JOLTCAB USER PRIVACY POLICY

Last Updated: January 10, 2025

Effective Date: January 10, 2025

INTRODUCTION

JoltCab Inc. ("JoltCab," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our mobile application, website, and services (collectively, the "Services").

By using the Services, you consent to the data practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services.

1. INFORMATION WE COLLECT

1.1 Information You Provide

Account Information:

- Full name

- Email address

- Mobile phone number

- Date of birth

- Profile photo (optional)

- Password (encrypted)

Payment Information:

- Credit/debit card numbers (tokenized)

- Billing address

- Payment history

- Transaction records

Trip Information:

- Pickup and drop-off locations

- Trip routes and distances

- Trip dates and times

- Fare amounts

- Trip purposes (if provided)

Communications:

- Customer support messages

- Feedback and reviews

- Survey responses

- Promotional preferences

1.2 Information Collected Automatically

Device Information:

- Device type and model

- Operating system and version

- Unique device identifiers

- Mobile network information

- IP address

- Browser type and version

Location Information:

- Precise GPS location (when app is in use)

- Approximate location (when app is in background)

- Pickup and drop-off addresses

- Route information

- Location history

Usage Information:

- App features used

- Pages viewed

- Time spent on pages

- Search queries

- Interaction with notifications

- App crashes and errors

Sensor Data:

- Accelerometer data

- Gyroscope data (for safety features)

1.3 Information from Third Parties

Social Media:

- If you connect your social media accounts, we may collect profile information

Payment Processors:

- Payment verification and fraud prevention data

Background Check Providers:

- Information about Drivers (not applicable to Users)

Marketing Partners:

- Information about how you interact with our advertisements

2. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

2.1 Providing Services

- Processing and facilitating ride requests

- Matching you with Drivers

- Calculating fares and processing payments

- Providing customer support

- Sending trip receipts and confirmations

- Enabling real-time tracking

- Facilitating communication between you and Drivers

2.2 Safety and Security

- Verifying your identity

- Detecting and preventing fraud

- Monitoring for suspicious activity

- Investigating accidents and incidents

- Complying with legal obligations

- Enforcing our Terms and Conditions

- Protecting against security threats

2.3 Improving Services

- Analyzing usage patterns and trends

- Conducting research and development

- Testing new features

- Improving app performance

- Optimizing routes and pricing

- Personalizing your experience

2.4 Marketing and Communications

- Sending promotional offers and updates

- Providing personalized recommendations

- Conducting surveys and market research

- Sending service announcements

- Displaying targeted advertisements

2.5 Legal and Compliance

- Responding to legal requests and court orders

- Complying with regulatory requirements

- Protecting our legal rights

- Resolving disputes

- Enforcing our agreements

3. HOW WE SHARE YOUR INFORMATION

We may share your information with the following parties:

3.1 Drivers

When you request a ride, we share:

- Your first name and last initial

- Pickup and drop-off locations

- Your phone number (masked)

- Your profile photo

- Your rating

3.2 Service Providers

We share information with third-party vendors who perform services on our behalf:

- Payment processors (Stripe, PayPal)

- Cloud storage providers (AWS, Google Cloud)

- Analytics providers (Google Analytics, Mixpanel)

- Customer support tools (Zendesk, Intercom)

- Marketing platforms (Mailchimp, SendGrid)

- Mapping services (Google Maps, Mapbox)

3.3 Business Partners

- Insurance companies (for claims processing)

- Fleet partners

- Marketing and advertising partners

3.4 Legal Authorities

We may disclose information to:

- Law enforcement agencies

- Government authorities

- Courts and legal counsel

- Regulatory bodies

When required by law or to:

- Comply with legal process

- Respond to government requests

- Protect our rights and property

- Prevent fraud or illegal activity

- Protect user safety

3.5 Business Transfers

In the event of a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the successor entity.

3.6 With Your Consent

We may share information with other parties when you provide explicit consent.

4. YOUR CHOICES AND RIGHTS

4.1 Account Information

- You can review and update your account information in the app settings

- You can delete your account at any time

4.2 Location Information

- You can enable or disable location services in your device settings

- Location is required to use ride services

- You can choose to share your location only while using the app

4.3 Marketing Communications

- You can opt out of promotional emails by clicking "unsubscribe"

- You can disable push notifications in app settings

- You cannot opt out of service-related communications

4.4 Cookies and Tracking

- You can control cookies through your browser settings

- You can opt out of interest-based advertising

- Disabling cookies may limit app functionality

4.5 Data Access and Portability

You have the right to:

- Request a copy of your personal information

- Download your trip history

- Request data in a machine-readable format

4.6 Data Correction

You have the right to:

- Correct inaccurate information

- Update incomplete information

- Request deletion of certain data

4.7 Data Deletion

You have the right to request deletion of your personal information, subject to:

- Legal retention requirements

- Pending transactions or disputes

- Safety and security concerns

To exercise these rights, contact us at info@joltcab.net.

5. DATA RETENTION

We retain your information for as long as necessary to:

- Provide the Services

- Comply with legal obligations

- Resolve disputes

- Enforce our agreements

Retention periods:

- Account information: Until account deletion + 7 years

- Trip data: 7 years (for legal and tax purposes)

- Payment information: 7 years (for financial records)

- Location data: 1 year (unless required for disputes)

- Communications: 3 years

- Marketing data: Until you opt out + 1 year

After retention periods expire, we will delete or anonymize your information.

6. DATA SECURITY

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

Technical Measures:

- Encryption in transit (TLS/SSL)

- Encryption at rest (AES-256)

- Secure authentication protocols

- Regular security audits

- Intrusion detection systems

- Firewalls and access controls

Organizational Measures:

- Employee training on data protection

- Access controls and authorization

- Confidentiality agreements

- Incident response procedures

- Regular security assessments

However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your information.

7. CHILDREN'S PRIVACY

The Services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at info@joltcab.net, and we will delete the information.

8. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

When we transfer data internationally, we implement appropriate safeguards:

- Standard contractual clauses

- Privacy Shield certification (where applicable)

- Adequacy decisions by regulatory authorities

9. CALIFORNIA PRIVACY RIGHTS

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

9.1 Right to Know

You have the right to request:

- Categories of personal information collected

- Sources of personal information

- Business purposes for collecting information

- Categories of third parties with whom we share information

- Specific pieces of personal information collected

9.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions.

9.3 Right to Opt-Out

You have the right to opt out of the sale of your personal information. Note: JoltCab does not sell personal information.

9.4 Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your CCPA rights.

To exercise these rights, contact us at info@joltcab.net or call 1-800-JOLTCAB.

We will verify your identity before processing requests. We will respond within 45 days.

10. NEVADA PRIVACY RIGHTS

Nevada residents have the right to opt out of the sale of certain personal information. JoltCab does not sell personal information as defined by Nevada law. If you have questions, contact us at info@joltcab.net.

11. EUROPEAN ECONOMIC AREA (EEA) RIGHTS

If you are in the EEA, you have additional rights under the General Data Protection Regulation (GDPR):

11.1 Legal Basis for Processing

We process your information based on:

- Contractual necessity (to provide Services)

- Legitimate interests (to improve Services and prevent fraud)

- Legal obligations (to comply with laws)

- Consent (for marketing and optional features)

11.2 Your Rights

- Right of access

- Right to rectification

- Right to erasure ("right to be forgotten")

- Right to restrict processing

- Right to data portability

- Right to object to processing

- Right to withdraw consent

- Right to lodge a complaint with a supervisory authority

To exercise these rights, contact us at info@joltcab.net.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of material changes by:

- Posting the updated Privacy Policy in the app

- Sending an email to your registered email address

- Displaying a notice when you next access the Services

The "Last Updated" date at the top of this Privacy Policy indicates when it was last revised. Your continued use of the Services after changes take effect constitutes acceptance of the updated Privacy Policy.

13. CONTACT US

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

JoltCab Inc.

Attn: Privacy Officer

Email: info@joltcab.net

Website: www.joltcab.net

For California residents:

Phone: 1-800-JOLTCAB (toll-free)

For EEA residents:

Data Protection Officer: dpo@joltcab.net

14. ADDITIONAL DISCLOSURES

14.1 Do Not Track

Some browsers have "Do Not Track" features. Currently, there is no industry standard for responding to Do Not Track signals. JoltCab does not respond to Do Not Track signals at this time.

14.2 Third-Party Links

The Services may contain links to third-party websites or services. This Privacy Policy does not apply to third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

14.3 Social Media Features

The Services may include social media features (e.g., Facebook Like button). These features may collect your IP address and set cookies. Your interactions with these features are governed by the privacy policies of the companies providing them.

14.4 Analytics and Advertising

We use third-party analytics and advertising services:

Google Analytics:

- Collects usage data and demographics

- Opt out: https://tools.google.com/dlpage/gaoptout

Facebook Pixel:

- Tracks conversions and ad performance

- Opt out: https://www.facebook.com/settings/?tab=ads

Adjust:

- Tracks app installs and attribution

- Opt out: https://www.adjust.com/opt-out/

15. DATA BREACH NOTIFICATION

In the event of a data breach that affects your personal information, we will:

- Notify you within 72 hours of discovering the breach

- Describe the nature of the breach

- Explain the potential consequences

- Describe the measures taken to address the breach

- Provide recommendations to protect yourself

- Notify relevant authorities as required by law

16. AUTOMATED DECISION-MAKING

We use automated decision-making for:

- Matching you with Drivers

- Calculating fares

- Detecting fraud

- Personalizing offers

You have the right to request human review of automated decisions that significantly affect you.

17. BIOMETRIC INFORMATION

JoltCab does not currently collect biometric information (e.g., fingerprints, facial recognition) from Users. If we implement biometric features in the future, we will update this Privacy Policy and obtain your consent where required by law.

18. SENSITIVE INFORMATION

We do not intentionally collect sensitive personal information such as:

- Social Security numbers

- Financial account numbers (except tokenized payment information)

- Health information

- Racial or ethnic origin

- Political opinions

- Religious beliefs

- Sexual orientation

If you provide sensitive information voluntarily (e.g., in customer support messages), we will handle it in accordance with this Privacy Policy and applicable laws.

19. YOUR CALIFORNIA PRIVACY RIGHTS - SHINE THE LIGHT LAW

California Civil Code Section 1798.83 permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, contact us at info@joltcab.net.

20. ACCESSIBILITY

We are committed to making our Privacy Policy accessible to everyone. If you have difficulty accessing this Privacy Policy, please contact us at info@joltcab.net, and we will provide the information in an alternative format.

© 2025 JoltCab Inc. All rights reserved.