TruckBase, Inc

Effective: December 16, 2024

This Privacy Policy (the “Privacy Policy”) serves to inform you of our policies and procedures regarding

the collection, use and disclosure of the information we receive when you access and use the website

(the “Site”), services, software, mobile applications, content, and all other products and services (all of

the foregoing collectively, the “Services”) owned, controlled or offered, directly or indirectly, by

TruckBase, Inc (together with its subsidiaries and affiliates, “TruckBase”, “we,” “our” or “us”). TruckBase

believes that the privacy of its users is paramount and strives to use Personal Information (as defined

below) only in ways outlined in this Privacy Policy. The Privacy Policy is incorporated by reference into

our Terms of Service, currently available at app.truckbase.com/terms-of-service (the “Terms of Service”).

Any terms used herein and not defined will have the meanings given to them in the Terms of Service. By

using the Services, you hereby warrant and represent that you have read, understand and agree to this

18 years of age. PLEASE DO NOT USE, INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS

1. What We Mean by Personal Information

For purposes of this Privacy Policy, “Personal Information” means any information from or about a

person that either identifies that person directly or that makes that person identifiable when it is

combined with other information from or about that person from any source.

2. Information We Collect

Information You Provide To Us

When you use the Services or otherwise communicate with us, we collect information that you provide

to us directly. For example, we collect information in the following circumstances: you (i) use our mobile

apps or visit the Site, (ii) register for the Services or create an account or profile or accept the creation of

an account or profile on your behalf (an “Account”), (iii) access the Services through social networking

sites or third party services, (iv) subscribe to newsletters; (v) purchase a product or service on the Site or

in our mobile apps; (vi) invite your friends to join the Services, “share” the Services on social networking

sites or perform other similar actions; (vii) request technical support; (viii) otherwise use our mobile

apps or online Services where Personal Information is required for such use and/or participation, (ix)

when you sign up for a newsletter, and (x) when you contact us via the Site or when you otherwise

communicate with us. You can choose not to provide information that is requested of you by us;

however, this may limit your ability to use or access the Services.

The information you provide to us directly may include, without limitation, the following information

that may, alone or in combination with other data, constitute Personal Information:

● Information you provide in connection with registering an account or completing a transaction

or purchase using the Services, including your name, e-mail, physical address, phone number,

and any other information you decide to provide;

● Information you provide via email or by using the contact details listed on various parts of the

Site, including your name, company name, e-mail, phone number, physical address, inquiry, and

any other information you decide to provide;

● Information you upload or otherwise make available to us or to other users while using the

Service including your name, e-mail, phone number, physical address and other information you

share while using the Service.

● Information you provide in order to subscribe to our newsletters and updates, including your

email address, the topic for which you wish to receive updates, or any other information you

decide to provide us with. You may always unsubscribe from these emails by following the

instructions included;

● If you are one of our customers, suppliers or prospects, we may process limited Personal

Information in the course of our business relation with you, for example when you place an

order, request a demo or vice versa. Such Personal Information may include your name,

company, title, e-mail address, telephone number, address, order details, and where applicable

and relevant, credit registrations and credit limits;

● Transaction and limited (non-PCI) payment data; and

● Any other information you may want to share with us.

Moreover, if you contact us, a record of such correspondence may be kept.

Additionally, if another user refers you to us by providing us with your e-mail address, we may send you a

message. However, we will use your e-mail address only to send such other user’s message unless you

otherwise affirmatively provide your information to us.

Automatically Collected Information

Most of the data we collect in and through the Site and the Services is technical in nature and is

collected and processed automatically through so-called application programming interfaces, software

development kits, cookies and similar software-based technologies. Alone or in combination with other

data, such automatically collected data may constitute Personal Information. The data we may collect by

automated means may include, without limitation:

● Device data: including, but not limited to, data on device advertising ID’s and similar hardware

qualifiers, and precise location data.

● Usage data: including, but not limited to, search terms entered and pages viewed.

● Network and internet information: including, but not limited to, URLs, Internet Protocol

addresses, bounce rates, use of spoofing, active (TCP/IP) ports, number of sessions initiated, click

streams, location information and network/Wi-Fi access points.

● Information we collect on the use of the Site via cookies: please see the “How We Use Cookies

and Other Technologies” section below for more information.

We may use, depending on the Services, (i) location based on the IP address presented by you, (ii)

network-based geo-location data based on proximity of network towers or the location of Wi-Fi

networks, and/or (iii) geo-location data based on coordinates obtained from a mobile device’s GPS radio

and location services. Your GPS geo-location is accessed in accordance with your device settings. If

location services are enabled on your mobile device and/or a mobile application in connection with the

Services, certain of the Services will passively and automatically send location information to TruckBase

in order to for us to deliver location-specific information on your device and compile your individualized

timeline. Please note that disabling location service will not anonymize data already collected and

uploaded to our servers.

Google Analytics is an element of the Site. By using cookies, Google Analytics collects and stores data

such as time of visit, pages visited, time spent on each page of the Site, the Internet Protocol address,

and the type of operating system used in the devices used to access the Site. By using a browser plugin

available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of

Google Analytics.

Information You Post on the Services

The Services may provide direct messaging, photo and document sharing, chat, forum or bulletin board

tools to users and the ability to create an “avatar” or other customized profile and Account information.

Information that you provide through the use of these tools will be available to the public generally.

TruckBase has no obligation to keep private any information that you disclose to other users or the

public using these functions. You should exercise caution when deciding to disclose Personal Information

through the use of these tools or functions. We strongly recommend that you do not post any

information through the Services that allows strangers to identify or locate you or that you otherwise do

not want to share with the public.

Information You Share on Third Party Websites or through Social Media Services

The Services may include links to third party websites and social media services where you will be able to

post comments, stories, reviews or other information. Your use of these third party websites and social

media services may result in the collection or sharing of information about you by these third party

websites and social media services. We encourage you to review the privacy policies and settings on the

third party websites and social media services with which you interact to make sure you understand the

information that may be collected, used, and shared by those third party websites and social media

services.

How We Use Cookies and Other Technologies

Some of the features on the Site and the Services require the use of “cookies” - small text files that are

stored on your device’s hard drive. We use cookies to measure which pages are being accessed, and

which features are most frequently used. This enables us to continuously improve the Site to meet the

needs of our visitors.

The following sets out how we may use different categories of cookies and your options for managing

cookie settings:

Type of Cookies

Description

Managing Settings

Required

Required cookies enable you to navigate the

Site and use their features, such as accessing

secure areas of the Site and using the Services.

If you have chosen to identify yourself to us,

we use cookies containing encrypted

information to allow us to uniquely identify

you. These cookies allow us to uniquely

identify you when you are logged into the Site

and to process your online transactions and

requests.

Because required cookies are

essential to operate the Site,

there is no option to opt out of

these cookies.

Performance

These cookies collect information about how

you use our Sites, including which pages you

go to most often and if they receive error

messages from certain pages. These cookies

do not collect information that individually

identifies you. Information is only used to

improve how the Site function and perform.

From time-to-time, we may engage third

parties to track and analyze usage and volume

statistical information relating to individuals

who visit the Site. We may also utilize Flash

cookies for these purposes.

To learn how to opt out of

performance cookies using your

browser settings, click here. To

learn how to manage privacy and

storage settings for Flash cookies,

click here.

Functionality

Functionality cookies allow our Sites to

remember information you have entered or

choices you make (such as your username,

language, or your region) and provide

enhanced, more personal features. These

cookies also enable you to optimize your use

of the Site after logging in. These cookies can

also be used to remember changes you have

made to text size, fonts and other parts of web

pages that you can customize. We may use

local shared objects, also known as Flash

cookies, to store your preferences or display

content based upon what you view on the Site

to personalize your visit.

To learn how to opt out of

functionality cookies using your

browser settings, click here. To

learn how to manage privacy and

storage settings for Flash cookies,

click here.

Targeting or

advertising

From time-to-time, we may engage third

parties to track and analyze usage and volume

statistical information from individuals who

visit the Site. We sometimes use cookies

delivered by third parties to track the

performance of our advertisements. For

example, these cookies remember which

browsers have visited the Site. By way of

To learn more about these and

other advertising networks and

their opt out instructions, click

here. To learn how to manage

privacy and storage settings for

Flash cookies, click here.

example, as you browse the Site, advertising

cookies may be placed on your computer so

that we can understand what you are

interested in. Our advertising partners then

enable us to present you with retargeted

advertising on other sites based on your

previous interaction with the Site. Third

parties, with whom we partner to provide

certain features on the Site or to display

advertising based upon your web browsing

activity, use Flash cookies to collect and store

information. Flash cookies are different from

browser cookies because of the amount of,

type of, and how data is stored.

We and our service providers may also use “pixel tags,” “web beacons,” “clear GIFs,” or similar means in

connection with the Services and HTML-formatted email messages to, among other things, track the

actions of users, to determine the success of marketing campaigns and to compile aggregate statistics

about Site usage and response rates. Our advertisement partners may use a “pixel tag” to collect

anonymous information about your visits to the Site and to other websites, and they may use that

information to target advertisements for goods and services. This information is collected anonymously,

in a manner that does not personally identify you.

3. Use of Collected Information

We use the information you provide to us for the following purposes: (i) to further our legitimate

interests in providing the Services, including without limitation to collect and remit payment for paid

features, (ii) to administer your use of the Services and any Accounts you may have with us, (iii) to

personalize your experience, (iv) to provide to you Service announcements or inform you of new releases

and features, (v) to provide you with further information and offers from us or third parties that we

believe you may find useful or interesting, such as newsletters, marketing or promotional materials, (vi)

to perform tasks on behalf of and according to instructions of a third party, such as payment processors

or third party-service providers, (vii) to enforce our Terms of Service, (viii) to resolve any disputes

between users of the Site or between such users and us, (ix) comply with a legal requirement or process,

including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures;

(x) to further our legitimate interest in protecting our rights, property, or safety and the rights, property

and safety of the Services, our users or the public, and (xi) to contact you to obtain feedback from you or

to provide updates regarding the Site and the Services.

In addition to the purposes described above, we use the information collected automatically to (i) to

further our legitimate interests in monitoring and analyzing the use of the Services and for the technical

administration of the Site, (ii) improve the Site and the Services, (iii) generate and derive useful data and

information concerning the interests, characteristics and website use behavior of our users, and (iv)

verify that users of the Services meet the criteria required to process their requests. We and or our

advertising partners may use demographic and geo-location, as well as information logged from your

hardware or device, including data such as IP address, device model and ID, MAC address, operating

system, application usage data, device time zone, region and language, and click ID, to ensure relevant

advertising is presented within the Services.

4. Third Parties We Share Personal Information With

We may disclose Personal Information you provide to us or that we collect automatically on the Site and

in and through the Services with the following categories of third parties:

● Service providers, such as payment processors, web hosting and data storage service providers,

and helping us deliver and develop the Services. data storage service providers, marketing

service providers, and communications service providers;

● Public authorities, such as law enforcement, if we are legally required to do so or if we need to

protect our rights or the rights of third parties; and

● Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Site and/or

the Services and their advisors in connection with a corporate merger, consolidation,

restructuring, the sale of substantially all of our stock and/or assets, or in connection with

bankruptcy proceedings, or other corporate reorganization, in accordance with this Privacy

Policy.

Mobile information will not be shared with third parties/affiliates for marketing/promotional purposes.

Text messaging originator opt-in data and consent information will not be shared with any other third

parties.

5. Links to Other Websites

We may make content or services from other websites available to you from links located on the Site. We

may present links in a format that enables us to keep track of whether these links have been followed.

This Privacy Policy applies only to the Site and the Services. We do not exercise control over third party

services or other websites that provide information, or links from within the Site or the Services. Your

interactions with these third party services are governed by the privacy policy of the company providing

it. These other sites and services may place their own cookies or other files on your computer’s browser,

collect data or solicit Personal Information from you. Other websites and services follow different rules

regarding the use or disclosure of the Personal Information that you submit, and the collection and use

of such information and access of any third party websites are subject to such third party’s privacy policy.

We encourage you to read the privacy policies and other terms of such third parties before using their

services.

6. Security

We understand the importance of privacy and security of Personal Information to our users and have

made them a priority. TruckBase uses a variety of industry-standard security technologies and

procedures to help protect Personal Information about you from unauthorized access, use, or disclosure

and trains TruckBase employees on privacy and security issues. However, we cannot guarantee that

unauthorized third parties will never be able to overcome those measures or use your Personal

Information for improper purposes, and we do not promise that Personal Information about you or

private communications will be protected from unauthorized disclosure or use.

7. Do Not Track Signals and Similar Mechanisms

TruckBase does not track its customers over time and across third party websites to provide targeted

advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party

sites do keep track of your browsing activities when they serve you content, which enables them to tailor

what they present to you.

8. Managing Your Privacy

We keep your data on your behalf and for your benefit. You can correct or terminate and delete your

Account information by following the instructions on the Services or by e-mail at

support@truckbase.com, which you may also access for further assistance and questions regarding the

information, TruckBase will limit its access to Personal Information to perform what is requested by you

and will delete information accessible to TruckBase within seven business days.

9. California Residents

California Civil Code Section 1798.83 requires certain businesses that share customer Personal

Information with third parties for the third parties’ direct marketing purposes to respond to requests

from California customers asking about the businesses’ practices related to such information-sharing. We

currently do not share or disclose your Personal Information to third parties for the third parties’ direct

marketing purposes. If we change our practices in the future, we will implement an opt-out policy as

required under California laws.

Furthermore, subject to certain exemptions, California residents have the following rights with respect to

Personal Information we may have collected about them:

Requests to Know

You have the right to request that we disclose:

● The categories of Personal Information we have collected about you;

● The categories of Personal Information about you we have sold or disclosed for a business

purpose;

● The categories of sources from which we have collected Personal Information about you;

● The business or commercial purposes for selling or collecting Personal Information about you;

● The categories of Personal Information sold or shared, if any, about you, as well as the categories

of third parties to whom the Personal Information was sold, by category of Personal Information

for each party to whom Personal Information was sold; and

● The specific pieces of Personal Information collected.

You may submit a request to know via https://forms.gle/sVT8SL1koD9HhPdg7 . The delivery of our

response may take place electronically or by mail. We are not required to respond to requests to know

more than twice in a 12-month period.

We do not sell, and have not in the prior 12 months sold, Personal Information about California

residents. Therefore, we have not included a “Do Not Sell My Personal Info” link on our Site. If our

practices change, we will update this Privacy Policy and take any other necessary action to comply with

applicable law. We do, however, disclose Personal Information for business purposes as described in the

“Third Parties We Share Personal Information With” section above.

Requests to Delete

You have the right to request that we delete any Personal Information about you that we have collected.

Upon receiving a verified request to delete Personal Information, we will do so unless otherwise required

or authorized by law. You may submit a request to delete Personal Information via

https://forms.gle/sVT8SL1koD9HhPdg7 .

Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized

agent written permission to submit a request on your behalf, and we may require that you verify your

identity directly with us. Alternatively, an authorized agent that has been provided power of attorney

pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

Methods for Submitting Consumer Requests and Our Response to Requests

You may submit a request for access and requests to delete Personal Information about you via:

● https://forms.gle/sVT8SL1koD9HhPdg7 , or

● via email at support@truckbase.com

Upon receipt of a request, we may ask you for additional information to verify your identity. Any

additional information you provide will be used only to verify your identity and not for any other

purpose.

We will acknowledge the receipt of your request within 10 days of receipt. Subject to our ability to verify

your identity, we will respond to your request within 45 days of receipt. If we require more time (up to

90 days), we will inform you of the reason and extension period in writing. In order to protect your

privacy and the security of Personal Information about you, we verify your request by checking your

email address against our database, and we may send a one-time code to the email address associated

with your account in our system.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer

request's receipt. The response we provide will also explain the reasons we cannot comply with a

request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive,

repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why

we made that decision and provide you with a cost estimate before completing your request.

The Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights

described above. Unless permitted by the CCPA, we will not:

● Deny you goods or services;

● Charge you different prices or rates for goods or services, including through granting discounts or

other benefits, or imposing penalties;

● Provide you a different level or quality of goods or services; or

● Suggest that you may receive a different price or rate for goods or services or a different level or

quality of goods or services.

10. Data Retention

We keep Personal Information related to your Account for as long as it is needed to fulfill the purposes

for which it was collected, to provide our services, to deal with possible legal claims, to comply with our

business interests and/or to abide by all applicable laws. Thereafter, we either delete Personal

Information about you or de-identify it. Please note that even if you request the deletion of Personal

Information about you, we may be required (by law or otherwise) to retain the Personal Information and

not delete it. However, once those requirements are removed, we will delete Personal Information about

you in accordance with your request.

11. Changes to the Privacy Policy

Our security and Privacy Policy are periodically reviewed and enhanced as necessary. This Privacy Policy

might change as we update and expand the Services. You can tell when this Privacy Policy was last

updated by reviewing the Last Updated legend on top of this page. We will endeavor to notify you of

these changes by email, but will not be liable for any failure to do so. We also encourage you to review

this Privacy Policy periodically. If you do not understand any of the terms or conditions of any of our

policies, you may inquire regarding the same via email at support@truckbase.com. Your continued use of

the Services after any change in this Privacy Policy will constitute your acceptance of such change.

12. Contacting Us

If you have any concerns or questions about this Privacy Policy, please contact us at

support@truckbase.com.