Privacy Policy

Version 1.0 | Effective Date: June 10, 2026

uDriveus, Inc., a Delaware corporation

1. INTRODUCTION AND SCOPE

uDriveus, Inc. (“uDriveus,”“we,”“us,” or “our”) is a Delaware corporation that operates a pre-scheduled transportation marketplace platform (the “Platform”) with operations in the states of Florida, Texas, Arizona and New Mexico. We take your privacy seriously. This Privacy Policy (this “Policy”) describes how we collect, use, disclose, retain, and protect personal information in connection with the Platform and our related websites, mobile applications and services (collectively, the “Services”).

By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree with the terms of this Policy, you must discontinue your use of the Services immediately.

Scope of This Policy. This Policy applies to:

Guests (passengers) who use the Platform to search for, book or otherwise engage with pre-scheduled transportation engagements;
Independent contractor drivers (“Drivers”) who use the Platform to offer transportation engagements; and
All other visitors to our websites and users of our Services, regardless of whether they complete a registration or booking.

Driver-Specific Provisions. Drivers who enter into a Driver Platform Agreement with us should note that the Driver Platform Agreement contains additional data-related provisions specific to the driver relationship, including provisions governing telematics data collection, background check authorizations and data sharing with insurance carriers. In the event of a conflict between this Policy and the Driver Platform Agreement with respect to driver-specific data practices, the Driver Platform Agreement governs. The Driver Platform Agreement is available at [INSERT URL].

This Policy does not apply to third-party services, websites, or applications that may be linked from the Services. We encourage you to review the privacy policies of those third parties before providing any personal information to them.

2. INFORMATION WE COLLECT

We collect personal information about you from several sources, as described below. “Personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked to a particular individual or household.

2.1 Information You Provide Directly

We collect information you voluntarily provide when you register for an account, use our Services or otherwise communicate with us, including:

(a) Account and Contact Information.

Full legal name;
Email address;
Mobile telephone number;
Residential and/or mailing address; and
Username and password credentials.

(b) Identity Verification Information.

Government-issued driver’s license (including license number, state of issuance, expiration date, and photograph);
State-issued photo identification card; and
Any additional documentation we may request to verify your identity in compliance with applicable law.

(c) Payment and Financial Information.

Credit card, debit card, or other payment card details (collected and processed by our third-party payment processor; we do not store full card numbers);
Billing address associated with your payment method; and
Bank account information, where applicable for Driver payouts.

(d) Driver-Specific Information.

Proof of valid automobile insurance (policy number, carrier, coverage limits, expiration date);
Vehicle registration and title information;
Vehicle make, model, year, color, VIN and license plate number;
Commercial vehicle inspection records, where required;
Background check authorization forms and related consents; and
Any other documentation required under applicable state or local law for transportation network company (TNC) drivers in Florida, Texas, Arizona or New Mexico.

(e) Profile Information.

Profile photograph;
Self-submitted biography or description;
Languages spoken; and
Vehicle amenities and preferences offered to guests.

(f) Communications.

Messages, inquiries, and other communications you send to uDriveus through our customer support channels;
In-app messages exchanged between guests and drivers through the Platform messaging feature; and
Surveys, feedback, ratings, and reviews you submit.

2.2 Information Collected Automatically

When you access or use the Services, we and our service providers automatically collect certain information about your device and your interactions with the Services, including:

(a) Device and Technical Information.

Internet Protocol (IP) address;
Browser type and version;
Operating system and version;
Unique device identifiers (e.g., IDFA, Android Advertising ID, IDFV);
Mobile carrier and network connection type; and
Device language and time zone settings.

(b) Usage Data.

Pages and screens viewed within the Services;
Features and functionality accessed;
Search queries entered;
Clickstream data and navigation paths;
Date and time stamps of interactions; and
Referring URLs or referring application identifiers.

(c) Precise Geolocation and Trip Data.

GPS-derived precise geolocation data collected from your mobile device (with your permission) when you use the Platform, including during active engagements;
Pickup and drop-off location data;
Route and navigation information;
Trip distance and duration; and
In-app map interactions.

(d) Telematics and Operational Safety Data (Drivers).

Vehicle speed and acceleration/deceleration data;
Braking and cornering behavior;
Mobile device orientation and usage patterns during active engagements;
Trip start and end events; and
Other vehicle sensor data collected during active engagements, where supported by the device and Platform.

(e) Communication Metadata.

Metadata associated with in-app messages (e.g., timestamps, delivery status); and
Telephone call records where calls are routed through the Platform (call duration, date/time; call content is not routinely recorded except as disclosed separately with appropriate consent).

(f) Cookies, Pixels, and Analytics Technologies.

We use cookies, web beacons, pixel tags, local storage, and similar tracking technologies to collect information about your interactions with our websites and mobile applications. For more information about our use of these technologies and your choices, please see Section 7 (Cookies and Tracking Technologies) of this Policy.

2.3 Information We Receive from Third Parties

We may receive personal information about you from third-party sources, including:

(a) Consumer Reporting Agencies and Background Check Providers.

For Drivers, we obtain consumer reports—including criminal background records and motor vehicle records (MVRs)—from one or more consumer reporting agencies (CRAs). These reports are obtained and used in compliance with the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. (“FCRA”), applicable state law analogs, and any applicable guidance from the Consumer Financial Protection Bureau. Drivers will receive separate FCRA-compliant disclosures and authorizations before any consumer report is obtained.

(b) Payment Processors.

Transaction confirmation data, payment status and fraud signals from our payment processing partners; and
Chargeback and dispute information.

(c) Identity Verification Services.

Identity match scores and verification determinations; and
Flags for potential identity fraud or document irregularities.

(d) Insurance Verification Providers.

Confirmation of insurance coverage status and policy details for Drivers.

(e) Publicly Available Information.

Publicly available records such as court records, sex offender registries, and similar sources accessed during background screening processes, to the extent permitted by applicable law.

(f) Other Users of the Platform.

Ratings and written reviews that guests submit about Drivers following completed engagements; and
Ratings and written reviews that Drivers submit about guests following completed engagements.

2.4 Biometric Information

Where required or permitted by applicable law, uDriveus may collect biometric identifiers or biometric information (collectively, “Biometric Information”) as part of our identity verification and safety processes. Such collection is subject to separate, conspicuous written consent obtained prior to collection, as required by applicable state law.

Texas Residents: If you are a Texas resident, any collection and use of your Biometric Information is governed by the Texas Capture or Use of Biometric Identifier Act, Tex. Bus. & Com. Code § 503.001, as amended (“CUBI Act”). We will not collect, capture or otherwise obtain Biometric Information from Texas residents without first:

Informing you in writing of the specific purpose and length of time for which the Biometric Information will be collected, stored, and used;
Receiving a written release from you authorizing the collection and use of your Biometric Information for the stated purpose; and
Establishing and making available a written policy governing our retention schedule for and destruction of Biometric Information.

We will not sell, lease, trade or otherwise profit from the Biometric Information of Texas residents without separate written consent. We will not disclose or redisclose Biometric Information without consent, except as required by law, or where necessary to complete a financial transaction requested by the individual.

Types of Biometric Information We May Collect:

Facial geometry scans or facial recognition data derived from submitted photographs for identity verification purposes; and
Voice recordings for safety monitoring or verification purposes,where separately consented to and disclosed.

We retain Biometric Information for no longer than the period required to fulfill the stated purpose or as required by law, whichever is shorter, and securely destroy such information thereafter.

3. HOW WE USE YOUR INFORMATION

We use the personal information we collect for the following purposes:

(a) Platform Functionality and Service Delivery.

To create, maintain, and manage your account on the Platform;
To facilitate the matching of guests and Drivers for pre-scheduled transportation engagements;
To process booking requests, confirmations, modifications and cancellations;
To enable navigation, routing, and real-time tracking during active engagements; and
To provide customer support and respond to your inquiries, disputes and feedback.

(b) Payment Processing.

To process payments from guests and facilitate payouts to Drivers;
To calculate applicable fees, taxes and service charges;
To issue refunds and resolve payment disputes; and
To maintain financial records as required by law.

(c) Identity Verification.

To verify the identity of guests and Drivers during onboarding and on an ongoing basis;
To confirm that Drivers hold valid licenses and meet applicable eligibility requirements in the jurisdiction of operations, including in Florida, Texas, Arizona and New Mexico; and
To detect and prevent identity fraud.

(d) Background Checks (Drivers).

To obtain and review criminal background reports and MVRs from CRAs in compliance with the FCRA and applicable state law; and
To determine Driver eligibility and to re-screen Drivers on a periodic or triggered basis.

(e) Safety and Fraud Prevention.

To monitor engagements for safety incidents, dangerous driving behavior and policy violations;
To investigate reported safety incidents, complaints and alleged violations of our Terms of Service;
To detect, prevent, and respond to fraud, abuse, unauthorized access and other harmful activity;
To take enforcement action, including account suspension or termination, where violations are confirmed; and
To contact emergency services and share information with law enforcement where we reasonably believe there is an imminent threat to the safety of any person.

(f) Insurance and Risk Management.

To share information with insurance carriers in connection with coverage for engagements and to process insurance claims;
To conduct risk assessments and underwriting-related analytics; and
To cooperate with insurance investigations.

(g) Legal Compliance.

To comply with applicable federal, state, and local laws and regulations, including but not limited to transportation network company statutes in Florida (§ 627.748, Fla. Stat.), Texas (Tex. Occ. Code Ch. 2402), Arizona (A.R.S. §§ 28-9551 et seq.) and New Mexico (N.M. Stat. Ann. §§ 65-7-1 et seq.);
To respond to lawful requests from governmental authorities, courts, and law enforcement agencies; and
To fulfill reporting obligations and maintain records required by applicable regulatory regimes.

(h) Analytics and Service Improvement.

To analyze usage patterns, feature adoption and operational performance of the Platform;
To develop, test and improve new features and functionality;
To conduct research and analytics, including on an anonymized or aggregated basis; and
To train and improve machine learning models used in fraud detection, safety monitoring and matching algorithms, subject to applicable legal requirements.

(i) Dispute Resolution.

To investigate and resolve disputes between guests and Drivers;
To review trip records, communication logs and telematics data in connection with dispute investigations; and
To facilitate arbitration or other dispute resolution proceedings as provided in our Terms of Service.

(j) Communications and Marketing.

To send transactional and operational communications, including booking confirmations, receipts, account notices and security alerts;
To send promotional and marketing communications about our services, offers and features, where you have consented or where otherwise permitted by applicable law; and
You may opt out of marketing communications at any time by following the unsubscribe instructions included in each marketing message or by updating your account notification preferences. Opting out of marketing communications will not affect your receipt of transactional or operational messages.

(k) Enforcement of Terms and Policies.

To enforce our Terms of Service, Driver Platform Agreement, Community Guidelines and other applicable policies; and
To pursue available remedies and limit our damages in the event of a dispute or breach.

4. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information to third parties. We may share your personal information in the following circumstances:

(a) Service Providers and Vendors.

We share personal information with third-party service providers and vendors who perform functions on our behalf, such as payment processing, identity verification, background check services, cloud hosting, data analytics, customer support, email delivery and marketing technology. These service providers are contractually obligated to use your personal information only as directed by us and in a manner consistent with this Policy, and to implement appropriate security measures.

(b) Payment Processors.

Your payment card information is transmitted directly to our third-party payment processor(s) over encrypted connections. We do not store full payment card numbers. Payment processors receive information necessary to process transactions, prevent fraud, and comply with their own legal obligations.

(c) Insurance Carriers.

We share information with insurance carriers and their agents in connection with the provision of insurance coverage applicable to engagements on the Platform, to process and investigate claims, and to cooperate with underwriting and policy administration activities.

(d) Consumer Reporting Agencies (Background Check Providers).

We share Driver information with CRAs for the purpose of obtaining criminal background reports and MVRs, as authorized by the Driver under the applicable FCRA consent and disclosure. Such sharing is governed by the FCRA and applicable state law.

(e) Regulatory Authorities and Law Enforcement.

We may disclose personal information to governmental authorities, regulatory bodies, courts and law enforcement agencies: (i) in response to a lawful subpoena, court order or other legal process; (ii) to comply with applicable law or regulation; (iii) to protect the rights, property, or safety of uDriveus, our users or the public; or (iv) to detect, prevent, or address fraud, security, or technical issues.
We may be required to share trip data and related records with state regulatory agencies in Florida, Texas, Arizona and New Mexico (and other jurisdictions as our operations expand) pursuant to applicable TNC laws.

(f) Other Users of the Platform (Limited Sharing).

Sharing with Guests: When a Driver accepts a booking, we share with the guest the Driver’s first name, profile photograph, vehicle make, model, color, and license plate number, and the Driver’s average rating, to the extent necessary to facilitate the engagement.
Sharing with Drivers: When a Driver is matched with a guest engagement, we share with the Driver the guest’s first name, profile photograph (if provided), pickup location, and any special accommodation requests, to the extent necessary to facilitate the engagement.
We do not share the full legal name, contact information, address, or payment details of one user with another user without consent, except as described herein or as required by law.

(g) Business Transfers.

In the event uDriveus undergoes a merger, acquisition, reorganization, sale of all or a portion of its assets, or similar transaction, personal information held by uDriveus may be transferred to the successor entity or acquiring party as part of such transaction. We will notify you via email and/or a prominent notice on our Services prior to such transfer, and inform you of any material changes to our privacy practices that result from the transaction, to the extent required by applicable law.

(h) With Your Consent.

We may share your personal information with third parties in ways not described above when we have obtained your prior consent to such sharing.

(i) Aggregated and De-Identified Data.

We may share aggregated or de-identified information—which cannot reasonably be used to identify you—with third parties for research, analytics, marketing, and other purposes. We take reasonable steps to ensure that such data cannot be re-identified.

WE DO NOT SELL YOUR PERSONAL INFORMATION TO THIRD PARTIES FOR MONETARY OR OTHER VALUABLE CONSIDERATION.

5. DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, as described in this Policy, and as required or permitted by applicable law. The criteria we use to determine appropriate retention periods include:

The duration of your ongoing relationship with uDriveus (e.g., as an active guest or Driver account holder);
Our legal obligations to retain records under applicable federal and state law, including tax, financial reporting and TNC regulatory requirements;
The existence of any pending or reasonably anticipated dispute, litigation, arbitration, regulatory inquiry or investigation;
Our need to enforce agreements, including our Terms of Service and Driver Platform Agreement;
Insurance-related retention requirements applicable to engagement records; and
Our legitimate interests in fraud prevention, safety monitoring and protection of our legal rights.

Deactivated and Closed Accounts. If you deactivate or close your account, we will retain your personal information as required by applicable law and our legitimate business interests. We will not delete personal information that is subject to a pending legal hold, regulatory obligation or ongoing dispute. Upon expiration of applicable retention periods, we will delete or anonymize your personal information.

Anonymized and Aggregated Data. We may retain anonymized and aggregated data—from which individual identities have been removed or obscured such that re-identification is not reasonably possible—indefinitely for analytical, research and business improvement purposes. Such anonymized data is not subject to this Policy.

Biometric Information. Biometric Information is retained only for the period necessary to fulfill the specific purpose for which it was collected, or as required by applicable law, whichever is shorter, and is then securely destroyed as described in Section 2.4.

6. DATA SECURITY

uDriveus implements and maintains reasonable and appropriate administrative, technical and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, destruction or loss. Our security measures include, without limitation:

(a) Administrative Safeguards.

Documented information security policies and procedures;
Employee and contractor training on data privacy and security obligations;
Access controls based on the principle of least privilege, limiting access to personal information to authorized personnel with a business need; and
Regular review and updates of security policies.

(b) Technical Safeguards.

Encryption of personal information in transit using industry-standard Transport Layer Security (TLS) protocols;
Encryption of sensitive personal information at rest using industry-accepted encryption standards;
Multi-factor authentication requirements for access to systems containing personal information;
Logging, monitoring, and alerting systems to detect unauthorized access or anomalous activity; and
Regular vulnerability assessments and penetration testing.

(c) Physical Safeguards.

Physical access controls to facilities and data centers where personal information is stored; and
Secure disposal of physical media containing personal information.

NO SECURITY MEASURES ARE PERFECT OR IMPENETRABLE, AND WE CANNOT GUARANTEE THAT UNAUTHORIZED THIRD PARTIES WILL NEVER BE ABLE TO DEFEAT OUR SECURITY MEASURES OR IMPROPERLY ACCESS PERSONAL INFORMATION. YOU PROVIDE PERSONAL INFORMATION TO US AT YOUR OWN RISK.

Breach Notification. In the event of a security breach involving your personal information, we will notify you and applicable regulatory authorities as required by applicable state data breach notification laws, including the Florida Information Protection Act (Fla. Stat. § 501.171), the Texas Identity Theft Enforcement and Protection Act (Tex. Bus. & Com. Code § 521.053), the Arizona data breach notification statute (A.R.S. § 18-552) and the New Mexico Data Breach Notification Act (N.M. Stat. Ann. §§ 57-12C-1 et seq.), as applicable. Notifications will be provided within the timeframes required by law.

You are responsible for maintaining the confidentiality of your account credentials. You agree to notify us immediately at contact@udriveus.com if you suspect any unauthorized use of your account or any other security incident involving your account.

7. COOKIES AND TRACKING TECHNOLOGIES

We and our third-party partners use cookies, web beacons, pixel tags, software development kits (SDKs) and similar tracking technologies (collectively, “Tracking Technologies”) to collect information about your interactions with our websites and mobile applications. This section explains the types of Tracking Technologies we use, why we use them, and the choices available to you.

7.1 Types of Tracking Technologies We Use

(a) Essential / Strictly Necessary Technologies.

These Tracking Technologies are necessary for the Services to function and cannot be disabled without impairing core functionality. They include, for example, technologies that authenticate users, maintain session state, prevent fraudulent use, and remember your privacy preferences. Because these technologies are essential, they are not subject to opt-out.

(b) Functional Technologies.

These Tracking Technologies enable enhanced functionality and personalization, such as remembering your language preferences, saved addresses, and other settings. If you disable these technologies, some features of the Services may not function properly.

(c) Analytics Technologies.

We use analytics Tracking Technologies—including those provided by third-party analytics providers—to understand how users interact with our Services, identify popular features and content, measure performance metrics, and improve the Services. The information collected through analytics technologies is generally aggregated and does not directly identify individual users, though it may be associated with your device or account.

(d) Marketing / Advertising Technologies.

With your consent where required, we and our advertising partners use marketing Tracking Technologies to deliver advertisements and promotional content that may be relevant to your interests, to measure the effectiveness of advertising campaigns, and to limit the frequency with which you see a particular advertisement. These technologies may track your activities across different websites and applications over time.

7.2 Your Choices Regarding Tracking Technologies

(a) Browser Settings.

Most web browsers provide settings that allow you to control the acceptance of cookies, to delete cookies already stored on your device, and to receive notice before a cookie is stored. You may use your browser’s settings to limit or block cookies from our Services; however, disabling all cookies may impair your ability to use certain features of the Services. Please refer to your browser’s help documentation for instructions.

(b) Mobile Device Settings.

Your mobile device operating system may provide settings that allow you to limit ad tracking or reset your advertising identifier. Please refer to your device manufacturer’s documentation for instructions.

(c) Opt-Out Tools.

You may opt out of interest-based advertising delivered by participating third-party advertisers by visiting the following industry opt-out tools:

Network Advertising Initiative (NAI) opt-out tool: https://www.networkadvertising.org/choices/
Digital Advertising Alliance (DAA) opt-out tool: https://optout.aboutads.info/

(d) Do-Not-Track Signals.

Some browsers include a “Do Not Track” (“DNT”) feature that signals websites that you do not want your online activities to be tracked. At this time, there is no universally accepted standard for how to respond to DNT signals, and uDriveus does not alter its data collection or use practices in response to DNT browser signals. However, we will continue to monitor developments in this area and may update our practices as industry standards evolve. You may also use the opt-out choices described above to limit certain tracking.

8. CHILDREN’S PRIVACY

Age Requirement. The Services are intended solely for persons who are eighteen (18) years of age or older. You must be at least 18 years of age to register for an account or book a transportation engagement as a guest. We do not knowingly allow individuals under the age of 18 to use the Services.

COPPA Compliance. The Children’s Online Privacy Protection Act, 15 U.S.C. § 6501 et seq., and its implementing regulations promulgated by the Federal Trade Commission (“COPPA”) prohibit the online collection of personal information from children under the age of 13 without verifiable parental consent. The Services are not directed to children under the age of 13, and we do not knowingly collect, solicit, or maintain personal information from children under 13.

No Intentional Collection from Children Under 13. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will take prompt steps to delete such information from our systems. If you believe that we may have inadvertently collected personal information from a child under 13, please contact us immediately at contact@udriveus.com

Parental Rights. If you are a parent or legal guardian and believe that your child under the age of 13 has provided personal information to uDriveus without your consent, you have the right to request that we:

Review the personal information we have collected from your child;
Refuse to permit any further collection or use of your child’s personal information; and
Delete your child’s personal information from our systems.

To exercise these rights, please contact us at contact@udriveus.com We will respond to verifiable requests from parents and guardians within a reasonable time and in accordance with COPPA requirements.

Enforcement and Account Termination. If we discover that a person under the age of 18 has created an account on the Platform, we will terminate that account and delete associated personal information as promptly as practicable. Users who provide false information about their age in order to register an account are in violation of our Terms of Service and may be subject to account termination and other enforcement action.

9. YOUR RIGHTS AND CHOICES

uDriveus is committed to respecting and fulfilling the privacy rights of all individuals who interact with our transportation marketplace platform (the “Platform”). This Section describes the rights you may have regarding your personal information, the mechanisms available to exercise those rights, and the additional protections afforded to residents of the states in which uDriveus currently operates.

9.1 Rights Available to All Platform Users

Regardless of the state in which you reside, all registered guests (passengers), drivers, and other users of the Platform have the following rights with respect to personal information uDriveus holds about them:

Right of Access. You may request a copy of the personal information we hold about you, including the categories of information collected, the purposes for which it is used, and the third parties with whom it has been shared.
Right of Correction. You may request that we correct inaccurate or incomplete personal information in our records. You may also update certain information directly through your Platform account settings.
Right of Deletion. You may request that we delete your personal information, subject to applicable legal obligations, safety requirements, and legitimate business needs (e.g., fraud prevention, financial recordkeeping, litigation holds).
Right to Opt Out of Marketing Communications. You may opt out of receiving promotional emails and other marketing communications from uDriveus at any time by clicking the “unsubscribe” link in any such communication or by updating your notification preferences in your account settings. Note that you may continue to receive transactional and service-related communications necessary to your use of the Platform.
Communication Preference Management. You may manage the types of communications you receive from uDriveus—including push notifications, SMS alerts, and email—through your account settings or your device’s notification controls.
Account Deactivation. You may request deactivation of your Platform account at any time. Following deactivation, we will retain your information only to the extent required by law, to resolve disputes, to prevent fraud, or for other legitimate business purposes as described in this Privacy Policy. Deactivation does not automatically result in the deletion of all personal information.

9.2 State-Specific Privacy Rights

In addition to the general rights described in Section 9.1, residents of the states where uDriveus currently operates may have additional rights under applicable state law. uDriveus will honor these rights to the extent required by the laws of each respective state.

9.2(a) Texas Residents

Texas Data Privacy and Security Act (“TDPSA”), effective July 1, 2024 (Tex. Bus. & Com. Code §§ 541.001 et seq.): Texas residents have the following rights under the TDPSA, which uDriveus endeavors to honor in full:

Right to Know. You have the right to know whether uDriveus is processing your personal data.
Right of Access. You have the right to access the personal data we hold about you, including a portable copy in a readily usable format that allows you to transmit the data to another controller without hindrance (right to data portability).
Right of Correction. You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and the purposes of processing.
Right of Deletion. You have the right to delete personal data you have provided to us or that we have obtained about you, subject to applicable exceptions.
Right to Opt Out of Sale and Targeted Advertising. You have the right to opt out of (i) the sale of your personal data; (ii) the processing of your personal data for purposes of targeted advertising; and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Right to Data Portability. Where technically feasible, you may obtain your personal data in a portable and readily usable format.
Right to Appeal. If uDriveus declines to take action on your rights request, you have the right to appeal that decision. Appeals must be submitted in writing within sixty (60) days of receiving our response. We will provide a written explanation of the reasons for our decision within sixty (60) days of receiving your appeal. If your appeal is denied, you may submit a complaint to the Texas Attorney General.

Texas Capture or Use of Biometric Identifier Act (“CUBI”), Tex. Bus. & Com. Code § 503.001: To the extent uDriveus captures, collects, or uses biometric identifiers or biometric information (such as facial recognition scans used for identity verification purposes), the following protections apply to Texas residents:

Separate Consent. uDriveus will obtain your separate, express written consent before collecting any biometric identifier or biometric information, as defined under CUBI.
Purpose Limitation. Biometric data will be used solely for the specific purpose disclosed at the time of collection (e.g., driver identity verification or fraud prevention) and will not be used for any other commercial purpose without additional consent.
Retention Schedule. uDriveus will not retain biometric data beyond the time necessary to fulfill the stated purpose of collection, or as otherwise permitted or required by law. A retention schedule for biometric data will be maintained and made available upon request.
Destruction Requirements. Biometric data will be permanently destroyed, using industry-standard methods, no later than one (1) year after the stated purpose for collection has been fulfilled, or as soon as practically possible thereafter, in accordance with applicable law.
No Sale or Profit. uDriveus will not sell, lease, trade, or otherwise profit from any Texas resident’s biometric identifiers or biometric information.

9.2(b) Florida Residents

Florida Digital Bill of Rights (“FDBR”), effective July 1, 2024 (Fla. Stat. §§ 501.701 et seq.): Florida residents have the following rights under the FDBR. uDriveus will honor these rights to the fullest extent applicable. Note: Certain rights under the FDBR (such as those related to controllers with annual global revenues exceeding $1 billion or deriving a specified percentage of global revenue from online advertising) may be subject to applicability thresholds. uDriveus will assess applicability as its operations scale and will update this Privacy Policy accordingly.

Right to Know. You have the right to know whether your personal data is being processed.
Right of Access. You have the right to access your personal data held by uDriveus, including confirmation of whether and how your data is being processed.
Right of Deletion. You have the right to delete personal data provided to or obtained by uDriveus, subject to applicable exceptions under the FDBR.
Right of Correction. You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and the purposes of its processing.
Right to Data Portability. You have the right to obtain a copy of your personal data that you previously provided to uDriveus in a portable and, to the extent technically feasible, readily usable format.
Right to Opt Out of Sale and Targeted Advertising. You have the right to opt out of (i) the sale of your personal data; (ii) the processing of your personal data for purposes of targeted advertising; and (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

9.2(c) Arizona Residents

Arizona Privacy Law: Arizona residents may have rights under applicable Arizona consumer data privacy legislation, including any consumer data privacy act enacted by the Arizona Legislature that is effective as of or after the effective date of this Privacy Policy. uDriveus will monitor and comply with Arizona privacy laws as they become effective. To the extent currently applicable, Arizona residents may have the following rights:

Right of Access. The right to confirm whether uDriveus is processing your personal data and to access such data.
Right of Deletion. The right to delete personal data you have provided to or that uDriveus has obtained about you.
Right of Correction. The right to correct inaccuracies in your personal data.
Right to Data Portability. The right to obtain a portable copy of your personal data in a readily usable format.
Right to Opt Out. The right to opt out of the sale of your personal data, the processing of your personal data for targeted advertising purposes, and profiling in furtherance of decisions that produce significant effects.

uDriveus will update this Section as Arizona privacy legislation is finalized, amended, or takes effect to ensure this Privacy Policy accurately reflects your rights under Arizona law.

9.2(d) New Mexico Residents

New Mexico Privacy Protections and Breach Notification: New Mexico residents are afforded protections under applicable New Mexico law, including the New Mexico Data Breach Notification Act (NMSA 1978, § 57-12C-1 et seq.) and other applicable state consumer protection statutes. uDriveus will provide timely notice of security breaches affecting your personal information in accordance with New Mexico law. uDriveus will also honor any additional consumer data privacy rights that may be enacted by the New Mexico Legislature and that are applicable to uDriveus’soperations. This Privacy Policy will be updated as new legislation takes effect.

9.3 How to Exercise Your Privacy Rights

To exercise any of the rights described in this Section, please submit a verifiable consumer request through one of the following methods:

Online: Submit a request through the privacy request portal accessible via your Platform account settings or through our website.
Email: Send a written request to the contact address provided in Section 15 of this Privacy Policy. Please include “Privacy Rights Request” in the subject line.
Mail: Send a written request to the mailing address provided in Section 15.

Verification Process. We will take reasonable steps to verify your identity before responding to any rights requestin order to protect the security of personal information. Verification may require you to provide information that matches information in our records, such as your registered email address, account credentials, or, for sensitive requests, additional identifying documentation. We will not discriminate against you for submitting a request if you are unable to satisfy all verification requirements; however, we may be unable to fulfill certain requests if identity cannot be reasonably verified.

Response Timeframes. We will respond to verifiable consumer requests within forty-five (45) days of receipt. If we require additional time (up to an additional forty-five (45) days), we will notify you in writing within the initial response period, stating the reason(s) for the extension. If we decline to take action on your request, we will provide a written explanation of the reason(s) and, where applicable, instructions for submitting an appeal.

Non-Discrimination. uDriveus will not deny services, charge different prices or rates, provide a different level or quality of service, or engage in any other retaliatory action against you for exercising your privacy rights under applicable law.

Authorized Agents. You may designate an authorized agent to submit privacy rights requests on your behalf. To use an authorized agent, you (or your authorized agent) must provide written proof of the agent’s authority to act on your behalf, and we may require you to verify your own identity directly. uDriveus reserves the right to deny requests from agents who cannot provide sufficient proof of authorization.

9.4 California – Forward-Looking Statement

uDriveus currently does not operate in the State of California and does not direct its Platform to California residents. Accordingly, the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), is not presently applicable to uDriveus’soperations. However, if and when uDriveus expands its operations to California in the future, uDriveus will comply with all applicable CCPA/CPRA requirements, including the rights to know, access, delete, correct, opt-out of sale of personal information, limit use of sensitive personal information, non-discrimination and the right to obtain a portable copy of personal data. This Privacy Policy will be updated at that time to reflect California-specific rights and disclosures, including any required “Do Not Sell or Share My Personal Information” and “Limit the Use of My Sensitive Personal Information” links.

10. SENSITIVE PERSONAL INFORMATION

Certain categories of personal information warrant heightened protection due to their nature and the potential harms that could result from their unauthorized disclosure or misuse. uDriveus recognizes these categories as “Sensitive Personal Information” and applies additional safeguards to their collection, use, and processing.

10.1 Definition

For purposes of this Privacy Policy, “Sensitive Personal Information” means personal information that reveals or relates to: (a) precise geolocation data; (b) biometric data processed for the purpose of uniquely identifying a natural person; (c) racial or ethnic origin; (d) health information, to the extent collected for safety, background screening, or insurance verification purposes; (e) the contents of communications; (f) genetic data; (g) sexual orientation or gender identity; (h) immigration or citizenship status; (i) mental or physical health condition or diagnosis; (j) financial data beyond what is necessary to process payment transactions; and (k) any other category designated as sensitive under applicable state law.

10.2 Categories of Sensitive Personal Information Collected by uDriveus

uDriveus may collect the following categories of Sensitive Personal Information in connection with Platform operations:

Precise Geolocation Data. Real-time and historical GPS location data collected from drivers during active engagements (trips) and, where permitted by user consent, from guests during the engagement period, for matching, navigation, safety monitoring and service delivery purposes.
Biometric Data. Facial scan or photographic identity verification data collected from drivers for the purpose of identity verification, fraud prevention, and platform safety. Such data is processed only to the extent necessary to uniquely identify the driver and confirm their identity in connection with a specific engagement. See Section 9.2(a) for additional Texas-specific biometric protections.
Racial or Ethnic Origin. uDriveus does not collect racial or ethnic origin information for commercial purposes. However, government-issued identification documents submitted for background screening or regulatory compliance purposes may incidentally contain such information. Any such information is used solely for the identity verification or regulatory purpose for which it was submitted.
Health Information. To the extent uDriveus collects any health-related information (for example, in connection with safety reporting, accommodation requests, or insurance-related purposes), such information is treated as Sensitive Personal Information subject to the protections described in this Section.

10.3 Consent and Purpose Limitation for Sensitive Personal Information

Conspicuous Disclosure and Separate Consent. Where required by applicable law, uDriveus will obtain your separate, express consent before collecting or processing Sensitive Personal Information. Such consent will be sought through a clear and conspicuous disclosure—separate from the general terms of service or this Privacy Policy—that identifies the specific category of Sensitive Personal Information being collected, the specific purpose(s) for which it will be used, and any third parties with whom it may be shared. Consent for sensitive data collection and processing is not a condition of using the Platform except where the specific use is operationally necessary and required by law (e.g., identity verification for licensed driver status).

Purpose Limitation. Sensitive Personal Information collected by uDriveus will be used only for the specific, disclosed purpose(s) for which it was collected. uDriveus will not sell Sensitive Personal Information, will not use it for targeted advertising, and will not process it for any purpose incompatible with the original purpose of collection without your additional consent, unless required by applicable law.

Retention and Destruction. uDriveus will retain Sensitive Personal Information only for so long as is necessary to fulfill the purpose for which it was collected, to comply with legal obligations, or for other legitimate business purposes as described in this Privacy Policy. Upon expiration of the applicable retention period, Sensitive Personal Information will be securely destroyed or de-identified using industry-standard methods.

Access Controls. Access to Sensitive Personal Information within uDriveus’s organization is restricted to personnel with a specific business need to access such information in connection with their job functions. uDriveus employs technical and organizational safeguards, including encryption, access logging, and role-based access controls, to protect Sensitive Personal Information from unauthorized access, disclosure, or misuse.

11. LOCATION DATA

Location data is fundamental to uDriveus’s pre-scheduled transportation marketplace. This Section describes in detail the types of location data we collect, the purposes for which we use it, and the controls available to you.

11.1 Types of Location Data Collected

Precise GPS Location Data – Drivers During Engagements. When a driver has accepted an engagement and the engagement is active, uDriveus continuously collects real-time precise GPS coordinates, including latitude, longitude, speed, heading, and timestamp, from the driver’s mobile device or in-vehicle hardware. This precise location data is collected from the moment a driver activates an engagement through the moment the engagement is completed or cancelled. Precise location data may also be collected for a limited period before and after an active engagement to facilitate matching, pickup coordination, and post-engagement safety monitoring.
Precise GPS Location Data – Guests During Engagements. With your permission (as described in Section 11.3 below), uDriveus may collect your precise GPS location during an active engagement to facilitate real-time tracking, estimated time of arrival updates, and safety features such as live trip sharing. Guests can enable or disable this feature through their device location settings.
Approximate Location Data. uDriveus may collect approximate location data (city, region, zip code, or IP-address-derived location) from all Platform users when they access the Platform, for purposes including service availability determination, fraud detection, analytics, and regulatory compliance. Approximate location data is collected regardless of whether you have granted precise location permissions to the Platform application.
Pickup and Drop-Off Location Data. When you schedule an engagement, we collect and store the pickup and drop-off locations you specify. This information is associated with your account and engagement history and is used for service delivery, customer support, and safety purposes.
Historical Location Data. uDriveus retains historical location data from completed engagements for the periods described in our data retention schedule, for purposes including safety investigations, dispute resolution, fraud detection, regulatory compliance, and service improvement analytics.

11.2 Purposes for Which Location Data Is Used

Location data is used by uDriveus for the following purposes:

Engagement Matching and Dispatch. To identify and match available drivers with guests based on proximity, pre-scheduled pickup location, and route efficiency.
Navigation and Route Optimization. To provide turn-by-turn navigation to drivers and to monitor route adherence for quality assurance and safety purposes.
Safety Monitoring. To monitor active engagements for anomalous route deviations, unexpected stops, speeding or other indicators of potential safety concerns. Location data enables our safety team to respond promptly to incidents and to assist law enforcement when required.
Live Trip Sharing. To enable guests to share a real-time view of their engagement’s progress with trusted contacts through the Platform’s live trip sharing feature.
Fraud Detection and Prevention. To detect and prevent fraudulent activities, including GPS spoofing, route manipulation, unauthorized account access from unusual locations and other platform integrity violations.
Customer Support and Dispute Resolution. To reconstruct engagement routes and verify pick-up and drop-off events in connection with billing disputes, safety complaintsand customer support inquiries.
Analytics and Service Improvement. To analyze aggregated and de-identified location data for the purpose of improving matching algorithms, identifying high-demand areas, optimizing driver availability and enhancing the overall Platform experience.
Regulatory Compliance. To maintain records required by applicable transportation network company (“TNC”) regulations in Florida, Texas, Arizona and New Mexico, including records of engagement routes, distances, and pickup and drop-off locations.
Insurance and Liability. To provide location records to insurance carriers and, where required, to law enforcement or regulatory authorities in connection with insurance claims or safety investigations.

11.3 Your Location Data Controls

You have controls over how uDriveus collects and uses your location data, subject to the limitations described below:

Device Location Settings – Guests. You can enable or disable precise location access for the uDriveus mobile application through your device’s operating system settings (e.g., iOS Settings > Privacy & Security > Location Services, or Android Settings > Apps >uDriveus > Permissions). You may set location access to “While Using the App,”“Always,” or “Never.” Please note that disabling precise location access may significantly limit Platform functionality, including the ability to receive real-time engagement tracking updates and to use the live trip sharing safety feature.
Device Location Settings – Drivers. Drivers are required to grant uDriveus continuous precise location access (“Always”) while the uDriveus driver application is active in connection with an accepted engagement. Precise location data collection is a contractual requirement under the Driver Platform Agreement, as it is essential for engagement matching, dispatch, navigation, and safety monitoring. Disabling location access while an engagement is active may result in engagement cancellation and may constitute a violation of the Driver Platform Agreement.
Approximate Location. Approximate location derived from IP address is collected automatically when you access the Platform. You may limit IP-based geolocation by using a VPN; however, uDriveus cannot guarantee Platform functionality or accuracy of service availability information when a VPN is used.
Historical Location Data. You may request deletion of historical engagement location data by submitting a data deletion request as described in Section 9.3, subject to applicable legal retention obligations and safety record requirements.

Disabling precise location access for the uDriveus mobile application through your device settings will limit or disable key Platform features, including live engagement tracking, real-time ETA updates, and the live trip sharing safety feature. uDriveus is not responsible for any loss of service or safety features resulting from your election to disable location access.

12. CROSS-REFERENCES AND RELATED AGREEMENTS

This Privacy Policy is one of several agreements and policies that govern your use of the UDrive Platform. The following additional agreements contain provisions relevant to data collection, use, and privacy, and should be read together with this Privacy Policy.

12.1 Driver Platform Agreement

All drivers who register and operate on the uDriveus Platform are bound by the uDriveus Driver Platform Agreement (the “Driver Agreement”), which contains driver-specific data provisions governing the collection, use, and sharing of data generated during driver operations. Drivers should review the Driver Agreement in its entirety. Of particular relevance to data privacy, Section 10 of the Driver Agreement (GPS, Telematics & Data Consent) contains the following driver-specific data provisions:

Driver consent to the continuous collection of precise GPS location data during active engagements, including location, speed, heading, and telematics data.
Driver acknowledgment that telematics data (including acceleration, braking, and driving behavior data) may be collected and used for safety scoring, insurance underwriting, and performance monitoring purposes.
Driver consent to the use of GPS and telematics data for matching, dispatch, navigation, regulatory compliance, and law enforcement cooperation.
Driver acknowledgment that precise location data is a contractual prerequisite for Platform participation and that disabling location permissions while an engagement is active may result in engagement termination.
Driver-specific data retention provisions applicable to GPS and telematics records.
Driver acknowledgment of identity verification data collection, including photographic and biometric verification processes, and the applicable consent and data handling provisions.

In the event of any conflict between the data provisions of the Driver Agreement and this Privacy Policy, the Driver Agreement shall govern with respect to driver-specific data practices, except where this Privacy Policy provides greater privacy protections, in which case this Privacy Policy shall govern.

12.2 Website Terms and Conditions

uDriveus’s Website Terms and Conditions (the “Website Terms”) govern your access to and use of uDriveus’swebsite(s) and contain additional provisions relevant to data collection through the website, including provisions regarding cookies, tracking technologies and website analytics. The Website Terms are incorporated herein by reference with respect to website-specific data practices.

12.3 Consistency of Agreements

uDriveus is committed to maintaining consistency across all of its agreements and policies with respect to its data practices. All uDriveus agreements are intended to be read together and in a manner that provides users with a complete and coherent understanding of how uDriveus collects, uses, shares, and protects personal information. In the event of a conflict between this Privacy Policy and any other uDriveus agreement, the agreement that provides the greater level of privacy protection to the affected individual shall govern, except to the extent that a specific agreement is required by law to govern a specific category of data or processing activity. If you identify any inconsistency between uDriveus’s agreements or policies, please notify us at the contact information provided in Section 15.

13. INTERNATIONAL DATA TRANSFERS AND SCOPE

The uDriveus Platform is designed, operated, and intended solely for use within the United States of America. uDriveus currently operates in the following states: Florida, Texas, Arizona and New Mexico.uDriveus does not offer services in, and does not direct the Platform to users located in, any country outside the United States.

13.1 No International Operations

uDriveus is a Delaware corporation with operations limited to the United States. uDriveus’sPlatform, systems and data infrastructure are located and maintained within the United States. uDriveus does not transfer personal information to, or process personal information in, any country outside the United States as part of its ordinary Platform operations.

13.2 Users Outside the United States

The uDriveus Platform is not intended for use by individuals located outside the United States. By accessing or using the Platform from a location outside the United States, you acknowledge and consent to the transfer of your personal information to, and its storage and processing within, the United States. The data protection laws of the United States, and of the specific states in which uDriveus operates, may differ from the data protection laws of your country of residence and may not provide the same level of protection. By using the Platform from outside the United States, you expressly consent to such transfer, storage, and processing.

uDriveus makes no representation that the Platform is appropriate for use, or that personal information collected through the Platform will be processed in compliance with the laws of, any jurisdiction other than the United States. If you are located outside the United States and have concerns about the transfer of your personal information, you should refrain from using the Platform and contact us at the address provided in Section 15.

13.3 Future Expansion

If uDriveus expands its operations to additional states or, in the future, to jurisdictions outside the United States, uDriveus will update this Privacy Policy to reflect any applicable cross-border data transfer requirements, including, as applicable, standard contractual clauses, data processing agreements, adequacy determinations, or other appropriate transfer mechanisms required by the laws of the relevant jurisdiction.

14. CHANGES TO THIS PRIVACY POLICY

uDriveus reserves the right to update, modify, or revise this Privacy Policy from time to time to reflect changes in our data practices, business operations, applicable law, regulatory guidance, or technological developments. This Section describes the procedures uDriveus will follow when making changes to this Privacy Policy.

14.1 Routine Updates

We may make minor, non-material updates to this Privacy Policy periodically. Minor updates may include clarifications, corrections of typographical errors, updates to contact information, or other changes that do not materially affect your rights or our data practices. For routine updates, we will post the revised Privacy Policy to our website and update the “Effective Date” at the bottom of this document. Your continued use of the Platform after the posting of a revised Privacy Policy constitutes your acceptance of the updated terms.

14.2 Material Changes

For material changes to this Privacy Policy—including changes that significantly affect the categories of personal information we collect, the purposes for which we use personal information, the third parties with whom we share personal information, or your rights under this Privacy Policy—uDriveus will provide at least thirty (30) days’ advance notice before the material changes take effect. Notice of material changes will be provided through one or more of the following methods:

Email Notification. We will send an email notification to the email address associated with your Platform account, summarizing the material changes and directing you to the updated Privacy Policy.
In-App Notification. We will post a prominent notice within the Platform mobile application, directing you to review the updated Privacy Policy prior to the effective date of the material changes.
Website Notice. We will post a prominent notice on our website homepage and/or Privacy Policy page, identifying the material changes and their effective date.

14.3 Your Acceptance of Updated Terms

By continuing to access or use the Platform after the effective date of any updated Privacy Policy, you acknowledge that you have read, understood, and agree to be bound by the updated Privacy Policy. If you do not agree to the updated Privacy Policy, you must discontinue your use of the Platform prior to the effective date of the updated Privacy Policy. To discontinue use of the Platform, you may deactivate your account as described in Section 9.1.

14.4 Versioning and Access to Prior Versions

Each version of this Privacy Policy will bear a clear “Effective Date” and “Version” designation at the bottom of the document. We will maintain an archive of prior versions of this Privacy Policy and will make such prior versions available upon request by contacting us at the address provided in Section 15. The most current version of this Privacy Policy is available on our website at all times.

15. CONTACT INFORMATION

If you have questions, concerns, or requests related to this Privacy Policy, uDriveus’s data practices or your personal information, please contact us using the information provided below. We take all privacy inquiries seriously and will respond to your inquiry as promptly as practicable, and in any event within the timeframes required by applicable law.

15.1 Privacy Inquiries and Requests

uDriveus, Inc. – Privacy Office

contact@udriveus.com
364 W Olive Ave, Sunnyvale 94086, CA
Phone +1 669-246-8803

When submitting a privacy request, please include your full name, the email address associated with your uDriveus account (if applicable), a description of your request, and the state in which you reside. This information will help us process your request efficiently and verify your identity as required.

15.2 Designated Privacy Contact

uDriveus has designated a Privacy Contact (and, where required by applicable law, a Data Protection Officer or equivalent) responsible for overseeing uDriveus’scompliance with applicable privacy laws and for responding to privacy inquiries. Correspondence addressed to the Privacy Office will be directed to the designated Privacy Contact for review and response.

15.3 Complaints to Regulatory Authorities

If you are not satisfied with uDriveus’sresponse to your privacy inquiry or request, you have the right to submit a complaint to the applicable state regulatory authority. The following contact information is provided for reference:

Texas. Office of the Texas Attorney General, Consumer Protection Division. Website: texasattorneygeneral.gov. Address: P.O. Box 12548, Austin, Texas 78711-2548.
Florida. Office of the Florida Attorney General, Consumer Protection Division. Website: myfloridalegal.com. Address: PL-01 The Capitol, Tallahassee, Florida 32399-1050.
Arizona. Office of the Arizona Attorney General, Consumer Information and Complaints. Website: azag.gov. Address: 2005 N. Central Avenue, Phoenix, Arizona 85004.
New Mexico. Office of the New Mexico Attorney General, Consumer Protection Division. Website: nmag.gov. Address: 408 Galisteo Street, Villagra Building, Santa Fe, New Mexico 87501.

Nothing in this Privacy Policy limits your right to file a complaint with any applicable state or federal regulatory authority at any time.

EFFECTIVE DATE AND VERSION

Effective Date: June 10, 2026

Policy Version: 1.0

Last Updated: June 10, 2026

This Privacy Policy supersedes and replaces all prior versions of uDriveus’s Privacy Policy. By using the uDriveus Platform on or after the Effective Date above, you acknowledge that you have read and understood this Privacy Policy in its entirety and agree to be bound by its terms. If you do not agree to this Privacy Policy, you must immediately discontinue your use of the Platform.

uDriveus, Inc. is a corporation organized and existing under the laws of the State of Delaware, operating a transportation marketplace platform. This Privacy Policy applies to all users of the Platform, including guests (passengers), drivers (independent contractors), and any other individuals who interact with uDriveus’s services in the states of Florida, Texas, Arizona and New Mexico.

Copyright © uDriveus, Inc. All rights reserved. This Privacy Policy may not be reproduced, distributed, or transmitted in any form without the prior written consent of uDriveus, Inc., except for personal, non-commercial reference purposes.