Driver Privacy Policy

Last Updated: September 30, 2025

This Driver Privacy Policy (“Policy”) explains how Local Motion Endorsements LLC (“Local Motion,” “we,” “us,” “our”) collects, uses, discloses, and protects personal information of drivers (“Drivers,” “you”) who use our Platform. This Policy supplements any broader privacy policy we may publish and should be read together with our Driver Terms of Service.

Important: The Platform may collect continuous, precise geolocation (including in the background) to compute mileage, determine eligibility, and detect fraud. If you disable permissions, your miles may be ineligible and Campaign participation may be limited.

1. Who We Are; Contact

Controller / Business Contact: Local Motion Endorsements LLC, Attn: Privacy Officer, [INSERT MAILING ADDRESS], New York, USA. Email: support@drivewithlocalmotion.com.

Scope: This Policy applies to personal information we collect about Drivers who use the Platform, including those who enroll in or participate in Campaigns.

2. Information We Collect

We collect information from you, your device, and certain third parties (such as payment and identity verification providers). Categories may include:

Identity & Verification: Name, date of birth, government-issued ID (e.g., driver’s license), selfie/photo verification, and verification results/status.
Contact & Residential: Email, phone number, home/mailing address (including for Base Radius eligibility and shipping Ad Materials where applicable).
Vehicle Information: Make/model/year, color, plate number, vehicle photos, and Ad Materials installation photos.
Payment, Tax & Compliance: Payout account details (collected/managed by our payment processor), payout status, tax information you provide (e.g., SSN/EIN where applicable), and tax classification.
Location & Movement Data (Sensitive): Precise GPS location (including background), timestamps, speed/inferred movement, derived routes and mileage, and inferences such as inside/outside Base Radius and Target Zone status.
Campaign & Earnings: Campaigns joined/assigned, Eligible Miles, statement totals, payout amounts, verification history (e.g., decal upload approvals/rejections), and performance/eligibility flags.
Device & Technical: Device type/model, OS version, app version, device identifiers, IP address, language settings, crash logs, diagnostics, and other technical data.
Usage Data: Screens/actions in the app, login/session data, feature usage, and support interactions.
Cookies / SDKs / Tracking: If you use web components or our sites, we may use cookies, pixels, and SDKs for authentication, analytics, and performance.

Sensitive Information: Some data (such as precise geolocation and government ID data) may be considered “sensitive” under certain laws. We process sensitive data only as needed for Platform operations, security, fraud prevention, legal compliance, and to provide the services you request.

3. How We Use Information

Provide and operate the Platform: create and manage accounts, enroll Drivers in Campaigns, deliver features, and provide support.
Track and calculate mileage: capture Location Logs, compute Eligible Miles, and generate monthly statements (typically end-of-month when a Campaign is active).
Eligibility and compliance: determine Base Radius and Target Zone status; verify Ad Materials installation; enforce Campaign requirements; prevent ineligible miles from being paid.
Payments and payouts: facilitate payouts through processors, handle failed payout workflows, and maintain payout records for reconciliation.
Fraud prevention and security: detect GPS spoofing, tampering, account abuse, and other suspicious activity; protect the integrity of the Platform and Businesses.
Communications: send service-related messages (account, verification, Campaign updates, statement notices, disputes, policy changes).
Analytics and improvement: debug, monitor performance, develop and improve features, and optimize user experience.
Legal compliance and enforcement: comply with legal obligations (tax, accounting, audits) and enforce our Terms.
Marketing: send marketing messages where permitted by law; you can opt out at any time.

4. Legal Bases for Processing (GDPR / UK GDPR Where Applicable)

Contract: to provide the Platform and fulfill our obligations under the Terms and any applicable agreements.
Consent: where required (e.g., certain marketing, and where local law treats precise/background location as consent-based).
Legitimate Interests: to prevent fraud, ensure security, improve the Platform, and administer Campaign operations (balanced against your rights).
Legal Obligations: tax, accounting, regulatory, and responding to lawful requests.

5. How We Share Information

We may share your information as follows:

Businesses (Campaign Administration): We may share relevant Campaign administration data with the Business you are associated with, such as verification status (approved/rejected), Eligible Miles summaries, and performance/eligibility metrics needed to operate the Campaign and support payment administration. We do not share your precise real-time location with a Business unless a feature explicitly requires it and you are notified.
Payment Processors: We use third-party processors (e.g., Stripe or similar) for identity checks (where applicable) and payouts. These processors receive the information needed to provide their services and are subject to their own terms and privacy practices.
Service Providers: Vendors that help us run the Platform (hosting, analytics, customer support tools, security, verification, communications, mapping/geocoding, fraud detection).
Legal and Safety: To comply with law, respond to lawful requests, protect rights and safety, investigate fraud, and enforce agreements.
Corporate Transactions: In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets.

No Sale of Personal Information: We do not sell your personal information in the traditional sense. If applicable law (such as California’s “sale” or “sharing” definitions) treats certain disclosures (e.g., some cross-context behavioral advertising) as “sale” or “sharing,” you may have the right to opt out as described below.

6. Location Tracking; Background Collection

Continuous GPS: The Platform may collect precise location data continuously, including when the app is in the background, to compute mileage, determine eligibility (Base Radius/Target Zones), detect fraud, and support auditing.
Disabling Permissions: If you disable location permissions or background tracking, the Platform may be unable to record Eligible Miles and your miles may be ineligible.
Derived Data: We may generate derived data from Location Logs (routes, mileage totals, Target Zone status, anomaly flags) and store aggregated results for statements, analytics, and fraud prevention.

7. Cookies and Tracking Technologies

Where applicable (e.g., our websites or embedded web components), we use cookies, SDKs, and similar technologies to authenticate sessions, secure accounts, analyze usage, and measure performance. You can manage cookies via your browser/device settings; disabling them may affect functionality.

8. Data Retention

We retain personal information for as long as reasonably necessary to provide the Platform and for legitimate business purposes (including fraud prevention, audits, dispute handling, and legal compliance). As a baseline, we generally retain Driver account and Campaign records for three (3) years after your last activity, unless a longer retention period is required or permitted by law (e.g., tax/accounting obligations, legal claims, or fraud investigations). We may retain de-identified or aggregated data longer.

9. Security

We use reasonable administrative, technical, and physical safeguards (such as encryption in transit, access controls, and monitoring). No system is 100% secure. You are responsible for maintaining the confidentiality of your credentials and promptly reporting suspicious activity.

10. Your Privacy Rights

10.1 General Rights

Access: request a copy of personal information we hold about you.
Correction: request correction of inaccurate or incomplete information.
Deletion: request deletion of certain personal information, subject to legal and operational exceptions.
Portability: request a portable copy of certain data where required by law.
Restriction / Objection: object to or request restriction of certain processing (where applicable).

10.2 California (CCPA/CPRA) Disclosures

Right to Know: request details about categories and specific pieces of personal information collected, used, and disclosed.
Right to Delete: request deletion, subject to exceptions.
Right to Correct: request correction of inaccurate personal information.
Right to Opt Out of Sale/Sharing: opt out of certain disclosures that may be considered “sale” or “sharing” under California law.
Right to Limit Use of Sensitive Personal Information: where applicable, you may have rights to limit certain uses of sensitive personal information, subject to exceptions for providing services and ensuring security.
Non-Discrimination: we will not discriminate for exercising your rights.

To submit a request, contact support@drivewithlocalmotion.com. We may need to verify your identity and/or account before fulfilling requests. If you use an authorized agent, we may require proof of authorization.

11. International Transfers

We may process information in the United States and other countries. Where required, we use appropriate safeguards for cross-border transfers, such as Standard Contractual Clauses (SCCs), or other lawful mechanisms.

12. Children’s Privacy

The Platform is not intended for individuals under 18, and we do not knowingly collect personal information from children.

13. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated via email and/or in-app notice. Continued use after the effective date constitutes acceptance.

14. Contact

Local Motion Endorsements LLC — Attn: Privacy Officer — [INSERT MAILING ADDRESS], New York, USA — support@drivewithlocalmotion.com.

Driver-Specific Supplement – Eligibility Concepts

Base Radius: Miles outside a 40-mile radius of your residential address on file are generally ineligible unless explicitly approved and reflected in the Platform.
Target Zones: Businesses may define Target Zones (ZIP/polygon geofences) paid at a premium rate. We may use point-in-polygon and related methods to determine in/out status.
Calculation & Disputes: We may smooth/deduplicate anomalous data. Dispute mileage within 30 days of statement issuance at support@drivewithlocalmotion.com.