Privacy Policy

1. Introduction

THIS PRIVACY POLICY SETS OUT THE MANNER IN WHICH FLEETOPERATE INC., a Canadian Corporation (hereinafter referred to as 'fleetoperate'), MANAGES PERSONAL INFORMATION AND FORMS PART OF THE FLEETOPERATE TERMS OF SERVICE. IN ORDER TO USE THE FLEETOPERATE SERVICES, PLATFORM, OUR WEBSITE, MOBILE APPLICATION AND/OR CONTENT, YOU MUST HAVE READ, UNDERSTOOD AND AGREED TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE, YOU MAY MAKE NO FURTHER USE OF FLEETOPERATE SERVICES, OUR WEBSITE, MOBILE APPLICATION OR CONTENT.

2. Information We Collect

2.1 Information we collect Directly

We collect the following information including your personal information that you provide directly to us when you:

• Register and create an account for FleetOperate services.
• Access and interact with our services, website, mobile app, and platform.
• Use our services, including compliance management, load booking, dispatch management, risk management.
• Place orders or complete transactions, such as setting up driver profiles, driver qualification file and company profile/s, managing loads or accessing any other services.
• Sign up to receive marketing communications or participate in promotional programs like SMS notifications.
• Communicate directly with us through our website, application, or customer support channels.

We collect a range of personal information, including but not limited to:

Consent for Sensitive Data: By providing personal data, including sensitive information such as your drug and alcohol test results, driving records, or any medical-related information, you explicitly consent to the collection, use, and processing of this data in accordance with this Privacy Policy. FleetOperate will use this information solely for the purposes outlined in this policy and in compliance with applicable regulations such as GDPR and HIPAA.

• Contact Information: First and last name, gender, date of birth, email address, phone number, Bank account information, company name, job title, current and previous address/es, and other similar information.
• Your username and password and/or other login credentials.
• Contact information for the Customer, such as business address and phone number.
• Driver and Employment Information: Employment history, driver's license, identification numbers, passport details, visa status, and address history.
• Background Information: Driving experience, motor vehicle and driver records from various authorities, drug and alcohol test results, police clearance certificates, and similar records.
• Business ownership information, including profit sharing and ownership interests, your FEIN / BN or SIN, social security number.
• Telematics Data: Data collected from telematics systems, such as GPS location, ELD data, speed, harsh braking, and similar data for fleet management.
• Risk and Compliance Data: Information related to risk assessments, loss prevention, driver qualification, compliance management, safety audit results, accident reports, claims history, violation records, and other compliance-related documentation.
• Payment Information: Credit card and/or bank details, invoice history, payment schedules, payment status, compensation details, and reimbursement records.
• Work-related Documents: Copies of contracts, agreements, certifications, performance reviews, work schedules, project documentation, time tracking data, job-related communications, and other work-related records.
• Information regarding the Customer Vehicles and the operation of the Customer Vehicles, including, without limitation, in connection with but not limited to transportation of a Load, which may include, the license plate number, make and model.
• Your payment history and claims information and/or
• Other information you may provide by filling out forms or by contacting us (such as your feedback or other communications with us).

By providing any sensitive data (e.g., drug test results or as outlined above or elsewhere in this document), you explicitly consent to its collection and processing for the purposes outlined in this policy.

Please be advised that we may ask you to update your information from time to time in order to keep it accurate. Additionally, if you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by data protection laws, we may collect, use and disclose such information for the purposes described in this Privacy Policy. For example, you should ensure the individual concerned is aware of the terms detailed in this Privacy Policy.

In certain circumstances, for example, if you only browse the site and do not provide us any information directly and do not otherwise access or use the FleetOperate services, we may not necessarily collect information from you directly, but may collect information indirectly as described in the Sections titled "Information Collected Indirectly" and "Information Collected from Third Parties" below.

2.2 Information we collect Indirectly

In addition to the data, you provide directly, we collect certain information automatically when you use our website or services. This includes:

Usage Information: Data about how you interact with our services, such as IP address, browser type, device information, access dates and times, and pages viewed as well as from interactions with our website and mobile application. This helps us understand user behavior and improve our platform's performance.

Device Information: Technical details about your device (e.g., operating system, mobile network information, hardware specifications).

Time Spent: Data regarding time spent on job duties, tasks completed, breaks, overtime hours, remote work duration, and other time-related information for productivity and compliance purposes.

Cookies and Similar Technologies: We, along with authorized third parties, collect specific data using automated technologies such as cookies, web beacons, and server logs to gather Usage Information for analytics and operational purposes. FleetOperate tracks user interactions within its services but does not track users across external websites. A cookie is a small text file stored on your device to help maintain records and enhance your experience. When you visit or use the FleetOperate website or mobile application, we may use cookies, beacons, tags, scripts, and similar technologies to collect technical information about your device and browser, such as:

• Type of browser or mobile device used,
• Referring website or source,
• IP address or device identifier,
• Operating system details, and
• Other relevant technical information.

This data is typically collected in an anonymous form and does not directly identify you.

We use session cookies (temporary cookies that expire when you close your browser) and persistent cookies (which remain on your device for a set period) to:

• Compile statistics and analytics on how the website and app are used, including tracking access locations, visit frequency, user actions, and traffic trends.
• Collect performance data such as network activity, CPU load, and resource usage to improve the overall functionality and performance of our platform.
• Monitor user behavior to prevent fraud and other inappropriate activities.
• Gather demographic data to better understand our user base and improve user experience.

Targeting/Advertising Cookies

We may collaborate with third-party advertising partners (such as Facebook Pixel and Google AdWords) that use targeting and advertising cookies to deliver relevant advertisements based on your interests. These cookies help us:

• Track how many users click on ads,
• Monitor how many orders are placed via ads,
• Advertise our products and services across the internet, and
• Tailor marketing to suit your preferences by displaying ads that are relevant to you.

These cookies are usually placed by advertising networks with the consent of the website operator. They may remember that you have visited a specific website and share this information with advertisers and other organizations.

You can manage your cookie preferences through your browser settings, and additional details on third-party advertising cookies used in our services are provided below:

• Google AdWords: https://policies.google.com/privacy?hl=en
• Facebook Pixel: https://www.facebook.com/policies/cookies/

For more information on managing cookies, refer to the Rights and Choices section of this policy.

2.3 Information Collected from Third Parties

At times, we process personal information obtained from third parties, which may include:

• Data from partners: Such as transactional data from third-party payment service providers.
• Third-party products and services: Information from external data products, services, or integrations made available through the FleetOperate platform. This may include location data or other relevant information from service providers that have been integrated into our platform.
• Data from Customers: Customers who authorize you to access and use the FleetOperate service may provide us with personal data, including data about you as an authorized user.
• Driver Information: Data submitted by customers or authorized users regarding drivers, including details such as driver qualifications, work history, and driving records.
• Freight Brokers, Shippers, and Other Third Parties: Data from brokers, shippers, or other third-party services, as necessary, to carry out services like booking loads or fulfilling orders on behalf of customers.

Additionally, this information may include:

• Other sources of information: Such as financial records, employment history, medical records (when relevant), or other data provided by third parties.
• Government agencies: Information from state and federal government agencies, such as motor vehicle departments, credit reporting agencies, or regulatory bodies.

All information collected from third parties, whether directly from you or via external sources, is processed in accordance with this Privacy Policy and our contractual agreements.

2.4 Aggregated Data

We may process aggregated data related to your use of the FleetOperate website or services. Aggregated Data refers to data that has been compiled from individual data points but does not directly identify you. For example, we may aggregate usage data to understand how many users access a particular feature or service. While aggregated data is not considered personal data under the law, if we combine or link it with information that can identify you directly or indirectly, we will treat it as personal data and process it according to this Privacy Policy.

3. How We Use Your Information

We use your personal information for the following purposes:

• Service Provision: To deliver services such as driver profiles and qualification files; driver onboarding; driver, fleet and company records and compliance management, monitoring and up-keep; risk management, operational optimization and streamlining; and tools for overall administration, oversight aiding in compliance with the relevant regulations.
• Insurance Services: To provide tools for evaluating and processing applications for commercial auto insurance, disability insurance benefits, and other related financial services; services that support accurate insurance quotes, manage policy underwriting, process claims, assess risk profiles, and offer insurance products tailored to your needs. This involves using your driving records, vehicle data, and employment history to determine eligibility and coverage options for commercial auto and disability insurance.
• Financial Services: To offer factoring services, evaluate creditworthiness, and facilitate funding solutions for your business. This includes using your financial history, payment records, and business data to structure customized financial services that support your operations.
• Legal and Regulatory Compliance: To provide tools to assist you meet your legal obligations and ensure compliance with industry regulations.
• Processing Payments: To securely process payments for services and subscriptions.
• Communication: To contact you with updates, promotions, and important information related to our services.
• Security and Fraud Prevention: To maintain the security of our services and prevent unauthorized activities.

Legal Basis for Processing: FleetOperate processes your personal information based on the following legal grounds:

• Contractual Obligation: We process your personal information to fulfill our contract with you, such as delivering services such as but not limited to help you manage driver qualification file/s.
• Legitimate Interest: We process certain data, such as telematics data and performance data, to improve our services and maintain the safety and security of our platform.
• Consent: For marketing communications, targeted advertising, and any sensitive data collection, we rely on your explicit consent.
• Legal Compliance: We process data to help you comply with legal and regulatory obligations, such as maintaining driver records and submitting compliance documentation.

4. Third-Party Use and Disclosure

To the extent permitted by applicable law, we may disclose the personal information we collect to the following third parties:

• Affiliates, Agents, Safety and Compliance Consultants, Trucking and/or Logistics Service Providers, or Business Partners: These parties may assist us in delivering our products and services, and we may share your information with them as necessary.
• Service Providers: We may disclose personal information to third-party service providers, including but not limited to providers of website hosting, payment processing, accounting, legal, consulting, marketing, data analysis, and compliance services.
• Business Transactions: In the event of a merger, acquisition, or other business transition, we may share your personal information with purchasers, investors, or other successors.
• Legal and Governmental Authorities: We may disclose personal information to legal, governmental, regulatory, tax, or judicial authorities when required by law, a legal process, or a government request.
• Insurers, Reinsurers, Insurance Brokers, Insurance Agent, or Producers: We may disclose you personal, professional and/or any relevant information that is required to provide you services that support accurate insurance quotes, manage policy underwriting, process claims, assess risk profiles, and offer insurance products and related services tailored to your needs
• Freight brokers or shippers: We may share your personal information with third parties to fulfill services, such as sharing driver or load information with freight brokers or shippers. Please review the privacy policies of these third parties before sharing your data.
• Third-Party Integrations: If you use third-party integrations (e.g., ELD/telematics providers), your data may be shared with the relevant service providers. These third parties may have their own privacy policies, and FleetOperate is not responsible for how they use your data.
• Other Third Parties: This includes parties to whom you have authorized us to disclose your information, or where disclosure is necessary to prevent fraud, illegal activities, or violations of our terms of service, or to protect the safety and security of individuals or property.

End-Client Data Processing: When our customers use FleetOperate Services to process data of their own clients ("end-clients"), they are required to:

• Obtain appropriate authorizations from their end-clients
• Maintain documentation of such authorizations
• Manage all direct communications with their end-clients
• Handle end-client data in accordance with our Terms of Service

While FleetOperate provides the technology platform for such data processing, our customers remain primarily responsible for:

• The lawful collection of end-client data
• Maintaining appropriate relationships with their end-clients
• Responding to end-client data requests
• Ensuring compliance with applicable regulations

For more details about end-client data management requirements, please refer to our Terms of Service at https://fleetoperate.com/terms.html.

Consent for Insurance Quote Services: When you request an insurance quote through the FleetOperate platform (e.g., by clicking "Get Me QUOTE"), you expressly authorize FleetOperate to collect, use, and disclose your personal and business information—including but not limited to fleet data, driver qualification records, telematics and dashcam data, incident and claims history, safety and compliance records, and other operational information—to licensed insurance brokers, underwriters, and insurance providers for the purpose of:

• Generating insurance quotes,
• Assessing risk profiles,
• Determining underwriting eligibility,
• Managing policies or claims,
• Delivering tailored insurance products and services.

You further confirm that: You are authorized to act on behalf of your company to request quotes and provide data for insurance purposes.

You have obtained, and will retain, all necessary authorizations, consents, and disclosures from any third parties whose data is included in your submission (e.g., drivers, employees, owner-operators).

The consent you provide through this action is specific, informed, and time-bound to the insurance quoting process initiated by you.

FleetOperate does not sell your data to insurers but acts as a facilitator and service provider to support your quote request. Data is disclosed only to trusted and authorized insurance partners, and only to the extent necessary to deliver the requested quote or service.

For more information, see our Terms of Service at https://fleetoperate.com/terms.html.

Whenever we disclose personal information to third parties, we strive to minimize the scope of data shared and ensure that the third parties protect the confidentiality and security of the data. When data is transferred outside of Canada, we ensure that it is protected in accordance with applicable privacy laws, both in Canada and in the jurisdiction of the third party.

5. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect data from individuals below this age.

6. Rights and Choices

At FleetOperate, we are committed to giving you control over your personal information. This section outlines how you can manage and exercise your rights regarding the personal data we collect and process.

Updating and Correcting Personal Information

If you need to correct or update your personal information (such as your contact details), please contact us at privacy@fleetoperate.com. We will make reasonable efforts to ensure your information is updated in a timely manner. If you are an authorized user or driver whose data is processed on behalf of a FleetOperate customer, please contact the customer directly to request updates or corrections.

Direct Marketing & SMS Program

You can manage the receipt of marketing and non-transactional communications sent via email by clicking the "unsubscribe" link located at the bottom of our marketing emails. We will process your request promptly.

Cookies & Targeted Advertising

You have options regarding the use of cookies and other tracking technologies:

• Cookie Preferences: Most browsers automatically accept cookies, but you can modify your browser settings to manage cookie preferences at any time. By adjusting these settings, you may block or delete cookies. However, doing so may limit your use of certain features on our site or mobile app.
• Google Analytics: You may opt out of tracking by Google Analytics using their browser add-on at https://tools.google.com/dlpage/gaoptout.
• Do Not Track (DNT): You can enable the DNT setting in your browser, which sends a signal to websites, analytics services, and plug-ins to stop tracking your online activity. However, please note that not all companies or websites honor DNT signals. Learn more about enabling DNT here https://allaboutdnt.com/#adjust-settings.
• All About Cookies: You can learn more about managing cookies at www.allaboutcookies.org. Please note that by blocking or deleting cookies, you may not be able to use certain functionalities of the FleetOperate services.

Although you may opt out of targeting/advertising cookies, you may still see general advertisements when using our services. FleetOperate does not respond to DNT signals or similar transmissions indicating a request to disable online tracking.

Your Rights Concerning Personal Information

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request corrections to inaccurate or incomplete data.
• Deletion: Request the deletion of your personal information, subject to legal obligations.
• Restriction: Request limits on how we process your data.
• Portability: Request your personal data in a machine-readable format for transfer to another service provider.
• Object to Processing: You may object to the processing of your personal information for direct marketing purposes.

For California residents, additional rights may apply under the California Consumer Privacy Act (CCPA), including the right to opt out of the sale of your personal information. To exercise any of these rights, please contact us at privacy@fleetoperate.com.

7. Data Retention and Security

Data Retention

We process your personal information for the duration necessary to fulfill the purposes for which it was collected, comply with legal and regulatory obligations, and for any period needed to establish, exercise, or defend legal claims.

To determine appropriate retention periods for your personal information, we consider several factors, including the type, nature, and sensitivity of the data, the reasons for collecting and processing it, and any applicable legal requirements.

In some cases, instead of deleting your data, we may choose to anonymize it for purposes such as statistical analysis. If data is anonymized, we ensure that it cannot be linked back to you or any individual user.

If you are an authorized user or driver whose personal information is managed by a customer, you must contact the service provider or customer directly to request the removal of any data under their control.

Data Security

We have implemented reasonable and appropriate security measures to protect your personal information from accidental loss, unauthorized access, misuse, alteration, or disclosure. Our security measures include encryption, firewalls, secure socket layer (SSL) technology, and password protection.

Access to personal information is limited to employees, agents, contractors, and third-party service providers who have a legitimate business need to know.

PHI and HIPAA Compliance: If any personal health information (PHI) is collected as part of your employment or driver qualification (e.g., drug test results), FleetOperate has implemented HIPAA-compliant safeguards to protect this data. This includes encrypted storage, restricted access, and detailed audit logs of who accesses the data. In the event of any unauthorized access to PHI, we will notify you and the relevant regulatory bodies as required by HIPAA's Breach Notification Rule.

While we have established procedures to address any suspected data breaches, it is important to note that no method of transmission over the internet or method of electronic storage is entirely secure. By using FleetOperate's services, you acknowledge and accept the inherent risks associated with online activities.

8. Data Transfers and Cross-Border Processing

Your personal information may be transferred to and processed in jurisdictions outside your own. We ensure that appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs), to protect your personal information in compliance with applicable laws, including PIPEDA, GDPR, and other relevant regulations.

Cross-Border Transfers: When transferring your personal data outside of Canada or the European Economic Area (EEA), we ensure that appropriate safeguards are in place to protect your data. These safeguards include the use of Standard Contractual Clauses (SCCs) approved by the European Commission, which provide lawful grounds for transferring personal information to jurisdictions that may not have equivalent data protection laws. We also assess the adequacy of the receiving country's data protection measures and ensure compliance with GDPR.

9. Payment Processing

FleetOperate does not directly collect or store your payment information. Instead, we rely on third-party, PCI-compliant payment processors to handle payment transactions securely on our behalf. These payment processors collect and process your payment information to complete transactions. FleetOperate administrators have access only to limited transaction details, which are available through the payment processors' secure portals.

10. Sensitive Data

FleetOperate does not require you to provide any sensitive personal information to use our website or services. This includes data related to your race or ethnicity, religious or philosophical beliefs, sexual orientation, sex life, political opinions, trade union membership, health information, genetic data, or biometric data.

11. External Websites

FleetOperate's website may include links to third-party websites that are not operated or controlled by FleetOperate ("External Websites"). By clicking on these links, the operators of these external websites may collect your personal information. We are not responsible for the content, security, or privacy practices of these External Websites. Your interactions with any External Websites are governed by their own terms of use and privacy policies.

12. Data Breach Notification

In the event of a data breach that compromises your personal information, FleetOperate will notify affected individuals and relevant authorities in compliance with applicable law. If applicable, under GDPR, we will notify you within 72 hours if a breach poses a high risk to your rights and freedoms. If the breach involves personal health information (PHI), we will also notify you as required by HIPAA, detailing the type of information affected and the steps we have taken to mitigate the risk.

13. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. We will notify you of any significant changes by posting the updated policy on our website.

Last Updated: June 09, 2025