PRIVACY POLICY

I. Introduction When you use AXYZ, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices. This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. 

II. Overview A. Scope This notice applies to users of AXYZ’s services anywhere in the world, including users of AXYZ’s apps, websites, features, or other services. This notice describes how AXYZ collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world, unless covered by a separate privacy notice. This notice specifically applies to drivers which are individuals that download and use the AXYZ app while driving their vehicles and to service providers that will provide services to those drivers (repair shops, gas stations, car wash, roadside assistance providers, and others). 

This notice also governs AXYZ’s other collections of personal data in connection with its services. For example, we may collect the contact information of individuals who use accounts owned by AXYZ for Business customers, or of owners or employees of Businesses that use corporate services. All those subjects to this notice are referred to as “users” in this notice. In addition, please note the following: · For users in Argentina: The Public Information Access agency, in its role of Regulating Body of Law 25.326, is responsible for receiving complaints and reports presented by any data subjects who believe their rights have been impacted by a violation of the local data protection regulation. · For users in Brazil: Please see here for information regarding AXYZ’s privacy practices required under Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados – LGPD). · For California users: Information regarding AXYZ’s privacy practices related to the California Consumer Privacy Act (CCPA) is that AXYZ does not sell your data — we are not data brokers, and we don’t put your data on the open market. However, under the CCPA, some sharing of personal information necessary to provide you with personalized ads may be considered a “sale,” even if no money is exchanged. You may opt-out of such sharing by sending an email to privacy@go2a.xyz. If you opt out, AXYZ will stop sharing your information with some of its advertising partners, and you will no longer receive personalized offers from AXYZ on some sites or services. Our practices are subject to applicable laws in the places in which we operate. 

This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. Please contact us here or through the addresses below with any questions regarding our practices in a particular country or region. B. Data controller and transfer Benefleet Technologies S.A. is the data controller for the personal data collected in connection with use of AXYZ’s services. AXYZ operates, and processes personal data, globally. We may also transfer such data to countries other than the one where our users live or use AXYZ’s services. We do so in order to fulfill our agreements with users, such as our Terms of Use, or based on users’ prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses. Questions, comments, and complaints about AXYZ’s data practices can be submitted to privacy@go2a.xyz. You may also use this form to submit a question to AXYZ’s Data Protection Officer. 

III. Data collections and uses A. The data we collect AXYZ collects personal data: · provided by users to AXYZ, such as during account creation · created during use of our services, such as location, app usage, and device data · from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities The following personal data is collected by or on behalf of AXYZ: 1. Data provided by users. This includes: · User profile: We collect data when users create or update their AXYZ accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of drivers and delivery persons, emergency contact information, user settings, and evidence of health or fitness to provide services using AXYZ apps. 

This also includes gender and/or occupation. · Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties. We may also infer demographic data from other data collected from users. For example, where necessary to enable features that allow women to provide or receive services from other women, we may infer gender using their first name. In such cases, we enable users to change their gender if necessary via in-app settings. · User content: We collect the data submitted by users when they contact AXYZ customer support, provide ratings or compliments for other users, or services providers, or otherwise contact AXYZ. This may include feedback, photographs or other recordings collected by users, including audio or video recordings (such as from dashcams) submitted by users in connection with customer support. This also includes metadata relating to the method you use to communicate with AXYZ. 2. Data created during use of our services. This includes: · Location data (driver): We collect drivers’ precise or approximate location data, including to enable rides and qualification of the rides. AXYZ collects this data when the AXYZ app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device. · Location data (drivers). We collect riders’ precise or approximate location data to enable and enhance use of our apps, including to driver’s feedback. We collect such data from users’ mobile devices if they enable us to do so. (See “Choice and transparency” below for information on how drivers can enable location data collection). AXYZ collects such data from the time a ride starts until it is finished (and may indicate such collection via an icon or notification on your mobile device depending on your device’s operating system), and any time the app is running in the foreground (app open and on-screen) of their mobile device. Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, payment transaction information (such as a repair shops or gas stations and location and amount of transaction), service information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person. ·

 Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser. We may also collect data regarding the third-party sites or services used before interacting with our services, which we use for marketing. (Please see “How We Use Data” below for more information on how we market our services to users). In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Notice. · Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data. · Communications data: We enable users to communicate with each other and AXYZ through AXYZ’s mobile apps and websites. For example, we enable drivers and services providers, to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, AXYZ receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. AXYZ may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our services and features, and for analytics. 3. Data from other sources. These include: · Users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s personal data from that user. · AXYZ account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of AXYZ for Business accounts. · users or others providing information in connection with claims or disputes. · AXYZ business partners through which users create or access their AXYZ account, such as payment providers, social media services, or apps or websites that use AXYZ’s APIs or whose APIs AXYZ uses. · AXYZ business partners in connection with debit or credit cards issued by a financial institution in partnership with AXYZ to the extent disclosed in the terms and conditions for the card. · vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements · insurance, vehicle, or financial services providers for drivers and/or delivery persons · partner transportation companies (for drivers or delivery persons who use our services through an account associated with such a company) · publicly available sources · marketing service providers or data resellers whose data AXYZ uses for marketing or research · law enforcement officials, public health officials, and other government authorities AXYZ may combine the data collected from these sources with other data in its possession. B. How we use personal data AXYZ uses personal data to enable reliable and convenient vehicle management and other products and services. We also use such data: · to enhance the safety and security of our users and services · for customer support · for research and development · to enable communications between users · to send marketing and non-marketing communications to users · in connection with legal proceedings AXYZ does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

 

 We use personal data we collect: 1. To provide our services. AXYZ uses data to provide, personalize, maintain, and improve our services. This includes using data to: · create/update accounts · enable transportation and vehicle services (such as using location data to provide feedback on the path chose and others), features that involve data sharing (such as driver’s safety score and others). · process payments · track and share the progress of rides · facilitate insurance, vehicle, invoicing, or financing solutions · perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends. AXYZ performs the above activities, including the collection and use of location data for purposes of these activities, on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users. 2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes: · using device, location, user profile, usage, and other data to prevent, detect, and combat fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our services by unauthorized drivers, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts. · using user ratings, reported incidents, and other feedback to encourage compliance with our Community Guidelines and as grounds for deactivating users with low ratings or who otherwise violated such guidelines in certain countries. AXYZ performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users, and/or for purposes of the legitimate safety and security interests of AXYZ or other parties, including users and members of the general public. 3. Customer support. AXYZ uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes. AXYZ performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users. 4. Research and development. We may use personal data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our services, and develop new services and features. AXYZ performs the above activities on the grounds that they are necessary to fulfil our obligations to users under our Terms of Use or other agreements with users in improving our existing services and features, or for purposes of AXYZ’s legitimate interests developing new services and features. 5. Enabling communications between users. For example, a driver may message or call a rider to confirm a pickup location, a rider may contact a driver to retrieve a lost item, or a restaurant or delivery person may call a delivery recipient with information about their order. AXYZ performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users. 6. Marketing. AXYZ may use personal data to market our services to our users. This includes sending users communications about AXYZ services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may do so through various methods, including email, text messages, push notifications, in app communications and ads, and ads on third party platforms. We may also inform users about products and services offered by AXYZ partners. For example, we may provide recommendations, promotions, or ads for AXYZ partners based on users’ past delivery orders. Although we inform users about products and services offered by AXYZ partners, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent. We may use the data we collect, including in combination with advertising partners’ data, to personalize and improve the marketing communications (including ads) that we send on and off AXYZ’s apps and websites, including based on user location, use of AXYZ’s services, and user preferences and settings. For example, we share user data (such as hashed email address, usage information, and device or user identifiers) with Facebook and TikTok to personalize and improve our ads for AXYZ’s services. For information about how to opt out of certain marketing communications (including ads) from AXYZ and its advertising partners, please see the section titled “Marketing choices.” We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, AXYZ has notified some users by email of ballot measures or pending legislation relating to AXYZ’s services in those users’ areas. AXYZ performs the above activities on the grounds that they are necessary for purposes of AXYZ’s legitimate interests in informing users about AXYZ services and features or those offered by AXYZ partners, or on the basis of user consent. See the sections titled “Choice and transparency” and “Marketing choices” for information on your choices regarding AXYZ’s use of your data for marketing. 7. Non-marketing communications. AXYZ may use personal data to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of AXYZ or its partners. AXYZ performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users, or for purposes of AXYZ’s and it’s users legitimate interests in informing users about events that may have an impact on how they can use AXYZ services. 8. Legal proceedings and requirements. We may use personal data to investigate or address claims or disputes relating to use of AXYZ’s services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement. AXYZ performs the above activities on the grounds that they are necessary for purposes of AXYZ’s legitimate interests in investigating and responding to claims and disputes relating to use of AXYZ’s services and features, and/or necessary for compliance with applicable legal requirements. 9. Automated decision-making We use personal data to make automated decisions relating to use of our services. This includes: · enabling auto refill, roadside assistance, accident notification as it happens and our algorithms detect. · flagging users who are identified as having engaged in fraud, unsafe activity, or other activities that may harm AXYZ, its users, and others. In some cases, such as when a user is determined to be abusing AXYZ’s referral program or has submitted fraudulent documents, such behavior may result in automatic deactivation, or in the European Union or where otherwise required by law, deactivation after human review. · using driver location information, and communications between drivers to enable gamification on the app. · Using driver data (such as location, rating) and rider data (such as rating, origin and destination) to help driving coaching. AXYZ performs the above activities on the grounds that they are necessary to fulfill our obligations to users under our Terms of Use or other agreements with users, or on the grounds that they are necessary for purposes of the legitimate interests of AXYZ, its users and others. C. Cookies and third-party technologies AXYZ and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice, and AXYZ’s Cookie Notice. Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. AXYZ uses cookies and similar technologies for purposes such as: · authenticating users · remembering user preferences and settings · determining the popularity of content · delivering and measuring the effectiveness of advertising campaigns · analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services We may also 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 the devices used by visitors to our websites, as well as when they visit other online sites and services. Please see our Cookie Notice for more information regarding the use of cookies and other technologies described in this section. D. Data sharing and disclosure Some of AXYZ’s services and features require that we share personal data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes. AXYZ may share personal data: 1. With other users This includes sharing: · riders’ first name, ride rating, and location for road side assistance services. · We also provide riders and delivery recipients with receipts containing information such as a breakdown · for those who participate in AXYZ’s referral program, we share certain personal data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus. 2. At the user’s request This includes sharing data with: · AXYZ business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, AXYZ may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurants, merchants or other AXYZ business partners and their users in connection with promotions, contests, or specialized services. · Emergency services: We offer features that enable users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”. 3. With the general public Questions or comments from users submitted through public forums such as AXYZ blogs and AXYZ social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user. 4. With the AXYZ account owner If a user is driving in an unsafe matter, we may choose to communicate the account owner when the app is used for fleet management or family management. 5. With AXYZ subsidiaries and affiliates We share personal data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, AXYZ processes and stores such data in the United States on behalf of its international subsidiaries and affiliates. 6. With AXYZ service providers and business partners AXYZ provides personal data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include: · payment processors and facilitators · background check and identity verification providers · cloud storage providers · Google, in connection with the use of Google Maps in AXYZ’s apps (see Google’s privacy policy for information on their collection and use of data) · social media companies, including Facebook and TikTok, in connection with AXYZ’s use of their tools in AXYZ’s apps and websites (see Facebook’s and TikTok’s privacy policies for information on their collection and use of data) · Marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness · research partners, including those performing surveys or research projects in partnership with AXYZ or on AXYZ’s behalf · vendors that assist AXYZ to enhance the safety and security of its apps · consultants, lawyers, accountants, and other professional service providers · insurance and financing partners · airports · providers of bike and scooters that can be rented through AXYZ apps, such as Lime · repair shops, gas stations, roadside assistance services and other vehicle service providers · third-party vehicle suppliers, including fleet and rental partners 7. For legal reasons or in the event of a dispute AXYZ may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect AXYZ’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to use of another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card. For more information, please see AXYZ’s Guidelines for Law Enforcement Authorities – United States, Guidelines for Law Enforcement Authorities – Outside the US, and Guidelines for Third Party Data Requests and Service of Legal Documents. This also includes sharing personal data with 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. 8. With consent AXYZ may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing. E. Data retention and deletion AXYZ retains user data for as long as necessary for the purposes described above. Users may request deletion of their accounts at any time. AXYZ may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy. AXYZ retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, and the purposes for which we collected the data. Users may request deletion of their account at any time sending an email to privacy@go2a.xyz with subject data deletion. Following an account deletion request, AXYZ deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers and delivery persons, this generally means that we retain their account and data for a minimum of 7 years after a deletion request. For riders and delivery recipients, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons. IV. Choice and transparency AXYZ enables users to access and/or control data that AXYZ collects, including through: · privacy settings · device permissions · in-app ratings pages · marketing choices AXYZ also enables users to request access to or copies of their data, changes or updates to their accounts, or deletion of their accounts, or that AXYZ restricts its processing of user personal data. 1. Device permissions Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider. 2. Marketing choices Users may opt out of certain marketing communications (including ads) and use of their data for marketing in the following ways: Ad settings: These settings enable users to choose whether their data is shared with AXYZ’s advertising partners to deliver personalized ads, and/or to measure the effectiveness of such ads. Marketing emails and messages: To opt out of receiving marketing emails from AXYZ, or for instructions on how to set your preferences regarding whether to receive marketing SMS or push notifications from AXYZ, click here. Users may also opt out of receiving emails and other messages from AXYZ by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for rides or information about their account. Cookies and related technologies: For information on how to opt out of personalized ads using cookies and related technologies, please see our Cookie Notice. AXYZ Eats ads: AXYZ Eats users can opt out of certain personalized ads from AXYZ’s advertising partners here. Users who opt out may still see ads, but they will be less relevant. 3. User personal data requests AXYZ provides users with a variety of ways to learn about, control, and submit questions and comments about AXYZ’s handling of their personal data. Accessing data: Users can access data including their profile data and trip or order history through the AXYZ apps or via AXYZ’s website. Users can also use our Explore Your Data feature to view an online summary of information about their account, such as number of trips or orders, rating, rewards status, and number of days since they’ve been an AXYZ user. Users can also request access to their data here. Receiving data: Users can request a copy of their personal data using our Download Your Data tool. For an overview of the data available through that tool, please click here. Users may also request a copy of their data here. Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in AXYZ’s apps or driver portal. Users may also request to update or correct their data here. Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. 

This includes objecting to our use of personal data that is based on AXYZ’s legitimate interests. AXYZ may continue to process data after such objection or request to the extent required or permitted by law. In addition, depending on their location, users may have the right to file a complaint relating to AXYZ’s handling of their personal data with the data protection authority in their country. For example, users in the European Union and South America may submit such requests to the data protection authorities in the country in which they live. Users may submit the above requests by sending an email to privacy@go2a.xyz. V. Updates to this notice We may occasionally update this notice. We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the AXYZ apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.