iBulk Privacy Policy

Effective Date: November 14, 2018

Introduction

Transportation Financial Services, Inc. operating under the trade name iBULK (iBULK, Company, we, us, or our) respects your privacy and are committed to protecting it through our compliance with this privacy policy (this Policy). This Policy covers the iBULK mobile app (the App) and the services provided thereon (the Services) and is applicable to all information about you or the company or other entity(ies) you represent (you or your) collected by us and/or through the App.This Policy describes the types of information that we collect and gather from you and the other people who use the App (collectively, the Users), the types of information that you may provide when you purchase, download, install, register with, access or use the App, any of its Services, or any other related or affiliated applications, portals or websites (collectively, the iBULK Technology), how we may use that information, our practices for collecting, using, maintaining, protecting, and disclosing that information, and how you can contact us regarding this Policy and your personal information. This Policy applies only to information we collect in or through the App or iBULK Technology and in email, text and other electronic communications sent through or in connection with the App or iBULK Technology. This Policy does not apply to information that we collect offline or on any third party apps or websites, including websites you may access through the App.This Policy does also does not apply to any information you provide to, or is collected by, any third party.Those third parties may have their own privacy policies, and we urge you to read any such policies before providing any information to or through them.

Before providing us with any personal information or using the App or any related or affiliated applications or websites, please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. By downloading, registering with, or using the App or any of the iBULK Technology, you agree to this Policy and consent to the collection, use, and disclosure of your information in accordance with this Policy. By providing personal information to us, all Users fully understand and consent to the collection, use, and processing of such information by us or third parties as set forth herein. If you do not agree with the terms of this Policy, or any of our policies, procedures or practices, do not download, register with, or use the App or any of the iBULK Technology. This Policy may change from time to time. Your continued use of the App or iBULK Technology after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

Information We Collect and How We Collect It

We collect information from and about Users of the App and iBULK Technology directly from you when you provide it to us and automatically when you use the App or iBULK Technology.

Information You Provide to Us

When you download, register with, access or use the App or iBULK Technology, we may ask you provide information by which you may be personally identified, such as name, mailing or billing address, email address, telephone number, credit card or other payment method information, banking information, social security number, and other personally identifiable information ("personal information"). We collect person information from our Users at several different points on the App and iBULK Technology, including, without limitation, when Users provide it to us by (i) contacting us through email, (ii) registering for use of the App or iBULK Technology, or (iii) submitting information through any forms, interactive features, or Services available through the App or iBULK Technology.We collect this personal information when you, at any point, manually enter it into any online or electronic form available on the App or iBULK Technology or when you voluntarily submit such information to us in another manner. We may also store your personal information in our systems for use in other ways as described in this Policy. We may also ask you for information that is about you but individually does not identify you.

Other information that you may provide to us from time to time includes the following:

• Information that you provide by filling in forms in the App or iBULK Technology. This includes information provided at the time of registering to use the App or iBULK Technology, subscribing to the App, posting material, and requesting further Services through the App or iBULK Technology.
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us, including when you report a problem with the App or iBULK Technology.
• Your responses to surveys that we might ask you to complete for research purposes.
• Information when you enter a contest or promotion sponsored by us.
• Details of transactions you carry out through the App or iBULK Technology, including any financial information necessary for completing such transaction(s).
• All other information that you submit to or via the App or iBULK Technology.

Automatic Information Collection and Tracking

When you download, access, and use the App and iBULK Technology, it may use technology to automatically collect:

• Usage Details. When you access and use the App and iBULK Technology, we may automatically collect certain details of your access to and use of the App and iBULK Technology, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App and iBULK Technology.
• Device Information. We may collect information about your device (mobile, computer, GPS or otherwise) and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
• Stored Information and Files. The App and iBULK Technology may also access metadata and other information associated with other files stored on your device.
• Location Information. The App and iBULK Technology may collect information about the location of your device in order to provide directions to work sites, use as proof of load delivery, and ensure compliance with approved haul routes.
• Behavioral Information: We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).

If you do not want us to collect this information do not download the App, do not use any of the iBULK Technology, or delete the App from your device.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your device or hard drive. A cookie may contain information that allows us to track your path through the App and to determine whether you have used the App before.Our cookies cannot be used to read data from your hard drive or and cannot retrieve information from any other cookies created by other sites. We use cookies in this manner to help us understand how Users use the App and iBULK Technology, and to help us improve them. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone or internet browser. However, if you select this setting you may be unable to access certain parts of the App or iBULK Technology.
• GPS/Telematics Devices. We may receive location and telematics data passed to us from third party services or GPS-enabled devices that you have set up, which we will use to show you local information on the App, and for data reconciliation, auditing, fraud prevention and security purposes.Most mobile devices allow you to prevent real time location data being sent to us, and of course we will honor your settings (please note, however, that the App and its functionalities will not work if such settings are chosen by you).
• Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related App statistics (for example, recording the popularity of certain App content and verifying system and server integrity).

Third-Party Information Collection � Using Third-Party Sites and Third-Party Services

This Policy applies only to the App and the iBULK Technology and their related Services. The App and iBULK Technology may contain links to or otherwise interact with other websites or products not operated or controlled by us (Third-Party Sites), including, without limitation, any payment processor, third-party add-ons, applications, and other software that could track your usage or collect personal information.The policies and procedures we described here do not apply to Third-Party Sites. If you decide to access any Third-Party Sites or use services provided by any Third-Party Sites, you do so at your own risk and your disclosure of your personal information on Third-Party Sites is governed solely by the Third-Party Site's policies. We suggest contacting those third-parties directly for information on their privacy policies.

You allow us to receive information when you use your account to log in to a Third-Party Site or application. You also allow us to receive information about your visits and interaction with the sites, applications and services of our partners that include our cookies and similar technologies, unless you opt out. You allow us to receive information when you send payment or receive funds through the App or our third-party payment processors for certain Services.Any information that you upload or sync with our Services is covered by the Terms of Use and this Policy.

When you use the App, the iBULK Technology, or their content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include advertisers, ad networks, and ad servers; analytics companies; your mobile device manufacturer; your mobile service provider; and other information. These third parties may use tracking technologies to collect information about you when you use the App or iBULK Technology. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use the Information We Collect

We may use information that we collect about you or that you provide to us, including any personal information, to:

• Provide you with the App, the iBULK Technology and their contents, and any other information, products or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Process or complete transactions requested by you and give you notices about your account, purchases, and sales.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when updates are available to the App or any iBULK Technology, and of changes to any products or services we offer or provide though them.
• Analyze and improve the App and iBULK Technology.
• Make your next use of the App more personalized.
• Contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments or requests.
• Mail, E-Mail, make telephone calls and send text messages with information and offers to you.
• Provide your information to third parties to fulfill services you have requested or that may be of interest to you.
• Compile anonymous statistical information and analysis.
• Provide compiled anonymous information to third parties.
• Provide, sell or rent your information to third parties for advertising purposes.
• Permit you to access certain web-based programs, portals or applications on the App or iBULK Technology.
• Facilitate the processing by third parties of payment for online purchases or other transactions.
• Prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities.
• Enforce this Policy, our Terms of Use, and out other policies.

You should be aware that any personal information that is voluntarily posted by you to a public area of the App or iBULK Technology may be viewed and used by others, including other Users.

Communications From Us

We communicate with you through email, notices posted on the App, and other means available through the Services, including mobile text messages and push notifications. Examples of these communications include: (1) welcome and engagement communications � informing you about how to best use our Services, new features, updates about other Users you are connected to and their actions, etc.; (2) service communications � these will cover service availability, security, and other issues about the functioning of our Services; (3) promotional communications � these include email and may contain promotional information directly or on behalf of our partners, including job opportunities and insurance information. These messages will be sent to you based on your profile information and messaging preferences. You may change your email and contact preferences at any time by signing into your account and changing your email settings.Please be aware that you cannot opt out of receiving service messages from us.

We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will contact you either through email, telephone, postal mail or through the App.

When it is necessary to do so, we will send you service-related announcements, primarily via email. For example, if our service is temporarily suspended for maintenance, we may send you an email. Generally, you may not opt out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account by emailing support@ibulk.io.

SMS Service

We may make available a Service either directly or through third parties by which you can receive messages on your wireless device via short message service (SMS Service). Your provider's standard data and messaging rates apply to all SMS correspondence. All charges are billed by and payable to your mobile service provider. You represent that you are 18 years of age and the owner or authorized user of the wireless device on which messages will be received, and that you are authorized to approve the applicable charges.

You may opt out of the SMS Service by replying with the keyword STOP, END, or QUIT. This process impacts only the future delivery of our SMS message offering and will not unsubscribe you from other SMS programs to which you may have subscribed. You may receive assistance for the SMS Service by replying with the keyword HELP to the message received.

Data obtained from you in connection with this SMS Service may include your name, address, cell phone number, your provider's name, and the date, time, and content of your messages. The use of this information will be in accordance with the Terms of Use and this Policy. If fees are charged to your wireless account invoice, we may provide your carrier with your applicable information in connection therewith. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies. You acknowledge and agree that the SMS Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. We will not be liable for any delays in the receipt of any SMS messages, as delivery is subject to effective transmission from your network operator. SMS message services are provided on an AS IS basis. We are not responsible for incomplete, lost, late, damaged, illegible or misdirected mobile messages or for any technical problems, malfunctions of any telephone lines, computer systems, servers, providers, hardware/software, lost or unavailable network connections or failed, incomplete, garbled or delayed computer transmission or any combination thereof. We are not responsible for any liability for damage to any computer system or mobile device resulting from participation in or accessing or downloading information in connection with this program. We assume no responsibility for undeliverable mobile messages resulting from any form of active or passive mobile filtering by a user's mobile provider or for insufficient space in user's mobile phone account to messages. We reserve the right, in our sole discretion, to cancel or suspend the App or any iBULK Technology should a virus, bugs, or other causes beyond our control corrupt the administration, security or proper operation of the programs. We do not guarantee that your use of the SMS Service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service.

Sharing Information with Third-Parties and Affiliates

We may share your personal information with third parties our affiliates (meaning entities controlled by, controlling or under common control with us) as reasonably necessary to provide the Services. You are consenting to this sharing. We may combine information internally across different Services that we offer. We do not rent or sell personal information that you have not posted on, or through, our App, iBULK Technology or Services, except as described in this Policy.

We may establish subsidiaries or other related companies, merge with or be acquired by another company, or sell substantially all of our assets (including substantially all assets to which other of our agreements relate) to another company.If that happens, we may disclose to them your personal information, in which case we will request them to abide by this Policy. We may also disclose some personal information to a potential acquirer.

Please understand that we may contract with third parties to provide various services to us on an outsourced basis rather than performing those services ourselves. For example, we may (i) contract with an email provider to handle the distribution of email messages to Users, (ii) contract with a web site hosting provider to host our App and iBULK Technology for us or (iii) contract with a third party to provide call center services to facilitate communication in connection with our services. We may also contract with various validation services to confirm contact information you provide. By using the App, all Users consent to us providing all information (whether or not personally identifiable) received or collected from those Users to such third-party providers for the purpose of enabling the third-party provider to provide these outsourced services to us. In addition, all Users consent to the collection, maintenance, and processing of their information (whether or not personally identifiable) by us and these third-party providers.

We will share information provided by Users (whether or not personally identifiable) with certain third parties in our network so that they can contact you with information about the Services in which you have expressed interest. In order to provide the Services available to you on the App and iBULK Technology, we may also supplement your information (whether or not personally identifiable) with information from third-party sources with whom we have contracted. You have the option not to have your information shared with third parties by not requesting these Services.

We may also share information about Users (whether or not personally identifiable) with third parties so that we can offer you a broader range of services and information to meet your needs.

Further, by registering on the App or iBULK Technology, you agree that your registration constitutes an inquiry and/or application for purposes of telemarketing laws, and notwithstanding that your telephone and/or cell number may be listed with the federal Do-Not-Call Registry you expressly opt-in to: (a) receive an offer or service from one or more of our partners or affiliates; (b) receive future information about products and services from us, our partners, affiliates and other third parties to whom we may provide your information; (c) permit us, our partners, affiliates and other third parties to contact you pursuant to the business relationship we have established using the information you provided to us for any purpose such as contacting you by email address, phone and/or mobile phone number (including use of automated dialing equipment), text (SMS) message or any means of communication for any purpose that, among other things, your wireless device may be capable of receiving (for example: mms, video etc.).

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual without restriction.

In addition, we may disclose personal information that we collect or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the App, iBULK Technology and Users are among the assets transferred.
• To third parties to market their products or services to you by which you have consented by accepting the disclosures in this Policy.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including this Policy, the App, the iBULK Technology, our Terms of Use, and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our Services, our Users, our customers or others.

Your Choices About Our Collection, Use, and Disclosure of Your Information

You have a right to (1) access, modify, correct or delete your personal information controlled by us regarding your account, (2) change or remove your content, and (3) close your account. You can review and change your personal information by logging into the App and visiting our account profile page. We provide the following mechanisms for you to control certain uses and disclosures of over your information.

• Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
• Location Information. You can adjust the App settings to choose whether or not to allow the App to share information about your device location with other Users linked to your account. The App will still collect the location information but will not share it with other Users connected to your account during that time. If you block the use of location information, some parts of the App may then be inaccessible or not function properly.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

Data Retention and Data Security

We retain the personal information you provide while your account is in existence or as need to provide you Services. We may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Users and/or customers, prevent fraud or abuse, or enforce this Policy and our Terms of Use.We may retain personal information, for a limited period of time, if requested by law enforcement.Our Customer Service and IT Support teams may retain information for as long as is necessary to provide support-related reporting and trend analysis.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the App or iBULK Technology, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure, and there is a possibility that internet and mobile transmissions containing Users' personal information may be intercepted by others. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the App or iBULK Technology. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Important Information

Children Under the Age of 13

We comply with the Children's Online Privacy Protection Act (COPPA).The App and iBULK Technology are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under the age of 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@ibulk.io. You are not permitted to use the App or iBULK Technology if you are under the age of 13. By using the App and iBULK Technology, you agree to provide us with accurate information concerning your age or identify if we request it. You also agree not to assist children under the age of 13 in accessing the App or iBULK Technology or contact children under the age of 13 through the App or iBULK Technology.

California's Shine the Light Law

California Civil Code Section 1798.83, known as the Shine the Light law, permits Users of the App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Requests may be made only once a year and are free of charge. To make such a request, please send an email to support@ibulk.io.

Changes to Our Privacy Policy

We may update this Policy from time to time. If we make material changes to how we treat our Users' personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify you by email and/or text message to the primary email address and/or phone number specified in your account, or an in-App alert the first time you use the App after we make the change.

The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this privacy policy to check for any changes.

Contact Us

To ask questions or comment about this Policy and our privacy practices, please contact us via email at: support@ibulk.io