1. INTRODUCTION

Groundvoy, Inc. (“Groundvoy,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our global mobility platform, including our mobile applications, websites, and related services (collectively, the “Platform” or “Services”).

This Privacy Policy applies to all users of the Platform, including Riders, Drivers, Fleet Operators, Corporate Clients, Travel Agencies, Partners, and visitors to our websites. By using the Platform, you consent to the data practices described in this policy.

We comply with applicable data protection laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other regional privacy regulations. This policy describes your privacy rights and how you can exercise them.

2. INFORMATION WE COLLECT

2.1 Information You Provide to Us

Account Registration Information:

• Name, email address, phone number

• Profile photo

• Payment information (credit card details, billing address)

• Date of birth (for age verification)

• Government-issued ID (for Drivers and certain verification purposes)

Driver-Specific Information:

• Driver’s license number and details

• Vehicle registration and insurance information

• Background check results and criminal history

• Tax identification number (for payment processing)

• Bank account details (for earnings deposits)

Ride and Booking Information:

• Pickup and drop-off locations

• Ride preferences and special requests

• Ratings and reviews

• Communication with Drivers and support

Communications:

• Messages, calls, and chat conversations

• Customer service inquiries and feedback

• Survey responses

2.2 Information Collected Automatically

Location Data:

• Precise GPS location (for ride matching and navigation)

• Location history during active rides

• Background location (when app is in background, if permitted)

Device Information:

• Device type, model, and operating system

• Unique device identifiers (IMEI, advertising ID)

• IP address

• Mobile network information

• App version and settings

Usage Information:

• Pages viewed, features used, and actions taken

• Time, frequency, and duration of activities

• Crash reports and performance data

• Interaction with notifications and emails

Sensor Data:

• Accelerometer and gyroscope data (for safety features)

• Motion and speed data

2.3 Information from Third Parties

• Background check providers (criminal records, driving history)

• Identity verification services

• Payment processors

• Social media platforms (if you connect your account)

• Insurance companies and claims processors

• Corporate account administrators (for business travel)

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

3.1 Providing and Improving Services

• Matching Riders with available Drivers

• Facilitating ride bookings and payments

• Providing navigation and routing

• Processing transactions and issuing receipts

• Enabling communication between Riders and Drivers

• Improving Platform functionality and user experience

3.2 Safety and Security

• Verifying user identity and eligibility

• Conducting background checks on Drivers

• Detecting and preventing fraud, abuse, and security incidents

• Monitoring compliance with our Terms and policies

• Responding to emergencies and safety incidents

• Maintaining Platform security and integrity

3.3 Customer Support

• Responding to inquiries and support requests

• Investigating and resolving disputes

• Processing refunds and adjustments

3.4 Communications

• Sending transactional notifications (ride updates, receipts)

• Providing service announcements and updates

• Sending marketing and promotional messages (with consent)

• Conducting surveys and research

3.5 Legal and Regulatory Compliance

• Complying with legal obligations and court orders

• Responding to law enforcement requests

• Meeting tax and financial reporting requirements

• Enforcing our Terms and Conditions

• Protecting our rights and property

3.6 Analytics and Research

• Analyzing usage patterns and trends

• Conducting market research

• Developing new features and services

• Creating aggregated, de-identified data for business insights

4. HOW WE SHARE YOUR INFORMATION

We share your information in the following circumstances:

4.1 With Other Users

• Riders: We share your name, photo, vehicle details, and location with Drivers when you request a ride

• Drivers: We share your name, photo, pickup/drop-off locations, and rating with Riders

• Both parties can communicate via anonymized phone numbers and chat

4.2 With Service Providers

We share data with third-party service providers who perform services on our behalf:

• Payment processors (Stripe, PayPal, Adyen)

• Background check companies

• Cloud hosting providers (AWS, Azure)

• Communication services (Twilio, SendGrid)

• Mapping and navigation providers (Google Maps, Mapbox)

• Analytics and monitoring services

• Customer support platforms

4.3 With Business Partners

• Corporate clients (for business travel reporting)

• Travel agencies and hospitality partners

• Fleet operators and franchise partners

• Insurance companies (in case of claims)

4.4 For Legal Reasons

We may disclose information when required or permitted by law:

• To comply with legal process (subpoenas, court orders)

• To respond to law enforcement requests

• To protect our rights, property, and safety

• To enforce our Terms and policies

• In emergencies to protect health and safety

4.5 Business Transfers

In connection with a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of such changes and any choices you may have.

4.6 With Your Consent

We may share your information for other purposes with your explicit consent or at your direction (e.g., connecting with social media accounts).

5. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods vary by data type:

• Account information: Retained while your account is active and for 7 years after closure

• Ride history: Retained for 7 years for accounting and legal purposes

• Location data: Retained during active rides and for 7 years thereafter

• Payment information: Tokenized and retained for transaction history

• Background checks: Retained for the duration of Driver status and 7 years after

• Safety incident reports: Retained indefinitely for safety and legal purposes

• Marketing data: Retained until you opt out or request deletion

6. YOUR RIGHTS AND CHOICES

6.1 Access and Portability

You have the right to access your personal information and receive a copy in a portable format. You can download your data from your account settings or contact us at privacy@groundvoy.com.

6.2 Correction and Updates

You can update most of your information directly through the app or website. For information you cannot update yourself, contact our support team.

6.3 Deletion

You can request deletion of your account and personal data. Note that some information may be retained for legal, safety, or business purposes even after deletion. To delete your account, use the in-app feature or contact privacy@groundvoy.com.

6.4 Marketing Communications

You can opt out of marketing emails by clicking the unsubscribe link or adjusting preferences in your account settings. You can opt out of SMS marketing by replying STOP. Note that you will still receive transactional messages related to your rides.

6.5 Location Services

You can control location permissions through your device settings. Disabling location services will limit your ability to use certain Platform features, particularly ride booking and navigation.

6.6 Cookies and Tracking

You can control cookies through your browser settings. However, disabling cookies may affect Platform functionality. We use cookies for authentication, preferences, analytics, and advertising.

7. REGIONAL PRIVACY RIGHTS

7.1 European Union (GDPR)

If you are in the EU, you have additional rights under GDPR:

• Right to access your personal data

• Right to rectification of inaccurate data

• Right to erasure (“right to be forgotten”)

• Right to restriction of processing

• Right to data portability

• Right to object to processing

• Right to lodge a complaint with a supervisory authority

Legal bases for processing: We process your data based on (a) contract performance, (b) legitimate interests, (c) legal obligations, or (d) consent. To exercise your rights, contact privacy@groundvoy.com.

7.2 California (CCPA/CPRA)

California residents have the following rights:

• Right to know what personal information we collect and how it is used

• Right to delete personal information

• Right to opt out of the sale of personal information (we do not sell your data)

• Right to non-discrimination for exercising privacy rights

• Right to correct inaccurate personal information

To exercise these rights, submit a request at privacy@groundvoy.com or call 1-800-GROUNDVOY. We will verify your identity before processing requests.

7.3 Other Regions

Users in other regions may have additional privacy rights under local laws. We comply with applicable privacy regulations in all jurisdictions where we operate. Contact privacy@groundvoy.com for information about your specific rights.

8. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Encryption of data in transit (TLS/SSL) and at rest (AES-256)

• Regular security audits and penetration testing

• Access controls and authentication mechanisms

• Network security and firewall protection

• Employee training on data protection

• Incident response procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

9. INTERNATIONAL DATA TRANSFERS

Groundvoy operates globally, and your information may be transferred to, stored, and processed in countries other than your country of residence, including the United States. These countries may have data protection laws that differ from those in your country.

When we transfer personal data from the European Economic Area (EEA) or the UK to other countries, we use appropriate safeguards such as Standard Contractual Clauses approved by the European Commission, adequacy decisions, or other legally approved mechanisms.

By using the Platform, you consent to the transfer of your information to countries outside your country of residence, including countries that may not provide the same level of data protection as your home country.

10. CHILDREN’S PRIVACY

The Platform is not intended for children under the age of 18. We do not knowingly collect personal information from children. If you are under 18, you may only use the Services with the involvement and consent of a parent or legal guardian.

If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete such information. If you believe we have collected information from a child, please contact us at privacy@groundvoy.com.

11. THIRD-PARTY SERVICES AND LINKS

The Platform may contain links to third-party websites, services, or integrations (such as social media platforms, payment processors, or mapping services). This Privacy Policy does not apply to those third-party services.

We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you use. When you interact with third-party services through our Platform, those third parties may collect information about you in accordance with their own privacy policies.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by:

• Updating the “Effective Date” at the top of this policy

• Sending an email notification to your registered email address

• Displaying a prominent notice in the app or on our website

Your continued use of the Platform after we make changes indicates your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

13. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Groundvoy, Inc.

Data Protection Officer

1621 Central Ave #60456

Cheyenne, WY 82001

United States of America

Email: privacy@groundvoy.com

Phone: 1-800-GROUNDVOY (1-800-476-8639)

Website: www.groundvoy.com/privacy

For EU/UK data protection inquiries:

Email: eu-privacy@groundvoy.com

EU Representative: [To be appointed as required under GDPR Article 27]

14. ACKNOWLEDGMENT

BY USING THE GROUNDVOY PLATFORM, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND AGREE TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED HEREIN.