PREMIER RIDE & TRAVELINGOO

GLOBAL DRIVER, CHAUFFEUR & NETWORK PARTNER PRIVACY NOTICE

Effective Date: September 17, 2026  |  Version: 1.0 (Enterprise Standard)  |  Governing Entities: Premier Ride Inc. & Travelingoo Co.

This Driver Privacy Notice ("Notice") is issued jointly by Premier Ride Inc. (dispatch technology, fleet management, and administrative services) and Travelingoo Co. (customer booking portal and transaction merchant) (collectively, "Platform Parties," "we," "us," or "our"). This Notice describes how we collect, process, use, store, disclose, and protect personal data belonging to independent drivers, professional chauffeurs, fleet operators, dispatchers, applicants, and network affiliate personnel (collectively, "Driver," "you," or "your") who apply for, access, or use the Premier Ride Driver Mobile Application, backend portals, telematics systems, and related technology services (collectively, the "App").

Scope & Enterprise Applicability: This Notice applies globally across all jurisdictions where Premier Ride services operate, including the United States (specifically Texas, California, and all operating states), the United Kingdom, the European Union, and international locations. This Notice operates in conjunction with the Premier Ride Driver App Terms and Conditions and any applicable Independent Driver or Affiliate Service Agreement.

1. Categories of Information We Collect

We collect personal data directly from you, automatically through your mobile device, vehicle telematics, and platform interactions, and from authorized third-party business partners and government registries.

A. Direct Identification & Credential Data

• Identity & Contact Records: Legal full name, preferred name, profile photograph, residential address, mobile phone number, email address, Social Security Number (SSN) or Tax Identification Number (TIN), emergency contact details, and date of birth.
• Credential & Regulatory Documentation: State driver's license details, commercial chauffeur permits, airport/port authority credentials, work authorization documentation, passport copies (for international operations), and medical examiner certificates.
• Financial & Payout Data: Direct deposit routing and account numbers, banking verification documentation, wire transfer instructions, tax reporting forms (e.g., IRS Form W-9, Form 1099-NEC, or international equivalents), completed trip earnings, wait-time fees, toll/expense reimbursements, and chargeback adjustments.

B. Screening & Background Verification Data

• Motor Vehicle & Criminal Records: Motor vehicle records (MVR), driving history reports, traffic violation logs, criminal history background checks, sex offender registry checks, and global sanctions / PEP screening results.
• Biometric Facial Identity Data: Live selfie photograph captures, facial geometry scans, and mathematical liveness comparison metrics collected during onboarding and periodic identity checks.

C. Geolocation, Telematics & Vehicle Data

• Precise Geolocation Data: High-accuracy GPS coordinates, movement trajectory, altitude, speed, and heading collected while the App is open or running in the background when marked online, available, en route, on location, or performing an active Trip.
• Vehicle & Fleet Information: Vehicle make, model, year, color, Vehicle Identification Number (VIN), license plate number, vehicle registration certificate, state/local inspection certificates, maintenance records, passenger capacity class, and vehicle amenity indicators.
• Commercial Insurance Documentation: Commercial auto liability insurance policies, policy numbers, coverage limits, Certificate of Insurance (COI), named driver endorsements, and claims history.

D. App Usage, Telematics & Operational Communications

• Operational Telematics & Motion Data: Accelerometer signals, braking force, cornering metrics, device orientation, signal strength, battery status, and network connectivity logs during active service windows.
• In-App & Platform Communications: In-app text messaging logs, masked VoIP call metadata, timestamped trip status updates (en route, on location, passenger on board, trip completed), dispatch notes, lost item reports, and customer support ticket records.
• Passenger Ratings & Feedback: Numerical star ratings, service tags, customer feedback comments, and quality assurance audit scores.

2. Sensitive Personal Information (SPI) Disclosures

Under applicable state privacy legislation (including the Texas Data Privacy and Security Act - TDPSA, California Consumer Privacy Act / CPRA, and similar laws), certain data elements we collect are categorized as Sensitive Personal Information (SPI):

• Social Security Numbers, Driver's License Numbers, Passport Numbers, and government ID credentials.
• Precise geolocation data (accurate within a radius of 1,850 feet or less).
• Biometric facial geometry data processed for real-time driver identity authentication.
• Account login credentials combined with passwords, passcodes, or security questions.

Strict Processing Limits: We process SPI strictly to perform essential platform operations, verify driver identity, maintain safety and regulatory compliance, process payouts, and protect system integrity. We do not sell, rent, or share Sensitive Personal Information for cross-context behavioral advertising or commercial profiling.

3. Third-Party Software Development Kits (SDKs) & Diagnostic Tools

The Premier Ride Driver App embeds software development kits (SDKs), application programming interfaces (APIs), and system libraries provided by vetted third-party technology vendors to deliver navigation, security, and diagnostic services:

4. Legal Bases for Processing (GDPR / UK GDPR & International Compliance)

When operating in or processing data belonging to drivers located in the European Union, European Economic Area, United Kingdom, or other international jurisdictions enforcing data protection frameworks, we rely on the following lawful bases under Article 6 and Article 9 of the GDPR:

• Performance of Contract (Art. 6(1)(b)): Necessary to execute the Driver App Terms, process trip assignments, calculate rates, issue biweekly payouts, and facilitate transportation logistics.
• Compliance with Legal Obligations (Art. 6(1)(c)): Required to adhere to tax withholding/reporting laws, commercial carrier regulations, airport authority rules, anti-money laundering (AML) controls, and law enforcement mandates.
• Legitimate Business Interests (Art. 6(1)(f)): Necessary to protect passenger and chauffeur safety, prevent platform fraud, secure account credentials, maintain app stability, defend against legal claims, and improve service quality.
• Explicit Consent (Art. 6(1)(a) & Art. 9(2)(a)): Required for processing biometric facial scans, background location tracking outside active trip windows, and marketing communications (where applicable). Consent may be withdrawn at any time.

5. Automated Decision-Making, Dispatch & Profiling

Premier Ride utilizes automated system logic and algorithms to assist with trip allocation, routing estimates, and fraud detection. However, we maintain strict policy safeguards regarding automated decisions:

• Trip Offer Matching: Offer distribution considers proximity, vehicle class, driver rating, and schedule availability. Declining a trip offer does not result in automated account termination.
• Deactivation Safeguards & Human Review: Automated flags (e.g., location anomalies or selfie mismatches) do not result in permanent deactivation without human review. A qualified Premier Ride compliance reviewer evaluates the underlying evidence, context, and driver explanations before any final suspension or termination decision is issued.
• Right to Contest Automated Decisions: Drivers have the right to request manual human review of any adverse automated determination by submitting an appeal request through the App support portal within 14 days.

6. Biometric Data Processing & Wiretap / Dashcam Policies

A. Biometric Data Notice

To prevent account sharing, identity impersonation, and safety risks, the App requires periodic live selfie uploads. These images are analyzed using automated facial recognition algorithms to verify that the active driver matches the registered account holder.

Biometric Retention & Destruction Mandate: Biometric facial scans and mathematical feature templates are retained only for the duration necessary to verify identity (typically processed within seconds) and in no event longer than thirty (30) days following account termination, unless a legal hold or court order requires extended preservation. Biometric data is stored in encrypted format and is never sold or disclosed to unauthorized parties.

B. Dashcam, Audio & Video Surveillance Compliance

If a driver or fleet operator utilizes a dashcam or cabin recording device inside a vehicle performing Premier Ride trips, the driver is solely responsible for strictly adhering to applicable local, state, national, and international wiretap and eavesdropping laws (e.g., two-party consent laws in California, Florida, etc.). Drivers must display visible notice signage in the vehicle where required by law and obtain necessary consent from passengers prior to audio/video recording.

7. Data Disclosures & Third-Party Sharing

We share Driver Data only with authorized parties under strict contractual confidentiality obligations:

• With Passengers & Travel Bookers: Chauffeur name, profile photograph, vehicle make/model/color/plate, contact masking connection, and real-time GPS location/ETA during an active trip.
• With Affiliates & Fleet Operators: Trip completion logs, earnings breakdowns, safety alerts, ratings, and credential renewal reminders associated with drivers operating under a fleet account.
• With Regulatory & Airport Authorities: Driver and vehicle details required to obtain airport staging permits, port access, or comply with local transportation authority reporting obligations.
• For Legal Protection & Claims: Insurers, claims adjusters, legal counsel, law enforcement, or courts in response to crashes, bodily injury claims, subpoenas, search warrants, or formal legal discovery.

8. International Data Transfers

Premier Ride Inc. and Travelingoo Co. are headquartered in Texas, United States. Driver Data collected globally may be transferred to, stored, and processed on secure servers located in the United States and other global cloud data centers.

To safeguard cross-border transfers from the EU, EEA, UK, and Switzerland to the U.S., we implement standard legal transfer mechanisms, including the European Commission Standard Contractual Clauses (SCCs), the UK International Data Transfer Agreement (IDTA), and compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) requirements. These mechanisms obligate US data recipients to maintain data protections equivalent to European privacy standards.

9. Comprehensive Data Retention Schedule

We retain personal data only as long as necessary to fulfill operational, contractual, legal, tax, and insurance obligations. Specific retention windows are defined below:

10. Your Privacy Rights & Regional Addenda

Depending on your state or country of residence, you possess specific legal rights regarding your personal data:

A. Rights under Texas (TDPSA), California (CPRA) & US State Privacy Laws

• Right to Know & Access: Request details regarding categories of data collected, sources, processing purposes, and specific data items held.
• Right to Correction: Request correction of inaccurate, outdated, or incomplete personal records.
• Right to Deletion: Request erasure of personal data, subject to mandatory legal, tax, insurance, and fraud-prevention retention exceptions.
• Right to Opt-Out of Sale/Sharing & Targeting: We do not sell driver data or share it for cross-context behavioral advertising. You have the right to confirm this non-sale status.
• Non-Discrimination: We will not retaliate, downgrade service, or deny platform access to any driver for exercising statutory privacy rights.

B. Rights under GDPR / UK GDPR

In addition to access, correction, and erasure, European drivers have the right to Data Portability (receiving data in a structured, machine-readable format), the right to Restrict Processing, and the right to Lodge a Complaint with a supervisory authority (such as the UK Information Commissioner's Office - ICO or an EU Data Protection Authority).

11. Fair Credit Reporting Act (FCRA) Interplay

Standalone FCRA Disclosure Notice: Background checks, criminal history reviews, and motor vehicle records (MVR) obtained for driver eligibility screening are conducted pursuant to the Fair Credit Reporting Act (FCRA) and applicable state background check laws. FCRA disclosures, authorizations, pre-adverse action notices, and adverse action rights are provided to you through a separate, standalone statutory document during onboarding and are not superseded by this Privacy Notice.

12. Age Restrictions & Minors Policy

The Premier Ride Driver App and platform are strictly intended for professional drivers and transportation personnel who are at least 18 years of age (or 21 years of age where required by vehicle class, airport authority, or commercial insurance policy). We do not knowingly solicit, collect, or maintain personal data from individuals under 18 years of age for driver accounts. If we discover an account registered by a minor, access will be revoked and data purged immediately.

13. Data Security Safeguards

We maintain comprehensive technical, physical, and administrative security measures to protect Driver Data. These include end-to-end TLS encryption for data in transit, AES-256 encryption for data at rest, strict role-based access controls, multi-factor authentication, quarterly vulnerability scans, and continuous threat monitoring. In the event of a confirmed security incident affecting your data, we will provide notification in accordance with applicable state and federal breach notification laws.

14. Revisions to This Privacy Notice

We reserve the right to update this Notice prospectively to reflect changes in legal requirements, technology, or platform operations. When material changes occur, we will notify you through an in-app banner, email notification, or pop-up consent prompt prior to the effective date. Continued use of the Driver App after the effective date constitutes acknowledgment of the revised Notice.

15. Contact Information & Data Protection Officer

If you have questions, wish to submit a Data Subject Access Request (DSAR), or seek to exercise any privacy right, contact our Privacy Compliance Team: