Privacy Policy

1. Introduction

This Privacy Policy explains how PayCabby, a product operated by ARIG LABS LLC, collects, uses, discloses, and safeguards personal information when individuals and businesses access or use the PayCabby platform, website, and related services (collectively, the "Platform").

PayCabby is designed to operate as a technology platform that facilitates payment workflows and operational tools for transportation companies. This Privacy Policy is intended to provide transparency regarding PayCabby's data practices and to help users understand their privacy rights and choices.

This Privacy Policy applies to personal information collected by PayCabby in connection with the Company accounts created by transportation companies ("Companies" or "Bases"), Authorized users acting on behalf of Companies, Individual contractors or drivers whose information is submitted through the Platform by Companies, Communications with PayCabby, including support inquiries, and Use of the PayCabby website and Platform.

This Privacy Policy does not apply to third-party services, including payment processors, identity verification providers, authentication providers, or other third parties that operate independently of PayCabby. Those third parties process personal information under their own privacy policies and terms.

For purposes of applicable U.S. privacy laws, PayCabby acts as a data controller with respect to personal information it collects and processes for its own business purposes, such as account management, platform operations, compliance, and customer support.

However, in certain contexts, particularly where Companies submit personal information relating to directors, owners, contractors, or drivers, PayCabby may process such information on behalf of the Company, and the Company remains responsible for ensuring it has the lawful right to provide such information to PayCabby.

PayCabby does not act as a bank, lender, money transmitter, or payment processor, and does not independently perform underwriting, lending decisions, or funds custody. Payment processing, wallet services, and identity verification functions are performed by independent third-party service providers, as further described in this Privacy Policy.

Notwithstanding the foregoing, to the extent PayCabby's facilitation of payment-related services causes it to be deemed a "financial institution" solely for purposes of the Gramm-Leach-Bliley Act ("GLBA") and its implementing Regulation P, this Privacy Policy is intended to serve as PayCabby's GLBA-compliant privacy notice. In such capacity, PayCabby's activities remain limited to providing technology and operational support services and do not include lending, underwriting, extending credit, or making financial determinations.

PayCabby qualifies for the annual privacy notice exemption under Regulation P because it does not share Nonpublic Personal Information outside of the permitted exceptions under the Gramm-Leach-Bliley Act, and its privacy practices do not change in a manner that would require additional notice.

2. Information We Collect

PayCabby collects limited personal information necessary to operate the Platform, provide services to Companies, comply with legal obligations, and maintain the Platform's security and integrity. We intentionally minimize data collection and do not collect or store sensitive payment credentials.

2.1 Information You Provide Directly

We collect information voluntarily provided by Companies and their authorized users when creating accounts, using the Platform, or communicating with us.

Company Information: When a transportation company ("Company" or "Base") registers for the Platform, we may collect Legal company name, Business address, Business email address and phone number, Employer Identification Number (EIN), State or country of incorporation, Entity type (e.g., LLC, corporation), Website URL (optional), "Doing Business As" (DBA) name (optional). This information is required to create and maintain a Company account, and to facilitate payment processing and compliance.

Company Directors and Authorized Users: For compliance, security, and account management purposes, we may collect information about Company directors, owners, administrators, and other authorized users, including Full name, Email address, Phone number, Date of birth, Residential or business address, Title or role within the Company, Ownership percentage (where applicable), and Government-issued identification information, such as Social Security Number (SSN), solely for identity verification purposes and processed through third-party providers. Identity-related information is collected to satisfy know-your-customer ("KYC"), anti-fraud, and regulatory obligations and is processed through our third-party payment and verification providers.

Contractor / Driver Information: Where applicable, PayCabby may process limited information relating to contractors or drivers associated with a Company in order to facilitate Company-requested functionality on the Platform, including payout processing. Such information may include first name, last name, email address, and bank account information submitted by the Company for payout purposes.

Bank account information provided for contractors or drivers is transmitted to PayCabby's third-party payment processor to enable payouts. PayCabby does not store full bank account numbers. PayCabby may retain only limited, non-sensitive elements of such information (such as the routing number and the last four digits of the account number) for reference, display, reconciliation, or record-keeping purposes.

Contractors and drivers do not enter into any contractual relationship with PayCabby. Any personal information relating to contractors or drivers is collected and processed solely in connection with services requested by the applicable Company and in accordance with this Privacy Policy.

2.2 Information Collected Automatically

When users access or use the Platform, certain information may be collected automatically for security, authentication, and operational purposes.

Device and Log Information: We may automatically collect IP address, Browser type and version, Operating system, Date and time of access, and Error logs and diagnostic data. This information is used to maintain Platform functionality, prevent fraud, and troubleshoot technical issues.

Session and Authentication Data: To manage user sessions and secure access to the Platform, PayCabby collects session identifiers, authentication tokens, login timestamps, and authentication-related data generated through supported authentication methods, including third-party authentication services and OAuth-based identity providers. This information is used solely for authentication, security, fraud prevention, and access control purposes. PayCabby does not collect or store passwords associated with third-party authentication accounts. Authentication data is processed only to enable secure login functionality and is not used for marketing, profiling, or analytics purposes.

2.3 Information We Do Not Collect

PayCabby is a non-custodial, technology-only platform that does not collect or store sensitive payment credentials.

Payment Card Details: We do not collect, store, or process credit card or debit card numbers, expiration dates, CVV codes, or related card data.

Bank Credentials: PayCabby does not collect or store bank account login credentials, online banking usernames, or passwords. While Companies may submit bank account numbers and routing numbers for contractors or drivers for the sole purpose of facilitating payouts, such information is transmitted directly to PayCabby's third-party payment processor and is not stored by PayCabby, except that PayCabby may retain limited, non-sensitive information such as the routing number and the last four (4) digits of an account number for display, reconciliation, or record-keeping purposes. Additional details regarding payment processing and pass-through handling of financial information as a pass-through are described in Section 3 of this Privacy Policy.

Sensitive Financial Credentials: We do not store sensitive financial credentials or payment authentication data. Our third-party payment processor handles all payment processing, wallet management, and identity verification in accordance with their own privacy and security practices.

2.4 Nonpublic Personal Information

Certain personal information collected or processed through the PayCabby Platform may constitute "Nonpublic Personal Information" ("NPI") as defined under the Gramm-Leach-Bliley Act ("GLBA") and its implementing regulations, including Regulation P. For purposes of GLBA, NPI may include, without limitation:

• Bank account information, including account numbers and routing numbers, submitted by Companies or on behalf of contractors or drivers for payment facilitation;
• Government-issued identification numbers, such as Social Security numbers, are collected solely for identity verification purposes;
• Employer Identification Numbers (EINs) and related business identification data;
• Identity verification and compliance data collected in connection with know-your-customer (KYC) and know-your-business (KYB) requirements.

PayCabby collects and processes such NPI solely for limited, permissible purposes, including facilitating payment workflows, enabling identity verification by third-party service providers, complying with applicable legal and regulatory obligations, preventing fraud, and maintaining Platform security.

Consistent with PayCabby's non-custodial, technology-only role, NPI is not used for lending, underwriting, credit decision-making, or marketing purposes. Where NPI is required for payment processing or compliance verification, it is transmitted securely to regulated third-party service providers, such as PayCabby's payment processor, and handled in accordance with those providers' regulatory obligations and privacy practices.

PayCabby implements reasonable administrative, technical, and organizational safeguards to protect NPI against unauthorized access, disclosure, or misuse, in accordance with applicable GLBA requirements and industry standards.

3. Payment Processing and Identity Verification Data

3.1 Role of Third-Party Payment and KYC/KYB Providers

PayCabby does not operate as a bank, money transmitter, or financial institution. All payment processing, wallet functionality, payouts, and identity verification services are provided by independent third-party service providers, including Moov, which operate under their own terms of service, privacy policies, and regulatory obligations.

These third-party providers are responsible for performing applicable know-your-customer ("KYC"), know-your-business ("KYB"), identity verification, anti-money laundering ("AML"), and transaction monitoring functions in accordance with applicable laws. Such verification may include, without limitation, the collection and validation of business information, employer identification numbers (EINs), director or owner information, and related documentation.

PayCabby's role is limited to facilitating the technical integration between the Platform and such third-party providers. PayCabby does not independently perform KYC, KYB, AML, underwriting, credit evaluation, or regulatory determinations, and does not verify user identity or business eligibility on its own.

To the extent PayCabby may be deemed a "financial institution" solely for purposes of the Gramm-Leach-Bliley Act ("GLBA"), PayCabby's sharing of information with payment processors and verification providers such as Moov is limited to disclosures permitted under GLBA §502(e), including disclosures necessary to process transactions, prevent fraud, comply with legal and regulatory obligations, and engage service providers that perform functions on PayCabby's behalf.

3.2 Data Shared with Moov

To enable payment processing, wallet funding, payouts, and compliance verification, PayCabby may collect certain information from Companies, Company Directors, Authorized Users, and Contractors, and transmit it to its third-party payment processor, Moov, for verification and transaction execution. The information shared with Moov may include:

• Company information, including legal name, DBA (if any), EIN, incorporation type, business address, and related business documentation;
• Company bank account information, including bank account numbers and routing numbers, submitted by Companies to fund platform wallets or initiate withdrawals (which information is transmitted to Moov and not stored in full by PayCabby);
• Company Director and Authorized User information, including names, contact information, dates of birth, ownership percentages, and government-issued identification numbers where required for verification purposes;
• Contractor or Driver information, including identifying information and bank account details submitted to facilitate payouts (with PayCabby retaining only limited reference data, such as routing numbers and the last four digits of account numbers, where applicable); and
• Transaction instructions, authorization data, and related metadata necessary to process payments and maintain transaction records.

Moov processes such information in its capacity as an independent data controller or processor (as applicable), in accordance with its own privacy policy, GLBA obligations, and other applicable regulatory requirements.

Any disclosure of Nonpublic Personal Information ("NPI") to Moov is made solely for purposes permitted under GLBA §502(e), including transaction processing, fraud detection and prevention, compliance with legal obligations, and the provision of payment and verification services. Such disclosures do not constitute a sale of information and do not trigger consumer opt-out rights under GLBA.

PayCabby's involvement is limited to facilitating the secure transmission of data and does not include independent verification, storage of full banking credentials, or direct handling or custody of funds.

3.3 Non-Custodial Processing Model

PayCabby does not receive, hold, or control funds on behalf of any user. All fund movement, wallet balances, payouts, and transaction settlements are executed exclusively by Moov through its regulated payment infrastructure.

PayCabby does not store payment card numbers, online banking login credentials, or full government-issued identification numbers. Where required for payment processing or know-your-customer / know-your-business (KYC/KYB) verification, sensitive information, such as bank account numbers, routing numbers, or Social Security numbers, is transmitted securely to Moov and processed directly by Moov in accordance with its compliance obligations.

For reference and operational purposes only, PayCabby may retain limited, non-sensitive fragments of such information (for example, the last four digits of a bank account number or Social Security number), but does not retain full account numbers, full identification numbers, or credentials capable of accessing financial accounts. Any retained fragments, on their own, are not sufficient to initiate transactions or perform identity verification.

3.4 Transaction Metadata Retained by PayCabby

While PayCabby does not store sensitive payment credentials or execute financial transactions independently, it may retain limited transaction-related metadata for operational, compliance, auditing, reporting, invoicing, and reconciliation purposes.

Such metadata may include transaction timestamps, transaction status (e.g., pending, completed, failed), transaction amounts, associated Company or Contractor identifiers, and reference IDs generated by the applicable payment processor.

The Platform may allow Companies to initiate payouts through batch uploads (e.g., CSV files), where each row represents an individual trip or payment record for a contractor or driver. Required fields typically include the contractor's email address and the payment amount. Companies may also submit optional trip-related metadata, including notes or custom data fields defined by the Company, such as trip dates, locations, reference IDs, vehicle numbers, or other operational details ("Trip Metadata").

Trip Metadata submitted by a Company is stored and displayed to the Company within the Platform and may also be included on payout receipts or invoices made available to the associated contractor or driver for transparency and reconciliation.

PayCabby does not control, review, validate, or screen Trip Metadata or other Company-submitted metadata for accuracy, legality, or regulatory compliance. Companies are solely responsible for determining what information they include in batch uploads and for ensuring that any data submitted complies with all applicable laws, regulations, and industry-specific requirements, including but not limited to privacy, data protection, and healthcare-related regulations such as HIPAA.

Companies should not submit sensitive, regulated, or protected information unless they have independently determined that doing so is lawful and appropriate. PayCabby expressly disclaims any responsibility or liability arising from the content of Trip Metadata or other information submitted by Companies.

4. How We Use Personal Information

PayCabby uses personal information solely for purposes necessary to operate the Platform, comply with applicable laws, and manage risk, consistent with PayCabby's role as a technology service provider and non-custodial platform.

4.1 Platform Operation and Account Management

We use personal information to operate, maintain, and provide access to the PayCabby Platform, including to create, authenticate, and manage Company accounts and authorized user access, verify account ownership and administrative authority, enable Companies to manage drivers and initiate payment-related actions through the Platform, maintain internal records associated with account activity, and communicate operational notices related to the Platform.

4.2 Identity Verification and Compliance

We use personal information to support identity verification, compliance, and fraud-prevention requirements, including by collecting required Company, director, and authorized user information, transmitting identity and verification data to third-party providers (such as Moov) for KYC, identity verification, and compliance checks, responding to lawful requests from regulators, law enforcement, or payment partners, and enforcing our Terms and Conditions and applicable Platform policies. PayCabby does not perform identity verification internally and does not make independent KYC or underwriting determinations.

4.3 Transaction Facilitation and Reporting

We use limited transaction-related information to facilitate Platform functionality, including enabling Companies to initiate payouts through third-party payment processors, displaying transaction status, confirmations, and summaries within the Platform, generating operational and reconciliation reports for Company users, and maintaining audit logs related to Platform activity. PayCabby does not store payment card numbers, bank credentials, or sensitive payment authentication data.

4.4 Customer Support and Communications

We use personal information to provide customer support and respond to inquiries, including communicating with Companies, authorized users, and administrators regarding account issues; responding to support requests and troubleshooting inquiries; sending transactional and service-related communications; and providing updates on Platform availability, security, or policy changes. PayCabby does not send third-party advertising communications and does not sell personal information.

4.5 Legal, Compliance, and Risk Management

We use personal information where necessary to protect PayCabby, our users, and third parties, including to detect, investigate, and prevent fraud, misuse, or security incidents, enforce contractual obligations and Platform rules, comply with applicable legal, tax, and regulatory requirements, resolve disputes and respond to legal claims, and maintain business continuity, security, and risk controls.

5. Legal Bases for Processing

5.1 Contractual Necessity

PayCabby processes personal information as necessary to enter into, perform, and administer contracts with Companies that use the PayCabby platform. This includes processing personal data to create and manage user accounts, providing access to platform features and functionality, facilitating payment initiation and transaction-related workflows through integrated third-party providers, and communicating with users regarding account activity, service updates, and support requests.

Where personal information is required to provide the services requested by a Company, failure to provide such information may prevent PayCabby from offering access to certain features or services.

5.2 Legal and Regulatory Obligations

PayCabby may process personal information as necessary to comply with applicable legal, regulatory, and compliance obligations, including but not limited to know Your Customer (KYC), identity verification, and anti-fraud requirements imposed by payment processors and financial partners, recordkeeping, audit, and reporting obligations required under applicable U.S. laws, responding to lawful requests from courts, regulators, law enforcement authorities, or other governmental bodies.

Where such processing is required by law, PayCabby may process personal information without obtaining additional consent.

5.3 Legitimate Business Interests

PayCabby processes personal information where necessary for its legitimate business interests, provided that the rights and freedoms of individuals do not override such interests. These legitimate interests include operating, maintaining, and improving the PayCabby platform, ensuring platform security, integrity, and fraud prevention, monitoring usage, diagnosing technical issues, optimizing performance, enforcing contractual terms, policies, and acceptable use standards, and protecting the rights, property, and safety of PayCabby, its users, and third parties. PayCabby carefully balances these interests against user privacy expectations and implements appropriate safeguards.

5.4 Consent Where Required

In circumstances where applicable law requires explicit consent for certain processing activities, PayCabby will obtain such consent prior to processing personal information. This may include, where applicable, optional communications not strictly necessary for platform operation, certain future features involving expanded data use, and any processing activity that requires consent under applicable privacy laws.

Where consent is relied upon, individuals may withdraw their consent at any time, subject to legal or contractual restrictions and to PayCabby's continued ability to provide its services.

6. Data Sharing and Disclosure

6.1 Service Providers and Vendors

PayCabby may share Personal Information with trusted third-party service providers that perform services on our behalf and under our instructions. These service providers are authorized to use Personal Information only as necessary to provide services to PayCabby and for no other purpose. Such services may include technical support, infrastructure hosting, security monitoring, and account authentication.

All service providers are required to implement reasonable administrative, technical, and organizational safeguards to protect Personal Information and to process such data in a manner consistent with applicable data protection laws.

6.2 Payment Processing and Verification Partners

PayCabby shares certain Personal Information with third-party payment processing and identity verification partners, including Moov, to enable transactions, verify identities, comply with applicable financial regulations, and prevent fraud.

Information shared may include Company information, authorized user details, director information, and Contractor/Driver identification data as required by applicable Know Your Customer (KYC), anti-money laundering (AML), and related compliance obligations. These third-party partners process such data pursuant to their own privacy policies and regulatory obligations. PayCabby does not control or is responsible for how such partners independently process Personal Information in their capacity as regulated service providers.

6.3 Hosting and Infrastructure Providers

PayCabby uses third-party cloud hosting and infrastructure providers to host, operate, and maintain the Platform. These providers supply computing, storage, and related infrastructure services necessary for the operation of PayCabby's systems.

Such providers are engaged solely to support PayCabby's operations and do not have permission to access or use personal information for their own purposes. They are contractually obligated to protect information, maintain appropriate security measures, and process data only in accordance with PayCabby's instructions and applicable law.

6.4 Legal and Regulatory Disclosures

PayCabby may disclose Personal Information if required to do so by law, regulation, subpoena, court order, or governmental request, or if PayCabby reasonably believes that such disclosure is necessary to Comply with applicable legal or regulatory obligations, Respond to lawful requests from public authorities, Protect the rights, property, or safety of PayCabby, its users, or others, Enforce the Platform's Terms and Conditions; or Detect, prevent, or address fraud, security, or technical issues.

Where legally permitted, PayCabby will take reasonable steps to notify affected users prior to such disclosure.

6.5 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, financing, or similar business transaction, Personal Information may be disclosed or transferred as part of that transaction. In such cases, PayCabby will ensure that any recipient of Personal Information agrees to protect it in a manner consistent with this Privacy Policy.

6.6 GLBA Information Sharing Disclosures

To the extent PayCabby is deemed a "financial institution" for purposes of the Gramm-Leach-Bliley Act ("GLBA") and its implementing regulations (Regulation P), this section describes PayCabby's practices with respect to the collection, use, and disclosure of Nonpublic Personal Information ("NPI").

(a) Categories of Nonpublic Personal Information Shared: In connection with providing the Platform and facilitating payment-related services, PayCabby may share the following categories of NPI, as defined under GLBA, where applicable:

• Identifiers and contact information (such as names, email addresses, phone numbers, and addresses);
• Business identification information, including Employer Identification Numbers (EINs) and incorporation details;
• Identity verification information for company owners, directors, or authorized users (including dates of birth and government-issued identification numbers);
• Bank account information submitted for funding wallets or facilitating payouts (including account numbers and routing numbers transmitted to payment processors, and limited reference data retained by PayCabby, such as the last four digits of account numbers);
• Transaction-related data and payment instructions necessary to process payouts and maintain records.

(b) Categories of Non-Affiliated Third Parties: PayCabby may disclose NPI to the following categories of non-affiliated third parties:

• Payment processing, wallet, and compliance service providers (such as Moov);
• Identity verification, KYC/KYB, and anti-fraud service providers;
• Cloud hosting, infrastructure, and security service providers;
• Professional advisors (including legal, accounting, and audit providers) were necessary for compliance or risk management;
• Government authorities or regulators that require disclosure by law.

(c) Purpose of Information Sharing: PayCabby shares NPI solely as permitted under GLBA §502(e) and applicable regulations, including for the following purposes:

• Processing and executing payment transactions and payouts requested by Companies;
• Performing identity verification, know-your-customer (KYC), know-your-business (KYB), anti-money laundering (AML), and fraud-prevention functions;
• Maintaining accounts, records, and audit trails;
• Providing services through authorized service providers acting on PayCabby's behalf;
• Complying with applicable legal, regulatory, and contractual obligations.

All such disclosures are limited to what is reasonably necessary to accomplish these purposes.

(d) No Sale of Nonpublic Personal Information: PayCabby does not sell, rent, license, or disclose Nonpublic Personal Information to third parties for their own marketing purposes, and does not share NPI in a manner that would require consumer opt-out rights under GLBA.

Where NPI is shared with service providers, such providers are contractually required to maintain the confidentiality and security of such information and to use it only for the permitted purposes described above.

7. Cookies and Tracking Technologies

PayCabby uses session cookies and similar technologies that are strictly necessary to operate the Platform. Session cookies are temporary files stored on a user's device for the duration of an active session and are automatically deleted when the session ends or the browser is closed.

These cookies enable core Platform functionality, including secure authentication, session management, and protection against unauthorized access.

Session cookies used by PayCabby serve the following essential purposes:

• Maintaining user authentication and login status
• Enabling secure access to user accounts and administrative features
• Preventing fraudulent or unauthorized activity
• Ensuring continuity of user sessions during Platform use

PayCabby's session cookies do not collect information for advertising purposes and are not used to track users across websites, applications, or services.

PayCabby does not use analytics, advertising, or tracking cookies, tracking pixels, or similar technologies for marketing, behavioral profiling, cross-site tracking, or advertising attribution. No Google Analytics, Meta Pixel, or similar third-party tools are deployed.

Because PayCabby uses only cookies and technologies that are strictly necessary for Platform operation, additional cookie consent is generally not required under applicable U.S. privacy laws.

8. Data Retention

PayCabby retains personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including operating the Platform, complying with applicable legal obligations, resolving disputes, enforcing agreements, and maintaining appropriate business records.

Retention periods may vary depending on the type of information, the purpose for which it is processed, and applicable legal or regulatory requirements. Factors considered when determining retention periods include:

• the duration of the Company's relationship with PayCabby;
• whether the information is necessary to provide ongoing Platform functionality;
• whether retention is required to comply with applicable laws, regulations, accounting rules, or contractual obligations; and
• whether retention is necessary for fraud prevention, dispute resolution, or audit purposes.

Certain information may be retained for longer periods where required or permitted by applicable law or regulation, including information subject to anti-money laundering (AML), know-your-customer (KYC), know-your-business (KYB), identity verification, financial recordkeeping, audit, reporting, or similar legal or regulatory requirements, as well as information relevant to legal claims, investigations, or regulatory inquiries.

Where PayCabby relies on third-party service providers (such as payment processors or identity verification providers), those providers may retain personal information in accordance with their own legal obligations and retention policies. PayCabby does not control the retention practices of independent third parties acting as separate data controllers.

Upon account closure or termination, PayCabby will take reasonable steps, where practicable, to delete or anonymize personal information associated with the account, unless continued retention is required for legitimate business purposes or legal, regulatory, or compliance reasons.

Information that may be retained following account closure includes records necessary to comply with applicable laws or regulations, information required to prevent fraud or abuse, backup or archival copies maintained for system integrity and security, and data retained in aggregated or anonymized form that no longer identifies any individual.

Users may request deletion of their personal information in accordance with applicable privacy laws, subject to the limitations described above.

9. Data Security

PayCabby implements reasonable administrative, technical, and physical safeguards designed to protect Personal Information, including any Nonpublic Personal Information ("NPI"), against unauthorized access, loss, misuse, alteration, or disclosure. These safeguards are appropriate to the nature of the information processed and the risks associated with such processing and include internal policies, procedures, access controls, and security measures governing data handling and system access.

To the extent PayCabby is deemed subject to the Gramm-Leach-Bliley Act ("GLBA") Safeguards Rule, PayCabby maintains safeguards that are designed to be consistent with the requirements of that rule, taking into account its role as a technology platform and non-custodial service provider.

PayCabby's security practices are intended to support and complement, rather than replace, the security measures implemented by its third-party payment processing, identity verification, and compliance partners, which operate their own regulated infrastructure and security programs.

Access to Personal Information is limited to authorized personnel and service providers who require it for legitimate business purposes, including platform operation, compliance, customer support, and risk management. Access rights are granted based on role and responsibility and are subject to periodic review.

Authentication mechanisms, including third-party OAuth services, help prevent unauthorized access to accounts. Users are responsible for maintaining the confidentiality of their login credentials and for all activity conducted through their accounts.

While PayCabby takes reasonable measures to protect Personal Information, no system or method of data transmission over the internet is completely secure. Accordingly, PayCabby does not guarantee absolute security and cannot ensure or warrant that security incidents, unauthorized access, or data breaches will never occur.

To the maximum extent permitted by applicable law, PayCabby shall not be liable for damages arising from security incidents or unauthorized access to Personal Information that occur despite the implementation of reasonable safeguards, including incidents attributable to third-party service providers, infrastructure providers, or factors beyond PayCabby's reasonable control.

10. User Rights and Choices

10.1 Access and Correction

Subject to applicable law, you may request access to the personal information we maintain about you and request that inaccurate, incomplete, or outdated information be corrected. Requests may be submitted by contacting us using the information provided in Section 13 below.

To protect your information, we may require verification of your identity and, where applicable, your authority to act on behalf of a Company before fulfilling such requests.

Where applicable under U.S. state privacy laws, you may also have the right to receive a copy of certain personal information in a portable and readily usable format.

10.2 Deletion Requests

Subject to applicable law, you may request the deletion of your personal information, subject to certain limitations. We may retain personal information where retention is necessary to:

• comply with legal, regulatory, accounting, or reporting obligations;
• maintain records required for fraud prevention, security, or audit purposes;
• complete transactions, provide the Platform, or enforce our Terms and Conditions; or
• satisfy obligations to payment processors, identity verification providers, or other service providers.

Where personal information has been shared with third parties (such as payment processors or identity verification providers), deletion requests may need to be directed to those third parties in accordance with their own policies and legal obligations. We do not control the retention practices of third parties acting as separate data controllers.

10.3 Opt-Out of Communications

You may opt out of receiving non-essential communications from us by following the unsubscribe instructions included in such communications or by contacting us directly.

Please note that even if you opt out of non-essential, marketing, or promotional messages, we may continue to send transactional, administrative, security-related, or service communications that are necessary to operate your account, provide the Platform, or comply with applicable legal or regulatory obligations.

10.4 Account Management

Companies and authorized users may review, update, or manage certain account information through the PayCabby Platform. It is your responsibility to ensure that all information associated with your account remains accurate and up to date.

Failure to maintain accurate or current information may result in limitations on Platform functionality, suspension, or termination of access in accordance with our Terms and Conditions.

11. U.S. State Privacy Rights

11.1 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you may have certain rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the "CCPA/CPRA"), subject to applicable law. These rights may include:

• Right to Know: The right to request information about the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes for which it is used, and the categories of third parties with whom it is disclosed.
• Right to Delete: The right to request deletion of personal information we have collected from you, subject to applicable legal exceptions.
• Right to Correct: The right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: PayCabby does not sell personal information and does not share personal information for cross-context behavioral advertising, as those terms are defined under the CCPA/CPRA.
• Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights.

PayCabby collects and uses personal information solely for business and operational purposes, including providing the Platform, compliance, fraud prevention, security, and transaction facilitation. We do not use personal information for targeted advertising, behavioral profiling, or marketing analytics.

11.2 Other State Privacy Laws

Depending on your state of residence, you may have additional rights under applicable U.S. state privacy laws, including by way of example laws in Virginia, Colorado, Connecticut, Utah, and other jurisdictions that have enacted consumer data protection statutes.

These rights may, where applicable, include the ability to access the personal information we maintain about you, request the correction or deletion of that information, obtain information about data processing activities, and exercise any appeal rights made available under applicable law.

PayCabby will honor applicable privacy rights as required by relevant state laws, subject to applicable legal and regulatory limitations.

To the extent applicable, PayCabby complies with state-level financial privacy and data protection laws governing the handling of financial information, to the extent such laws apply to PayCabby's activities, including any state statutes that supplement or expand upon federal privacy requirements.

11.3 Exercising State Privacy Rights

To exercise any applicable privacy rights, you may contact us using the contact details provided in this Privacy Policy. We may need to verify your identity and, where applicable, your authority to act on behalf of a Company before processing your request. Verification may require confirming certain account- or company-related information.

Requests will be handled within the timeframes required by applicable law. If a request cannot be fulfilled, we will provide an explanation to the extent required or permitted by law.

Authorized agents may submit requests on behalf of users where permitted by law, subject to appropriate verification and authorization procedures.

11.4 GLBA Opt-Out Rights (Regulation P Disclosure)

To the extent PayCabby is deemed a "financial institution" for purposes of the Gramm-Leach-Bliley Act ("GLBA") and its implementing Regulation P, PayCabby provides the following disclosure regarding opt-out rights.

PayCabby does not disclose Nonpublic Personal Information ("NPI") to non-affiliated third parties outside of the exceptions permitted under GLBA §502(e). Specifically, PayCabby shares NPI solely for purposes permitted under applicable law, such as processing payment transactions, performing identity verification and fraud prevention, complying with legal and regulatory obligations, and engaging service providers that perform functions on PayCabby's behalf.

Because PayCabby's information-sharing practices are limited to these permitted exceptions, users do not have the right to opt out of such disclosures under GLBA or Regulation P. PayCabby does not sell, rent, license, or otherwise disclose NPI to non-affiliated third parties for their own independent marketing or commercial purposes.

12. Children's Privacy

The PayCabby platform is intended solely for use by business entities and individuals acting on behalf of such entities in a professional or commercial capacity. The platform is not designed for, directed to, or intended for use by children.

PayCabby does not knowingly offer services to, solicit information from, or permit registration by any individual under the age of thirteen (13). Access to and use of the platform are limited to authorized representatives of transportation companies, contractors, and other individuals legally capable of entering into binding agreements under applicable law.

If you are under the age of thirteen (13), you are strictly prohibited from accessing, using, or submitting any information through the PayCabby platform. Any attempt by a minor to register for or use the platform constitutes a violation of this Privacy Policy and the applicable Terms and Conditions.

PayCabby does not knowingly collect, use, store, or disclose personal information from children under the age of thirteen (13). We do not intentionally design our services, registration processes, or data collection practices to solicit information from minors.

In the event that PayCabby becomes aware that personal information has been inadvertently collected from a child under the age of thirteen (13) without verified parental or guardian consent, we will take prompt and reasonable steps to delete such personal information from our records, disable or terminate the associated account, where applicable, and prevent further collection or processing of such information.

Parents or legal guardians who believe that a child has provided personal information to PayCabby without appropriate consent are encouraged to contact us using the details provided in the Contact Information section of this Privacy Policy. Upon receipt of such a request, PayCabby will investigate the matter and take appropriate corrective action in accordance with applicable law.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or PayCabby's data practices, you may contact us at:

To exercise your privacy rights or submit a request relating to your personal information (including requests to access, correct, or delete data), please get in touch with us using one of the methods listed above.

For security purposes, we may require you to verify your identity before processing certain requests. We will respond to verified requests within the timeframe required under applicable law.