that a child under the age of 13 has given us personal information, please contact us at our Help Center.

Links to Third-Party Websites

The LugIt Platform may contain links to third-party websites. Those websites may have privacy policies that differ from ours. We are not responsible for those websites, and we recommend that you review their policies. Please contact those websites directly if you have any questions about their privacy policies.

Changes to This Privacy Policy

We may update this policy from time to time as the LugIt Platform changes and privacy law evolves. If we update it, we will do so online, and if we make material changes, we will let you know through the LugIt Platform or by some other method of communication like email. When you use LugIt, you are agreeing to the most recent terms of this policy.

Contact Us

If you have any questions or concerns about your privacy or anything in this policy, including if you need to access this policy in an alternative format, we encourage you to contact us.