DRIVER PRIVACY POLICY

Last updated June 30, 2017

Alfred Executive Transportation LLC and its affiliates and subsidiaries (including Alfred Holdings, Inc.) (collectively “Leap,” “us”, “our” or “we”) are committed to protecting your privacy. Our privacy policy, which applies to all users of our Website, the Driver App (“App”) and Service, is designed to explain the information we collect and how we use it to provide our services and give users a better experience (“Privacy Policy”). Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use. This Privacy Policy is part of, and incorporated into, the Terms and Conditions (see www.Leaprides.com/terms-and-conditions/).

BY ACCESSING AND USING THE WEBSITE, APP AND/OR SERVICE, IN ADDITION TO ALL PROVISIONS OF THE TERMS AND CONDITIONS (WWW.LEAPRIDES.COM/TERMS-AND-CONDITIONS/) (“TERMS”) YOU CONSENT TO OUR COLLECTION, STORAGE, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AND OTHER INFORMATION DESCRIBED IN THIS PRIVACY POLICY. YOU FURTHER AGREE TO USE PERSONAL INFORMATION CONCERNING LEAP RIDERS ONLY AS AUTHORIZED BY THIS POLICY AND THE TERMS AND NOT AS PROHIBITED BY THIS POLICY AND/OR THE TERMS.

1. Types of Information We Collect

We collect both “Personal Information” and “Anonymous Information” about our users. Personal Information is information that can be used to contact or identify you, such as your full name, email address, phone number, payment method and profile picture, as well as information that is linked to such information. "Anonymous Information" is information that cannot be used to contact or identify you and is not linked to information that can be used to do so. It includes passively collected information about your activities on the Service, such as usage data, to the extent that information is not linked to your Personal Information.

You can access and browse certain portions of the Website and download the App without disclosing Personal Information, although, like most website and mobile app providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system. We also collect geolocation data from visitors that download and open the App. Please note that you can choose not to provide us with certain information, but this will limit the features of the Service you can access and use.

• Voluntarily submitted information. We collect information that you provide to us during your use of the Website, App and/or Service, such as:

o Personal Information that you enter when registering for or using the Service, including your full name, email address, phone number, billing information, driver’s license information, TLC license information, profile picture and profile information.

 

o Communications with us (e.g., emails, text messages) or with Riders or other Drivers (e.g., verbal or written instructions from Riders) through the Service.

o Information you provide in your user preferences, to customer support services or customer support calls or that you post on any forums or message boards. We may record your customer support calls for quality assurance purposes.

• Information Collected Through Use of the Service. Information collected through the use of the Service includes, but may not be limited to:

o Geolocation data. If you access the Service through a mobile device, we may access, collect, monitor and/or remotely store “geolocation data,” which may include the GPS coordinates of your trip (including pick-up and drop-off data and route information) or similar information regarding the location of your mobile device.

o Contacts. We may access your address book or contacts if you provide us with your permission to do so.

o Transaction data. We collect information created during your various interactions with the Service, including the date and time of a Ride, distance of Ride and amount charged.

• Information collected via technology. Information collected through the use of the Service includes, but may not be limited to:

o If you are using our Website, we collect information from you, including your hardware model, browser type, operating system, Internet Protocol (IP) and domain name. If you are using a mobile device, Leap may also receive your UDID, or another unique identifier, and mobile operating system. We may correlate this information with other Personal Information we have about you. We may also use Cookies and URL information to gather information regarding the date and time you used the Service and the information for which you searched and accessed. “Cookies” are small pieces of information that a website sends to your device while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following your web browser help file directions.

o In connection with your use of the Service, we may receive your call data, including the date and time of calls and SMS messages, the Rider and Driver phone numbers and the content of the SMS messages.

o We may also use third party tracking services, such as Google Analytics, and usage logs, to track and analyze data from users of the Website and/or App.

 

o If you choose to receive payment for Rides via a third party payment provider (e.g., ACH), your Personal Information obtained by the payment provider may be given to us by such payment provider.

o If you choose to log-in to the App or Service via a third party social media website (e.g., Facebook) where and when available, your Personal Information may be provided to us by such social media website.

• Information provided by others.
o We collect information that Riders provide about Drivers, and vice versa, including via

ratings, Submissions and postings on forums or message boards.

2. How We Use Your Information

• Personal Information. We may use your Personal Information to: o Register and administer your Account;
o Provide and maintain the Service;
o Facilitate communications between Riders and Drivers;
o Offer customer support;

o Send communications and administrative emails about the Service;
o Personalize and tailor the features, performance and support of the Website, App and

Service;

o Send you promotional/marketing information, newsletters, offers or other information from us or on behalf of our affiliates or partners;

o Provide you with opportunities and functionality that we think would be of particular interest to you;

o Improve the quality and safety of the Website, App and Service and perform internal operations;

o Analyze, benchmark and conduct research on user data and interactions with the Service; and/or

o Detect, prevent, or otherwise address fraud, security, technical issues and/or suspected or actual violation of the Leap Terms of Use.

• Anonymous Information. We may use Anonymous Information to:

 

o Improve the Website, App and Service and customize the user experience, such as by providing targeted useful features and promotions based on the type of services you seek or provide; and/or

o Aggregate the information collected via Cookies and similar technologies to use in statistical analysis to help us track trends, evaluate the effectiveness of our ads and analyze patterns.

3. How We Share and Disclose Information.

We know how important it is to keep your information confidential. We will not rent, sell or share your Personal Information with third parties except as specifically approved by you at the time of disclosure or under the circumstances described below.

If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may refrain from providing your Personal Information at any time or choose not to download the App and become a Driver. However, our receipt of certain Personal Information from you (for example, to open an Account) is required for your use of the Service.

In addition to using the information collected by us for the purposes described in Section 2 above, we may also share your information as described below. Please review our sharing policy closely, especially with respect to your Personal Information. BY BECOMING A DRIVER, YOU AGREE TO ALLOW US TO SHARE THE PERSONAL INFORMATION YOU PROVIDE TO US IN THE WAYS DESCRIBED BELOW. IN ADDITION, BY DOWNLOADING AND USING THE APP, YOU AGREE TO ALLOW US TO SHARE YOUR GEOLOCATION INFORMATION AS DESCRIBED BELOW. Your ability to make changes to what information is shared is also described below.

• Riders and Drivers

o We share certain information about Riders and Drivers with each other (e.g., name, rating, pick-up and drop-off locations, route information, profile picture) to enable the scheduling and provision of Rides.

o Information provided on any Leap online forum or message board may be viewed by any Riders or Drivers who access the forum or board.

• Third Party Service Providers. We also share Personal Information with vendors, payment providers, consultants and data processers who perform services on behalf of Leap, including without limitation, companies that provide route guidance, estimated times of arrival, email services and hosting for the Website, App and Service. We also share Personal Information with third parties who provide analysis, monitoring, and reports to assist us in preventing and detecting fraudulent transactions and other activity. Leap has selected companies who maintain high standards with respect to privacy and agree to use the Personal Information only to perform specific services on behalf of Leap and in accordance with the terms and conditions of this Privacy Policy.

 

  • Compliance with Laws, Law Enforcement and Safety. We may disclose information we have collected about you: if required to do so by law (or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law), pursuant to requests or orders from law enforcement, or to protect or defend Leap’s, or a third party's, rights or property. We may also reserve the right to disclose information we have collected about you for purposes of protecting the health and safety of our Riders and Drivers, such as in the case of risk of harm or violence against any person.

  • Aggregated Anonymous Information. Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other users (“Aggregated Anonymous Information”). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third parties, and, depending on the circumstances, we may or may not charge third parties for such information, or limit the third parties' use of the same.

  • Business transactions. We may share all or some of your Personal Information with any of our parents, subsidiaries, affiliates, joint venturers, or other companies under common control, in which case we will require them to honor this Privacy Policy. Additionally, in the event we undergo a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and is permitted by this Privacy Policy, and that any entity that acquires us, is merged with us or that acquires our assets may continue to process your Personal Information as set forth in this Privacy Policy.

    4. Your Choices

    By becoming a Driver, you consent to receive certain communications from us. You may modify or opt out of receiving email or text messages sent for marketing purposes by adjusting your Account settings or following the unsubscribe instructions in such messages. Please note that despite any indicated marketing preferences, we may send you administrative messages regarding the Website, App or Service, including, for example, notices of updates to our Privacy Policy.

    5. Location-Based Tracking

    BY REGISTERING AS A DRIVER AND BY USE OF THE SERVICE, YOU CONSENT TO OUR USE OF LOCATION TRACKING SERVICES. YOU EXPRESSLY WAIVE AND RELEASE LEAP FROM ANY AND ALL LIABILITY, CLAIMS, CAUSES OF ACTION, AND DAMAGES WHATSOEVER, ARISING FROM YOUR USE OF THE APPS OR SERVICE, OR IN ANY WAY RELATED TO OUR USE OF LOCATION-BASED AND LOCATION TRACKING INFORMATION.

    6. Limitation on Your Use of Personal Information of Riders

 

You may be given certain personal information concerning Riders seeking transportation (for example name, phone number, address or location, the Executive Account or Business account under which such Rider is an authorized user). YOU AGREE THAT YOU WILL USE SUCH INFORMATION ONLY FOR THE PURPOSE OF PROVIDING THE TRANSPORTATION REQUESTED BY THE RIDER AND FACILITATED BY THE SERVICE. USE OF SUCH INFORMATION FOR ANY OTHER PURPOSE IS STRICTLY PROHIBITED. USE OF SUCH INFORMATION FOR UNINVITED CONTACT WITH ANY RIDER OR PERSON ACCOMPANYING A RIDER IS STRICTLY PROHIBITED.

7. Updating and/or Deleting Your Personal Information.

You may revise your Personal Information by adjusting your Account settings in the App. You may submit a request to delete your Personal Information by contacting us directly at customerservice@leaprides.com. However, please note that we may be required to maintain certain Personal Information, or to maintain certain Personal Information for a period of time, in which case we will comply with your deletion request only after we have fulfilled such requirements. (For example, we may retain your Personal Information for fraud detection or similar purposes.) Be advised that when we delete any Personal Information, it will be deleted from our active database, but may remain in our archives. Note that if we have already disclosed some of your Personal Information to third parties, we cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures. Even after your Personal Information is deleted, we may maintain Anonymous Information from your Account (which, as a reminder, cannot be used to contact or identify you, and is not linked to information that can be used to do so) to use as part of Aggregated Anonymous Information for legitimate business purposes, including analyzing data metrics and conducting internal operations. See Section 3, above, for further information regarding Aggregated Anonymous Information.

8. COPPA.

The Website, App and Service are not directed at or intended for anyone under 18 years of age. Additionally, in accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly collect or solicit Personal Information from individuals under 13 years of age and per Leap’s Terms of Use no one under age 13 may provide any Personal Information to Leap. If we later obtain actual knowledge that a Rider is under 13 years of age, we will take steps to remove that Rider's Personal Information from our systems and delete the Account. If you are the parent or guardian of a minor whom you believe has disclosed Personal Information to us, please contact us at customerservice@leaprides.com so that we may delete and remove such information from our systems.

9. Security and Data Retention.

We are very concerned with safeguarding your information. We employ commercially reasonable administrative, physical and electronic measures designed to protect your information from unauthorized access. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal identifiable data" (as

 

defined in applicable statutes on security breach notification) to you via email, text or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Although guaranteed security does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations.

We will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws. Your consent to such purpose remains valid after termination of our relationship with you.

10. Third Party Websites.

Leap may provide links to other websites that may be of interest to our users. However, we are not responsible for the privacy practices employed by those websites, nor are we responsible for the information or content they contain. This Privacy Policy applies solely to information collected by us through the Website, App and Service; thus when you use a link to go from our website to a third party website, this Privacy Policy is no longer in effect. We encourage users to read and consider the privacy policies of these other websites before using them.

11. Changes to Our Privacy Policy.

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. Your continued use of the Service after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended. We encourage you to bookmark this webpage and review this Privacy Policy regularly.

12. Contact Us.

If you have any questions regarding our Privacy Policy, you can contact us via email at customerservice@leaprides.com.