CharterUp, LLC ("charterUP") is committed to providing its customers with charter-bus transportation around the clock. To make this possible, charterUP collects certain information about you when you use our mobile applications, website, and online products and services (collectively, the “Services”) and through other interactions and communications you may have with us. This Privacy Policy ("Policy") applies to information collected and used by charterUP through its provision of the Services.

I. Scope and Application

charterUP values its customers' privacy. This Policy outlines the information we collect and how it is used to provide the Services and improve our customer experience. This Policy applies to persons anywhere in the world who use the Services to request charter-bus transportation (“Users”). This Policy does not apply to information we collect from or about drivers, couriers, partner transportation companies, or any other persons who contract with charterUP to provide vehicles or transportation services (collectively “Suppliers”). If you interact with the Services as both a User and a Supplier, this Policy applies to your use as a User.

II. Collection of Information

A. Information You Provide to Us

We collect information you provide directly to us, such as when you create or modify your account, request on-demand services, contact customer support, or otherwise communicate with us. This information may include: name, email address, phone number, postal address, profile picture, payment method, IP address, operating system, services requested, service notes, and other information you choose to provide.

B. Information We Collect Through Your Use of Our Services

When you use our Services, we along with our Suppliers and third parties with whom we work (e.g., service providers, business partners, advertisers and advertising servers) may, from time to time, place, view, and/or use various electronic tools or other similar authenticating or tracking technologies on your devices’ hard drive and/or memory to collect information. Through your use of the Services, and the use of the electronic tools and similar technologies, we may collect information from the following categories:

∙ Location Information: When you use the Services for transportation, we may collect precise location data about your trip from the charterUP app used by the Supplier. If you permit the charterUP app to access location services through the permission system used by your mobile operating system (“platform”), we may also collect the precise location of your device when the app is running in the foreground or background. We may also derive your approximate location from your IP address.

∙ Contact Information: If you permit the charterUP app to access the address book on your device through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Policy or at the time of consent or collection.

∙ Transaction Information: We may collect transaction details related to your use of our Services, including the type of service requested, date and time the service was provided, the Supplier utilized, amount charged, distance traveled, pickup and drop off locations, any promo code used, and other related transaction details.

∙ Usage and Preference Information: We may collect information about how you interact with our Services, preferences expressed, and settings chosen. In some cases we do this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers. To learn more about these technologies, please see Section V.

∙ Device Information: We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.

∙ Call and SMS Data : Our Services facilitate communications between Users and Suppliers. In connection with facilitating this service, we may receive call data, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of the SMS message.

∙ Log Information: When you interact with the Services, we may collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.

C. Important Information About Platform Permissions

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the charterUP app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the charterUP app seeks before you first use the app, and your use of the app constitutes your consent.

D. Information We Collect From Other Sources

We may also receive information from other sources and combine that with information we collect through our Services. For example:

∙ If you choose to link, create, or log in to your charterUP account with a payment provider (e.g., Google Wallet) or social media service (e.g., Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.

∙ When you request on demand services, our Suppliers may provide us with a User rating after providing services to you.

III. Use of Information

We may use the information we collect about you to:

∙ Provide, maintain, and improve our Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users and Suppliers, develop safety features, authenticate users, and send product updates and administrative messages;

∙ Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;

∙ Send or facilitate communications (i) between you and a Supplier, such as estimated times of arrival (ETAs), or (ii) between you and a contact of yours at your direction in connection with your use of certain features, such as referrals, invites, or ETA sharing;

∙ Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of charterUP and other companies, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards; and

∙ Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements.

A portion of the information collected under this Policy may be stored and maintained by a third-party processor(s), including, but not limited to, a payment-processing center. charterUP currently uses XXXXXXX to process our credit card transactions. By making a credit card transaction, you agree to also be bound by the Terms & Conditions of XXXX 's own Privacy Policy regarding such transactions, which can be found at https://www.charterup.com/privacy-policy.

We may transfer the information described in this Policy to, and process and store it in, the United States and other countries, some of which may have less protective data protection laws than the region in which you reside. Any personal information you provide to us is kept on secure servers. We use reasonable administrative, technical, personnel, and physical measures (i) to safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (ii) to ensure the integrity of the personal information.

Despite our best efforts and those of our Suppliers to protect your personal information, the confidentiality of any communication or material transmitted to or from us cannot be, and is not, guaranteed. Accordingly, neither charterUP nor its Suppliers are responsible for the security of information transmitted to or from you.

IV. Sharing of Information

We may share the information we collect about you as described in this Policy or as described at the time of collection or sharing, including as follows:

A. Through Our Services

We may share your information:

∙ With Suppliers, including specifically those with affiliated websites, platforms, applications, services, and/or portals that are under the common ownership or control of charterUP, to enable them to provide the Services you request. For example, we may share your name, photo (if you provide one), phone number, email address, requested and pickup and/or drop-off locations, dates of travel, and other information with Suppliers;

∙ With third persons as directed by you, such as when you want to share your estimated time of arrival with a friend;

∙ With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us;

∙ With the general public if you submit content in a public forum, such as blog comments, social media posts, or other forums accessible by the general public;

∙ With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate; and

∙ With unaffiliated third parties if we believe in good faith that the disclosure is necessary to: (a) comply with the law or in response to a subpoena, court order, government request, and/or other legal process; (b) produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, and/or other legal or administrative proceedings; (c) protect the interests, rights, safety, or property of charterUP, or others; (d) enforce any of our Terms and Conditions; (e) provide you and other users with the Services requested by you and/or the other users, and to perform other activities related to such services and products, including billing and collection; (f) provide you with special offers or promotions from charterUP and its Suppliers that may be of interest to you; and/or (g) operate charterUP’s and its Suppliers’ systems properly.

B. Other Important Sharing

We may share your information:

∙ With charterUP subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and / or logistics purposes;

∙ With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;

∙ In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;

∙ With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our User agreements, Terms of Service, or policies, or to protect the rights, property, or safety of charterUP or others;

∙ In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;

∙ If we otherwise notify you and you consent to the sharing; and

∙ In an aggregated and/or anonymized form which cannot reasonably be used to identify you.

C. Social Sharing Features

The Services may integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa, as well as rate the Services. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them. Any materials or comments posted by you through any social sharing service are public. As such, charterUP assumes (i) no liability for the accuracy of such materials, ratings, communications and/or comments, (ii) no duty to update, monitor, or correct such materials or comments, and (iii) no liability for such communications arising under the laws of copyright, libel, privacy, obscenity, or otherwise. charterUP may, in its sole discretion, delete any materials or comments.

D. Analytics and Advertising Services Provided by Others

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you use our Services, as well as when you visit other online sites and services. For more information about these technologies, please refer to Section V.

V. Your Choices

A. Account Information

You may correct or correct your account information at any time by contacting charterUP at legal@charterup.com. While charterUP will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our policies, we may seek to resolve the issue before deleting your information.

B. Access Rights

charterUP will comply with individual’s requests regarding access, correction, and/or deletion of the personal data it stores in accordance with applicable law. If you do not wish to provide us the personal information described in this Policy, and/or if you prevent us from collecting and storing other necessary information in accordance with this Policy, you will be unable to obtain the Services. You may choose to opt out of certain provisions of this Privacy Policy by submitting a request in writing to legal@charterup.com. Please note that this opt-out process may take some time to complete, based upon then-current request volume and applicable law(s).

To assist us with the uses described in this Privacy Policy, we may combine certain data about your use of the Services with personal information about you from other online or offline sources. If you prefer that we not combine such information, please contact us at legal@charterup.com.

C. Location Information

We request permission for our app’s collection of precise location information from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, you can later disable it by changing the location settings on your mobile device. However, this will limit your ability to use certain features of our Services. Additionally, disabling our app’s collection of precise location information from your device will not limit our ability to collect your trip location information from a Supplier's device nor our ability to derive approximate location from your IP address.

D. Contact Information

We may also seek permission for our app’s collection and syncing of contact information from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, iOS users can later disable it by changing the contacts settings on your mobile device. The Android platform does not provide such a setting.

E. Promotional Communications

You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.

F. Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 provides you with the right to request certain information regarding disclosure of your personal information to third parties for direct marketing purposes, including a description of the categories of personal information, be disclosed. In order to obtain such information, please email your request to legal@charterup.com.

VI. Cookies and Other Identification Technologies

A. Overview

"Cookies" are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. There are different types of cookies. Cookies served by the entity that operates the domain you are visiting are called “first party cookies.” Cookies served by companies that are not operating the domain you’re visiting are called “third party cookies.” For example, if we allow Google to set a cookie on your browser while you visit our website, it would be a third party cookie. Cookies may also endure for different periods of time. “Session Cookies” only last as long as your browser is open. They are deleted automatically once you close your browser. Other cookies are “persistent cookies” meaning that they survive after your browser is closed. For example, they may recognize your device when you re-open your browser.

Other Identification Technologies we may use include, "Pixel tags” (also called beacons or pixels), which are small blocks of code installed on (or called by) a webpage, app, or advertisement which can retrieve certain information about your device and browser, including for example: device type, operating system, browser type and version, website visited, time of visit, referring website, IP address, and other similar information, including the small text file (the cookie) that uniquely identifies the device. Pixels provide the means by which third parties can set and read browser cookies from a domain that they do not themselves operate and collect information about visitors to that domain, typically with the permission of the domain owner. “Local storage” refers generally to other places on a browser or device where information can be stored by websites, ads, or third parties (such as HTML5 local storage and browser cache). “Software Development Kits” (also called SDKs) function like pixels and cookies, but operate in the mobile app context where pixels and cookies cannot always function. The primary app developer can install pieces of code (the SDK) from partners in the app, and thereby allow the partner to collect certain information about user interaction with the app and information about the user device and network information.

B. Types of Cookies We Use

We may use a number of different types of cookies in providing the Services, as outlined below:

∙ Authentication Cookies - tell us when you’re logged in, so we can show you the appropriate experience and features such as your account information, trip history, and to edit your account settings.

∙ Security and Site Integrity Cookies - support or enable security features to help keep charterUP safe and secure. For example, they enable us to remember when you are logged into a secure area of the Services and help protect your account from being accessed by anyone other than you.

∙ Localization - helps charterUP provide a localized experience. For example, we may store information in a cookie that is placed on your browser or device so you will see the site in your preferred language.

∙ Site Features and Services - provide functionality that helps us deliver products and Services. For example, cookies help you log in by pre-filling fields. We may also use cookies and similar technologies to help us provide you and others with social plugins and other customized content and experiences, such as making suggestions to you and others.

∙ Analytics and Research - used to understand, improve, and research products and Services, including when you access the charterUP website and related websites and apps from a computer or mobile device. For example, we may use cookies to understand how you are using site features, and segmenting audiences for feature testing. We and our partners may use these technologies and the information we receive to improve and understand how you use websites, apps, products, services and ads.

∙ Advertising - used to deliver relevant ads, track ad campaign performance and efficiency. For example, we and our ad partners may rely on information gleaned through these cookies to serve you ads that may be interesting to you on other websites. Similarly, our partners may use a cookie, attribution service or another similar technology to determine whether we’ve served an ad and how it performed or provide us with information about how you interact with them. For more information about interest-based ads, or to opt out of having your web-browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices if you are in the United States.

C. Your Choices

You have the right to choose whether or not to accept cookies. However, they are an important part of how our Services work, so you should be aware that if you choose to refuse or remove cookies, this could affect the availability and functionality of the Services. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. To do so, please follow the instructions provided by your browser which are usually located within the "Help" or “Preferences” menu. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link. Removing or rejecting browser cookies does not necessarily affect third-party flash cookies, which may be used by us or our partners in connection with our Services.

VII. Use of Information from Individuals Under 18 Year of Age

charterUP does not knowingly collect or maintain personal information of anyone under the age of eighteen (18). By agreeing to our Terms & Conditions and this Privacy Policy, you represent to us and our Suppliers that you are at least eighteen (18) years of age. If you are not at least eighteen (18) years of age, then you may not access and use the Services.

VIII. Changes to the Policy

We may change this Policy from time to time. If we make significant changes in the way we treat your personal information, or to the Policy, we will provide you notice through the Services or by some other means, such as email. Your continued use of the Services after such notice constitutes your consent to the changes. We encourage you to periodically review the Policy for the latest information on our privacy practices.

IX. Contact Us

If you have any questions about this Privacy Policy, please submit your questions to legal@charterup.com.