Website and Digital Platform Privacy Policy

FREELANCER LLC®

WEBSITE AND DIGITAL PLATFORM PRIVACY POLICY

Effective Date: July 21, 2026 Last Updated: July 21, 2026

1. OUR COMMITMENT TO PRIVACY

At FREELANCER LLC®, privacy is more than a legal obligation.

It is an essential part of the trust, discretion, safety, and professional care that define the FREELANCER Executive Mobility Experience.

When passengers, Partner-Chauffeurs, corporate representatives, business partners, applicants, website visitors, and other authorized users provide personal information to FREELANCER, they are placing confidence in our ability to use that information responsibly.

We respect that confidence.

This Privacy Policy explains how FREELANCER LLC, referred to throughout this Policy as “FREELANCER,” “we,” “us,” or “our,” collects, uses, protects, retains, and discloses personal information obtained through:

www.freelancedrivers.com;

FREELANCER passenger mobile applications;

FREELANCER Partner-Chauffeur mobile applications;

Passenger and Partner-Chauffeur registration systems;

Corporate and Enterprise Concierge Service accounts;

Reservation, transportation, and payment-processing systems;

Administrative and customer-support platforms;

Digital forms, communications, and service inquiries; and

Other websites, applications, programs, and digital services operated by or on behalf of FREELANCER.

This Privacy Policy applies to information collected online and, where applicable, information collected during the administration and performance of FREELANCER transportation and business services.

By accessing or using the FREELANCER website, mobile applications, registration systems, or related services, you acknowledge the practices described in this Privacy Policy.

2. THE FREELANCER PRIVACY PHILOSOPHY

FREELANCER believes that Executive Mobility should provide more than transportation.

It should provide confidence.

Passengers should be able to request transportation knowing that their personal information, travel details, payment information, preferences, and communications are treated with discretion.

Partner-Chauffeurs should be able to submit professional qualifications and compliance documentation knowing that such information is collected for legitimate operational, safety, legal, and service purposes.

Corporate and business partners should be able to coordinate Executive Mobility services knowing that account information is handled responsibly and only for authorized business purposes.

FREELANCER collects information because it is necessary to provide safe, intelligent, personalized, and professionally managed transportation services.

We do not collect personal information merely because technology makes collection possible.

Our collection, use, retention, and disclosure of personal information are intended to remain reasonably necessary and proportionate to the services being requested or provided.

3. INFORMATION WE MAY COLLECT

The information FREELANCER collects depends upon how an individual interacts with our website, mobile applications, services, and business operations.

3.1 Personal Identification Information

We may collect:

Full legal name;

Preferred name;

Date of birth;

Residential or business address;

Mailing address;

Personal or business email address;

Mobile telephone number;

Profile photograph;

Government-issued identification information;

Driver’s license information;

Identity-verification information; and

Other information reasonably necessary to confirm identity, eligibility, account ownership, or authorization.

3.2 Passenger Registration Information

Passenger registration information may include:

Passenger account credentials;

Mobile telephone verification information;

One-Time Code or One-Time Confirmation Code information;

Facial-recognition or biometric login credentials, where enabled and legally permitted;

Driver’s license validation information;

Residential address;

Personal email address;

Date of birth;

Corporate affiliation;

Emergency or authorized contact information;

Accessibility or accommodation requests;

Transportation preferences;

Preferred language;

Preferred vehicle category;

Preferred Partner-Chauffeur characteristics, where lawfully offered;

Loyalty-program information;

Wedding anniversary or other voluntarily submitted recognition dates; and

Communications submitted through the platform.

Optional information is identified as such when reasonably practicable.

Declining to provide optional information will not ordinarily prevent access to basic website information, although certain requested services, preferences, benefits, or account features may be unavailable.

3.3 Reservation and Transportation Information

When a passenger requests or receives transportation, we may collect:

Reservation date and time;

Requested pickup date and time;

Pickup and destination locations;

Intermediate stops;

Airport, airline, and flight information;

Hotel or corporate location information;

Estimated and actual trip duration;

Vehicle category requested;

Assigned Partner-Chauffeur and vehicle;

Reservation status;

Cancellation information;

Staging, arrival, pickup, and drop-off information;

One-Time Code trip-activation information;

GPS and navigational information;

Passenger and Partner-Chauffeur ratings;

Service comments;

Trip-related communications;

Lost-property reports;

Safety or incident reports;

Customer-support records; and

Information necessary to calculate charges, adjustments, refunds, incentives, or fees.

Precise location information may be collected while location-dependent services are actively being provided or when a user authorizes location access through a device or application.

3.4 Partner-Chauffeur and Applicant Information

Partner-Chauffeurs and applicants may be required to provide information necessary to confirm identity, professional qualifications, regulatory compliance, vehicle eligibility, insurance, payment eligibility, and operational readiness.

This information may include:

Full legal name and contact information;

Driver’s license and endorsement information;

Facial-recognition or selfie-verification information;

Date of birth;

Business-entity name and structure;

Employer Identification Number;

Business address;

California Secretary of State registration information;

Business ownership information;

Good-standing documentation;

Tax documentation, including Form W-9 information;

Bank-account or payment-disbursement information;

Professional licensing information;

California Public Utilities Commission permit information;

Transportation Charter-Party Carrier or other operating-authority information;

Department of Motor Vehicles records;

Employer Pull Notice enrollment or request-code information;

Driving-record information;

Background-screening information;

Drug-and-alcohol testing compliance information, where applicable;

Watchlist, fraud-prevention, identity, and sanctions-screening results;

Commercial automobile insurance information;

Certificates of insurance;

Insurance endorsements;

Waivers of subrogation;

Airport permits and operating credentials;

Vehicle registration;

Vehicle Identification Number;

License-plate number;

Vehicle photographs;

Interior and exterior vehicle videos;

Vehicle inspection information;

Vehicle make, model, year, color, condition, equipment, and passenger capacity;

Partner-Chauffeur performance ratings;

Mystery Rider or service-quality evaluations;

Passenger comments;

Availability and reservation-response information;

Membership and subscription information;

Compensation and incentive information;

Support and disciplinary communications; and

Other records required to administer the Partner-Chauffeur relationship.

3.5 Corporate and Business Account Information

For corporate, hotel, production, concierge, transportation, or Enterprise Concierge Service accounts, we may collect:

Business or organization name;

Representative’s name and title;

Business address;

Business telephone number;

Business email address;

Employer Identification Number;

Billing information;

Authorized-user information;

Corporate account credentials;

Key-card or Entry Code information;

Passenger authorization records;

Reservation and usage history;

Contract information;

Service preferences;

Invoices and payment records; and

Business communications.

3.6 Payment and Transaction Information

FREELANCER may collect or process information necessary to administer:

Transportation charges;

Reservation charges;

Cancellation fees;

Waiting-time charges;

Passenger memberships;

Partner-Chauffeur memberships;

Corporate account charges;

Refunds;

Credits;

Incentives;

Driver compensation; and

Other approved transactions.

Payment-card information may be collected and processed by an authorized third-party payment processor, such as Stripe.

FREELANCER generally does not intend to directly store complete payment-card numbers or card-security codes when those details are securely processed and retained by the authorized payment provider.

We may receive limited transaction information, such as:

Card type;

Last four digits of the card;

Payment status;

Transaction amount;

Transaction date;

Billing name and address;

Payment-token information; and

Fraud-prevention or payment-verification results.

Third-party payment processors maintain their own privacy and security practices.

3.7 Communications and Customer-Support Information

We may collect information provided through:

Email;

Telephone calls;

Text messages;

Website contact forms;

Mobile-application messaging;

Customer-support communications;

Partner-Chauffeur support communications;

Complaints;

Service inquiries;

Surveys;

Reviews;

Incident reports; and

Other correspondence.

Where permitted by law, telephone or digital communications may be monitored or recorded for training, documentation, quality assurance, dispute resolution, fraud prevention, or safety purposes.

When recording is used, appropriate notice or consent will be provided where legally required.

3.8 Device and Website-Usage Information

When a person visits our website or uses a FREELANCER application, certain information may be collected automatically, including:

Internet Protocol address;

Browser type;

Device type;

Operating system;

Device identifiers;

Application version;

Language settings;

Referring website;

Pages viewed;

Features used;

Links selected;

Date and time of access;

Session duration;

General geographic area;

Error logs;

Diagnostic information;

Security-event information; and

Website or application performance information.

This information assists FREELANCER in maintaining platform security, improving functionality, understanding service use, and identifying technical problems.

3.9 Cookies and Similar Technologies

FREELANCER and authorized service providers may use cookies, software-development kits, pixels, local storage, and similar technologies to:

Maintain website and application functionality;

Remember account or session preferences;

Authenticate users;

Protect accounts;

Prevent fraud;

Measure website performance;

Understand how digital services are used;

Diagnose technical problems; and

Improve service accessibility and design.

Users may adjust browser or device settings to limit certain cookies or tracking technologies.

Disabling essential cookies may prevent portions of the website or platform from functioning properly.

Where required, FREELANCER will provide appropriate cookie notices, preference controls, or consent choices.

3.10 Sensitive Personal Information

Certain information collected by FREELANCER may be considered sensitive personal information under applicable law.

This may include:

Government identification information;

Driver’s license information;

Precise geolocation;

Financial-account information;

Account credentials;

Biometric information;

Racial or ethnic origin information when voluntarily submitted or necessarily processed for a legally permitted preference or accommodation;

Immigration or citizenship information when legally required;

Health, disability, or accessibility information voluntarily submitted for transportation accommodations;

Contents of certain private communications; and

Information concerning an individual’s identity or personal safety.

FREELANCER uses sensitive personal information only for purposes reasonably necessary to verify identity, provide requested services, process transactions, protect safety, prevent fraud, comply with law, administer authorized preferences, and conduct legitimate business operations.

FREELANCER does not use sensitive personal information to make improper assumptions about an individual or to discriminate unlawfully.

4. HOW INFORMATION IS COLLECTED

FREELANCER may collect personal information from the following sources:

4.1 Directly From You

Information may be collected when you:

Visit the website;

Create an account;

Complete a registration form;

Apply to become a Partner-Chauffeur;

Submit vehicle or compliance documentation;

Request a reservation;

Contact customer support;

Participate in a loyalty or membership program;

Complete a payment;

Submit a review or rating;

Report an incident;

Communicate with FREELANCER; or

Voluntarily provide information for another authorized purpose.

4.2 From Your Device

Information may be collected through:

Website cookies;

Mobile-application permissions;

GPS or location services;

Device identifiers;

Application logs;

Browser activity;

Security tools; and

Similar digital technologies.

4.3 From Service Providers

Information may be received from providers that assist with:

Payment processing;

Identity verification;

Background screening;

Driving-record verification;

Regulatory-compliance verification;

Fraud prevention;

Cloud hosting;

Communications;

Mapping and navigation;

Flight tracking;

Customer support;

Analytics;

Cybersecurity;

Document storage; and

Other platform operations.

4.4 From Corporate or Authorized Representatives

A company, hotel, concierge, production company, travel coordinator, family member, assistant, or other authorized representative may provide passenger or reservation information on behalf of another person.

The person providing the information is responsible for having appropriate authorization to submit it.

4.5 From Public and Government Sources

FREELANCER may obtain information from:

Government licensing databases;

Court or public records;

Regulatory agencies;

Business registries;

Insurance-verification sources;

Airport authorities;

Sanctions or watchlist databases;

Professional directories; and

Other legally available sources.

5. HOW FREELANCER USES PERSONAL INFORMATION

FREELANCER may use personal information to:

5.1 Provide Transportation Services

This includes using information to:

Create and maintain accounts;

Accept and manage reservations;

Match passengers with qualified Partner-Chauffeurs;

Allocate appropriate vehicles;

Confirm pickup and destination information;

Provide navigation;

Track reservation progress;

Activate trips through security codes;

Process trip completion;

Communicate service updates;

Provide airport or flight-related coordination;

Administer passenger preferences; and

Deliver requested Executive Mobility services.

5.2 Verify Identity and Protect Accounts

We may use information to:

Confirm user identity;

Verify mobile telephone numbers;

Validate identification;

Perform facial or biometric authentication, where enabled;

Detect unauthorized account access;

Prevent duplicate or fraudulent accounts;

Protect payment transactions; and

Maintain platform integrity.

5.3 Qualify and Manage Partner-Chauffeurs

We may use Partner-Chauffeur information to:

Review applications;

Confirm professional qualifications;

Verify licensing and operating authority;

Verify insurance;

Review vehicle eligibility;

Conduct background and driving-record reviews;

Confirm compliance with legal and operational requirements;

Administer membership;

Allocate reservations;

Calculate compensation;

administer incentives;

Monitor service quality;

Review complaints or incidents;

Conduct vehicle or operational inspections; and

Protect passengers, Partner-Chauffeurs, and the public.

5.4 Process Payments

We may use information to:

Authorize charges;

Process payments;

Administer recurring memberships;

Issue refunds or credits;

Calculate cancellation or waiting-time fees;

Prevent transaction fraud;

Resolve payment disputes;

Prepare invoices;

Maintain financial records; and

Process Partner-Chauffeur compensation.

5.5 Personalize the Executive Mobility Experience

Information may be used to remember and administer authorized preferences involving:

Vehicle category;

Accessibility accommodations;

Language;

Corporate-account instructions;

Loyalty benefits;

Passenger comfort;

Communication preferences; and

Other service selections.

Preferences are subject to availability, applicable law, safety requirements, and operational feasibility.

5.6 Maintain Safety, Quality, and Accountability

We may use information to:

Investigate complaints;

Document incidents;

Review trip activity;

Address lost or damaged property;

Evaluate vehicle condition;

Assess passenger-caused damage;

Review ratings;

Administer Mystery Rider evaluations;

Enforce platform agreements;

Detect unsafe or prohibited activity;

Respond to emergencies; and

Protect legal rights.

5.7 Communicate With Users

We may use information to send:

Reservation confirmations;

Trip-status notifications;

Account-verification messages;

Security alerts;

Membership notices;

Payment confirmations;

Policy updates;

Customer-support responses;

Operational announcements;

Service reminders; and

Other communications related to the user’s relationship with FREELANCER.

Marketing or promotional messages will be sent only as permitted by law.

Users may opt out of promotional communications while continuing to receive necessary transactional, safety, legal, and account-related communications.

5.8 Improve and Protect the Digital Platform

We may use information to:

Maintain website and application functionality;

Diagnose errors;

Develop new features;

Improve accessibility;

Analyze platform performance;

Prevent cyberattacks;

Detect fraud;

Conduct security testing;

Protect intellectual property; and

Improve the FREELANCER service experience.

5.9 Comply With Legal Obligations

We may process information to:

Comply with transportation laws;

Respond to valid legal process;

Satisfy tax and accounting requirements;

Maintain required business records;

Respond to regulatory agencies;

Meet insurance requirements;

Enforce contracts;

Establish or defend legal claims; and

Fulfill other lawful obligations.

6. DISCLOSURE OF PERSONAL INFORMATION

FREELANCER does not disclose personal information merely for convenience.

Information may be disclosed only when reasonably necessary to provide services, administer business operations, protect safety, comply with law, or fulfill another purpose described in this Policy.

6.1 Partner-Chauffeurs and Passengers

Information may be exchanged between passengers and assigned Partner-Chauffeurs as reasonably necessary to perform a reservation.

This may include:

Passenger or Partner-Chauffeur name;

Profile photograph;

Telephone or masked communication information;

Vehicle information;

Pickup location;

Destination;

Reservation instructions;

Trip status;

Accessibility needs;

Service preferences; and

Ratings or safety information.

Neither party is authorized to use the other party’s information for unrelated personal, commercial, or unlawful purposes.

6.2 Service Providers and Contractors

FREELANCER may disclose information to authorized providers that perform services such as:

Cloud hosting;

Data storage;

Payment processing;

Identity verification;

Background screening;

Driving-record verification;

Insurance verification;

Communications;

Mapping and navigation;

Flight tracking;

Customer support;

Analytics;

Cybersecurity;

Fraud prevention;

Accounting;

Legal services;

Document management; and

Platform development and maintenance.

These providers are expected to use personal information only for authorized purposes and in accordance with contractual, legal, confidentiality, and security obligations.

6.3 Corporate and Authorized Account Representatives

Reservation, billing, passenger, and service information may be disclosed to a corporate account, concierge, travel coordinator, production company, hotel, assistant, family representative, or other person who arranged or paid for the transportation, where such disclosure is authorized or reasonably necessary.

6.4 Government, Regulatory, and Law-Enforcement Authorities

FREELANCER may disclose information when reasonably necessary to:

Comply with a subpoena, warrant, court order, or other valid legal process;

Respond to a lawful government request;

Satisfy regulatory requirements;

Report suspected criminal conduct;

Protect the safety of passengers, Partner-Chauffeurs, employees, contractors, or the public;

Investigate fraud or security threats; or

Protect FREELANCER’s legal rights and property.

6.5 Insurance Providers and Professional Advisers

Information may be disclosed to insurers, claims administrators, attorneys, accountants, auditors, consultants, or other professional advisers when necessary to:

Administer insurance coverage;

Evaluate claims;

Investigate incidents;

Resolve disputes;

Conduct audits;

Maintain compliance; or

Protect legal and financial interests.

6.6 Business Transactions

If FREELANCER becomes involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar business transaction, information may be reviewed, transferred, or disclosed as part of that transaction.

Any successor receiving personal information will be expected to honor applicable privacy obligations.

7. SALE AND SHARING OF PERSONAL INFORMATION

FREELANCER does not sell personal information in exchange for money.

FREELANCER does not knowingly sell or share the personal information of individuals under 16 years of age.

FREELANCER does not authorize personal information collected for transportation, identification, payment, safety, or regulatory purposes to be used by third parties for their own unrelated commercial purposes.

Certain website analytics, advertising, or digital-technology practices may be legally classified as “sharing” or “targeted advertising” under some privacy laws, even when no money is exchanged.

Where FREELANCER engages in an activity legally considered a sale or sharing of personal information, FREELANCER will provide the notices, links, preference controls, and opt-out mechanisms required by applicable law.

FREELANCER will recognize legally required browser-based opt-out preference signals, including the Global Privacy Control, when applicable to its digital practices.

8. BIOMETRIC AND FACIAL-RECOGNITION INFORMATION

Where offered and legally permitted, FREELANCER may use facial-recognition, selfie-verification, or other biometric technology for:

Identity verification;

Secure account access;

Fraud prevention;

Partner-Chauffeur onboarding;

Passenger authentication;

Account recovery; and

Protection against unauthorized platform use.

Biometric information will not be collected or used unless appropriate notice, authorization, or consent has been obtained where required by law.

FREELANCER does not sell biometric information.

Biometric information will be retained only for as long as reasonably necessary to fulfill the disclosed purpose, meet legal requirements, resolve disputes, protect platform security, or enforce agreements.

Where biometric processing is conducted by an authorized service provider, the provider will be expected to comply with applicable confidentiality, security, retention, and deletion requirements.

9. LOCATION INFORMATION

Location is essential to many FREELANCER services.

Depending upon device permissions and platform use, FREELANCER may collect precise or approximate location information to:

Identify pickup locations;

Provide navigation;

Match passengers and Partner-Chauffeurs;

Confirm arrival and staging;

Track reservation progress;

Support trip activation;

Estimate time and distance;

Assist during emergencies;

Investigate incidents;

Prevent fraud; and

Verify completion of transportation services.

Users may manage location permissions through their device settings.

Restricting location access may prevent certain reservation, safety, navigation, or trip-management features from operating properly.

FREELANCER does not authorize location information collected for transportation services to be sold to data brokers or used to create unrelated consumer profiles.

10. PAYMENT SECURITY

Payment transactions may be processed through PCI-compliant third-party payment providers.

FREELANCER uses payment tokens and limited transaction records where reasonably possible to reduce direct exposure to complete payment-card information.

Users should never send complete payment-card numbers, card-security codes, passwords, or other sensitive financial credentials through ordinary email, unprotected text messages, or unauthorized communication channels.

Although FREELANCER takes reasonable measures to protect payment information, no electronic payment or transmission system can be guaranteed to remain completely secure under every circumstance.

11. DATA SECURITY

FREELANCER uses reasonable administrative, technical, physical, and organizational safeguards designed to protect personal information against:

Unauthorized access;

Unlawful use;

Improper disclosure;

Accidental loss;

Alteration;

Destruction;

Fraud;

Cyberattack; and

Other reasonably foreseeable threats.

Safeguards may include:

Access controls;

Account authentication;

Encryption;

Secure cloud infrastructure;

Payment tokenization;

Monitoring and logging;

Fraud-detection systems;

Confidentiality requirements;

Service-provider controls;

Data minimization;

Backup procedures;

Security reviews; and

Incident-response procedures.

Access to personal information is limited to individuals and service providers who have a legitimate operational, legal, safety, financial, or technical reason to access it.

No website, mobile application, database, or electronic transmission can be guaranteed to be completely secure.

Users are responsible for protecting their passwords, devices, account credentials, security codes, and login information.

Users should immediately notify FREELANCER of suspected unauthorized account activity.

12. DATA RETENTION

FREELANCER retains personal information only for as long as reasonably necessary and proportionate to:

Provide requested services;

Maintain accounts;

Complete transactions;

Verify qualifications;

Maintain regulatory compliance;

Administer insurance;

Resolve complaints;

Investigate incidents;

Prevent fraud;

Protect safety;

Enforce agreements;

Maintain tax and accounting records;

Establish or defend legal claims; and

Fulfill other disclosed or legally required purposes.

Retention periods vary according to:

The nature and sensitivity of the information;

The reason it was collected;

The length of the business or customer relationship;

Regulatory requirements;

Limitation periods;

Insurance requirements;

Safety considerations; and

Legal obligations.

When personal information is no longer reasonably necessary, FREELANCER will delete, destroy, anonymize, or securely isolate it, subject to legal, security, backup, and recordkeeping requirements.

13. USER ACCOUNTS AND RESPONSIBILITIES

Users are responsible for:

Providing accurate information;

Keeping account information current;

Protecting passwords and verification codes;

Preventing unauthorized device access;

Using the platform lawfully;

Reviewing account activity;

Promptly reporting suspected fraud; and

Avoiding submission of another person’s information without authority.

Users should not share One-Time Codes, passwords, biometric access credentials, or payment-verification information with unauthorized persons.

FREELANCER may suspend or restrict an account when necessary to protect users, investigate suspicious activity, comply with law, or maintain platform security.

14. CHILDREN’S PRIVACY

The FREELANCER website and digital services are not directed to children under 13 years of age.

Children are not permitted to create independent passenger, Partner-Chauffeur, corporate, or payment accounts.

Transportation for a minor must be arranged and authorized by a parent, legal guardian, corporate representative, school, agency, or other responsible adult as permitted by FREELANCER policies and applicable law.

FREELANCER does not knowingly collect personal information directly from a child under 13 without legally sufficient parental or guardian authorization.

If FREELANCER learns that personal information was collected directly from a child in violation of applicable law, reasonable steps will be taken to delete or restrict that information.

A parent or legal guardian who believes a child has submitted information without authorization should contact FREELANCER.

15. THIRD-PARTY WEBSITES AND SERVICES

The FREELANCER website or mobile applications may contain links to third-party websites, applications, payment systems, mapping services, social-media platforms, or other external resources.

FREELANCER does not control the privacy, security, content, or operating practices of independent third parties.

A link does not necessarily represent an endorsement of the third party’s privacy practices.

Users should review the privacy policies and terms of every third-party service they choose to access.

This Privacy Policy applies only to information collected or controlled by FREELANCER.

16. COMMUNICATION PREFERENCES

Users may opt out of promotional email or text communications by:

Using an unsubscribe link;

Following the instructions provided in the message;

Adjusting available account preferences; or

Contacting FREELANCER.

Opting out of promotional communications will not prevent FREELANCER from sending:

Reservation confirmations;

Trip notifications;

Payment receipts;

Security alerts;

Policy notices;

Membership notices;

Account messages;

Safety communications; or

Other non-promotional communications necessary to administer the service relationship.

Message and data rates may apply to text-message communications.

17. YOUR PRIVACY RIGHTS

Depending upon where you reside and the laws applicable to FREELANCER, you may have the right to:

Know whether FREELANCER processes your personal information;

Request access to personal information;

Request the categories of information collected;

Request specific pieces of personal information;

Request information concerning sources, purposes, and disclosures;

Request correction of inaccurate information;

Request deletion of personal information;

Obtain a portable copy of certain information;

Opt out of the sale or sharing of personal information;

Opt out of certain targeted advertising;

Limit certain uses of sensitive personal information;

Withdraw consent where processing is based on consent;

Appeal the denial of a privacy request where required; and

Exercise privacy rights without unlawful discrimination.

These rights are subject to legal exceptions.

For example, FREELANCER may retain or continue using information when reasonably necessary to:

Complete a transaction;

Provide requested services;

Protect safety;

Detect fraud;

Maintain security;

Comply with law;

Exercise or defend legal claims;

Maintain required records; or

Fulfill another purpose permitted by law.

CALIFORNIA PRIVACY NOTICE

FREELANCER LLC is a California limited liability company committed to protecting the privacy and personal information of its passengers, Partner-Chauffeurs, business partners, applicants, website visitors, and authorized platform users.

Based upon FREELANCER’s present business size, operations, and data-processing activities, FREELANCER is not currently subject to the California Consumer Privacy Act or the California Privacy Rights Act.

Accordingly, references within this Privacy Policy to access, correction, deletion, or other privacy requests represent FREELANCER’s voluntary privacy practices and should not be interpreted as an acknowledgment that any particular privacy statute currently applies to the company.

FREELANCER may nevertheless consider reasonable requests concerning personal information when the identity of the requesting individual can be appropriately verified and when fulfilling the request would not conflict with legal, regulatory, safety, financial, contractual, insurance, fraud-prevention, record-retention, or operational obligations.

As FREELANCER grows, expands its services, introduces new technology, or becomes subject to additional privacy requirements, this Privacy Policy may be revised to include any notices, procedures, and consumer rights required by applicable law.

18. CALIFORNIA PRIVACY RIGHTS

California residents may have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act.

Subject to applicability and legal exceptions, these rights may include:

18.1 Right to Know

You may request information concerning:

The categories of personal information collected;

The categories of sources;

The business or commercial purposes for collection, use, sale, or sharing;

The categories of third parties receiving information;

The categories of personal information disclosed for business purposes;

The categories of information sold or shared, if any; and

Specific pieces of personal information maintained about you.

18.2 Right to Delete

You may request deletion of personal information collected from you, subject to legal exceptions.

18.3 Right to Correct

You may request correction of inaccurate personal information.

18.4 Right to Opt Out of Sale or Sharing

You may direct a covered business not to sell or share personal information.

FREELANCER does not sell personal information for monetary compensation.

Should FREELANCER engage in digital practices legally defined as selling or sharing, an appropriate Do Not Sell or Share My Personal Information method will be provided.

18.5 Right to Limit Use of Sensitive Personal Information

When legally applicable, you may request that use or disclosure of sensitive personal information be limited to purposes necessary to provide the requested services and other purposes permitted by law.

FREELANCER primarily uses sensitive personal information for identity verification, transportation, safety, payment, fraud prevention, regulatory compliance, and other necessary operational purposes.

18.6 Right to Non-Discrimination

FREELANCER will not unlawfully discriminate against you because you exercised an applicable privacy right.

Exercising a privacy right will not result in:

Denial of service;

Unlawful price differences;

Unlawful reduction in service quality; or

Retaliatory treatment.

A lawful loyalty, membership, incentive, or pricing program may involve different benefits when the difference is reasonably related to the value or operational use of information and all legally required notices are provided.

18.7 Authorized Agents

A California resident may designate an authorized agent to submit a privacy request.

FREELANCER may require documentation confirming the agent’s authority and may separately verify the identity of the consumer.

19. SUBMITTING A PRIVACY REQUEST

A privacy request may be submitted through the contact methods identified below.

Privacy Request Email: [INSERT PRIVACY EMAIL ADDRESS]

Website Request Form: [INSERT PRIVACY REQUEST WEBPAGE OR FORM]

Telephone Number: [INSERT TOLL-FREE OR BUSINESS TELEPHONE NUMBER]

Mailing Address:

FREELANCER LLC Attention: Privacy Administration [INSERT BUSINESS MAILING ADDRESS] California, United States

A request should clearly identify:

The person making the request;

The privacy right being exercised;

The information or account involved; and

A reliable method for FREELANCER to respond.

FREELANCER may request additional information to verify identity and protect personal information from unauthorized disclosure.

Verification information will be used only for identity verification, fraud prevention, request administration, and related legal obligations.

FREELANCER will respond within the period required by applicable law.

When additional time is legally permitted and reasonably necessary, FREELANCER will provide notice of the extension.

20. GLOBAL PRIVACY CONTROL AND BROWSER SIGNALS

Where required by applicable law, FREELANCER will process recognized browser-based opt-out preference signals, including the Global Privacy Control, as a request to opt out of applicable sale or sharing activities associated with the browser or device transmitting the signal.

Because browsers, devices, accounts, and platform sessions may operate independently, users may need to activate the preference signal on each browser or device used.

FREELANCER does not presently respond to ordinary “Do Not Track” browser signals unless legally required, because no universally accepted technical standard currently governs all such signals.

21. INFORMATION CONCERNING CALIFORNIA PRIVACY CATEGORIES

During the preceding 12 months, depending upon an individual’s interaction with FREELANCER, we may have collected the following categories of personal information:

Identifiers;

Customer-record information;

Protected classification information where voluntarily supplied or legally required;

Commercial information;

Internet or electronic-network activity;

Geolocation information;

Audio, electronic, photographic, or visual information;

Professional or employment-related information;

Education information when relevant to an application;

Inferences used to administer service preferences or evaluate platform performance; and

Sensitive personal information.

These categories may be collected from the sources and used for the purposes described in this Policy.

They may be disclosed to the categories of recipients described in this Policy for legitimate business purposes.

FREELANCER does not sell these categories of information for monetary compensation.

22. NOTICE AT COLLECTION

At or before the point where personal information is collected, FREELANCER may provide a short-form notice identifying:

The categories of information being collected;

The purposes for which the information will be used;

Whether information is sold or shared;

The applicable retention criteria;

A link to this Privacy Policy; and

Any legally required privacy choices.

A notice displayed within a registration form, mobile application, reservation page, payment screen, cookie banner, onboarding system, or other collection interface supplements this Privacy Policy.

23. EMPLOYMENT AND BUSINESS-CONTACT INFORMATION

Where FREELANCER receives information from employees, independent contractors, applicants, vendors, business contacts, or representatives, the information may be used to:

Review qualifications;

Communicate regarding opportunities;

Administer business relationships;

Conduct identity or background verification;

Manage contracts;

Maintain security;

Process payments;

Satisfy tax obligations; and

Comply with law.

Partner-Chauffeurs are independent business operators and are not classified as employees merely because FREELANCER collects information required to administer platform access, membership, regulatory compliance, reservations, safety, or compensation.

24. INTERNATIONAL ACCESS AND DATA PROCESSING

FREELANCER is organized and operated in the United States and primarily provides services within California.

Information may be processed or stored in the United States or in other jurisdictions where authorized technology providers operate.

Privacy and data-protection laws may differ between jurisdictions.

When personal information is transferred or processed outside the jurisdiction where it was collected, FREELANCER will use legally appropriate safeguards where required.

Accessing the website from outside the United States does not represent a guarantee that FREELANCER services are available or legally authorized in that location.

25. DATA BREACH AND SECURITY-INCIDENT RESPONSE

FREELANCER maintains procedures intended to identify, investigate, contain, document, and respond to suspected security incidents.

When personal information is affected by a security incident, FREELANCER will provide legally required notifications to affected individuals, government agencies, law-enforcement authorities, business partners, insurers, or other appropriate parties.

Notification may be delayed when requested or required by law enforcement or when otherwise permitted by law.

26. CHANGES TO THIS PRIVACY POLICY

FREELANCER may update this Privacy Policy as:

Services develop;

Technology changes;

Legal requirements change;

New platform features are introduced;

Business practices evolve; or

Additional privacy protections are implemented.

The revised Privacy Policy will identify the updated effective date.

Material changes may also be communicated through:

Website notices;

Mobile-application notices;

Account messages;

Email;

Text message; or

Other appropriate communication methods.

Continued use of FREELANCER services after an updated Policy becomes effective constitutes acknowledgment of the revised Policy to the extent permitted by law.

27. CONTACT FREELANCER

Questions, concerns, or requests regarding this Privacy Policy may be directed to:

FREELANCER LLC Attention: Privacy Administration [INSERT BUSINESS MAILING ADDRESS] California, United States

Email: [INSERT PRIVACY EMAIL ADDRESS] Telephone: [INSERT BUSINESS TELEPHONE NUMBER] Website: www.freelancedrivers.com

Please do not include complete payment-card numbers, passwords, Social Security numbers, security codes, or unnecessary sensitive personal information in ordinary email communications.

28. FINAL PRIVACY COMMITMENT

The FREELANCER Executive Mobility Experience is built upon confidence.

Confidence that the reservation will be professionally managed.

Confidence that the Partner-Chauffeur has been appropriately qualified.

Confidence that the vehicle will arrive prepared.

Confidence that the passenger will be treated with dignity, discretion, and respect.

That same confidence must extend to personal information.

FREELANCER uses information to provide transportation, protect passengers and Partner-Chauffeurs, verify professional qualifications, secure transactions, personalize service, and maintain the integrity of the Executive Mobility experience.

Personal information is not merely data within a digital platform.

It represents the identity, movement, preferences, trust, and security of the individuals we serve.

That responsibility is taken seriously.

Because Executive Mobility should not only feel comfortable.

It should feel protected.

FREELANCER – IT PAYS TO RIDE®™