POSH TECHNOLOGIES INC. PRIVACY POLICY

Last Updated: November 4th, 2024

At Posh, Inc. (“Posh,” “we,” “our,” or “us”), our mission is to enhance people’s lives through reliable, efficient transportation solutions. This Privacy Policy is designed to help you understand how we collect, use, and protect your personal information when you use our services. We believe transparency is essential to building trust, and this document outlines our practices to handle your information responsibly.

This Privacy Policy applies to all individuals interacting with the Posh Platform, including Riders, Drivers, and Driver applicants. It covers the data practices associated with Posh’s applications, websites, and other services or features offered by Posh (collectively, the “Posh Platform”). This policy pertains solely to personal information that can identify you and does not extend to aggregate data or information that cannot be linked to an individual.

This policy details the types of data we gather, how we use it to improve the Posh Platform, and the steps we take to keep your information safe. We encourage you to read this policy to understand your rights and choices regarding your personal information.

Posh recognizes that privacy laws and rights vary by location. To respect these differences, we provide location-specific privacy notices for users in certain jurisdictions, such as California, Canada, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia. These notices address specific data rights and protections relevant to users in those locations and are available within this policy. If you are in one of these areas, please review the appropriate section for details on your specific privacy rights.

1. THE INFORMATION WE COLLECT

1.1 Information You Provide to Us

Account Registration Details: When you create an account with Posh, we collect essential information such as your name, email address, phone number, date of birth, and payment information. You may also add profile information, including saved addresses and preferences (e.g., preferred pronouns), to personalize your experience on the platform.

Driver Application and Profile Information: If you apply to be a Driver, we collect additional information as part of the application process, including government identification numbers (e.g., social security number), driver’s license details, vehicle information, insurance information, and bank details for payments. We may also request further verification, such as business permits or profile images, to ensure platform integrity based on location or program requirements.

Ratings and Feedback: Posh values the feedback from its community. When you provide ratings and feedback for a ride or user experience, we collect and store this information to improve the platform, promote safe interactions, and maintain quality service.

Communications and Customer Support: When you communicate with Posh—whether through emails, support inquiries, or surveys—we collect the information you share with us, including the content of messages, attachments, and any additional details you provide. This helps us respond effectively and improve our support services.

1.2 Information Collected When You Use the Posh Platform

Location Information (for Riders and Drivers): Location data is crucial to providing accurate and efficient rides. If you are a Rider, we collect your device’s location data from the moment you open the Posh app, including while the app runs in the background, until your ride concludes. For Drivers, location data is collected continuously while the app is active and briefly afterward if a ride incident is detected to ensure rider safety. Additionally, if you use Posh’s e-bikes or scooters, we always track their locations for security and availability purposes.

Usage Data and Ride Information: Posh gathers data about your interactions with the platform, such as ride details (e.g., date, time, distance, and route), payment information, and promotional code usage. For e-bikes and scooters, sensor data like speed, direction, and movement patterns are collected to optimize safety and performance.

Device Information and Settings: We collect technical details about your devices to access the Posh Platform, including model type, IP address, browser type, operating system, and device identifiers. This data helps us tailor services to your device’s specifications, enhance security, and ensure a seamless experience across different devices.

Communication Data (Between Riders and Drivers): Posh partners with a third party to handle calls and messages to facilitate communication between Riders and Drivers without disclosing personal phone numbers. We collect information about these communications, such as the date, time, and content of SMS or in-app chat messages. For security reasons, we may monitor or record certain communications and notify you when this occurs.

Address Book and Calendar Access (Optional): If you link your address book or calendar with Posh, we access selected information, such as contact names and event details, to assist with referrals or ride reminders. You can control and disable these permissions anytime via your device settings.

Cookies, Analytics, and Tracking Technologies: To understand user preferences and optimize the platform, Posh uses cookies, tracking pixels, and data analytics tools (such as Google Analytics). These technologies track how you navigate the platform, what content you engage with, and your ad interactions. We use session and persistent cookies, which you can manage or disable in your browser settings, although some features may be impacted.

Inferences Derived from Interactions: Based on your interactions with the platform, Posh may derive inferences, such as preferences, habits, or probable interests (e.g., frequent travel patterns or commonly visited locations). These insights help us personalize your experience, suggest relevant features, and enhance platform engagement.

1.3 Information We Collect from Other Sources

Data from Service Providers and Third Parties: To support core functions and enhance your Posh experience, we receive data from service providers, such as background checks, insurance information, payment verification, and marketing insights. These third parties help us verify identities, prevent fraud, and operationalize loyalty or promotional programs.

Enterprise and Delivery Programs: If you use Posh services through your employer or another organization enrolled in our enterprise programs, we may receive your contact details and usage information from that entity. For deliveries arranged through Posh, we may collect information like your name and delivery address to fulfill requests.

Concierge and Referral Programs: When another person or business orders a Posh ride on your behalf, such as through our Concierge service, we may receive your contact and location details to coordinate the ride. If you were referred to Posh or someone else, we may collect information about the referral to manage incentives and track participation in the referral program.

Information from Other Users or Public Sources: Occasionally, Posh may receive information about you from other users or public sources, such as during investigations or safety checks. This may include reports from law enforcement, insurance agencies, or third-party witnesses related to platform incidents or support cases.

2. HOW WE USE YOUR INFORMATION

2.1 Providing and Personalizing the Posh Platform: We use the information collected to offer a seamless, intuitive experience on the Posh Platform. This includes verifying your identity, managing your account settings, connecting you with Drivers, and tracking ride progress. Your data allows us to calculate prices, process payments, and provide you with relevant features, promotions, and third-party offerings. Additionally, we use your preferences and profile details to personalize your interactions with the platform, such as suggesting frequently used pickup points or offering services tailored to your needs.

2.2 Ensuring Security and Safety: Security and safety are core elements of the Posh Platform. We use your data to authenticate users, verify that Drivers and their vehicles meet safety standards, and proactively address any safety concerns. Location information, identity verification, and behavioral patterns are used to monitor potential risks, detect unsafe activities, and help prevent fraud. We also use your data to investigate and resolve incidents, claims, or issues, ensuring a secure and trustworthy environment for both Riders and Drivers.

2.3 Building and Maintaining the Community: Posh is committed to building a positive, connected community. Your information helps us inform you about events, promotions, and campaigns relevant to your interests and encourages engagement through content and experiences designed to foster community growth. We also use your data to provide targeted advertising and relevant content within the Posh Platform and through our partners, helping you discover new features and opportunities that may enhance your experience.

2.4 Customer Support and Assistance: When you reach out for assistance, we use your information to offer timely, effective support. Your data enables us to troubleshoot issues, respond to inquiries, and provide guidance on platform features. Whether through chat, email, or phone, our support team uses the information provided to address your concerns, investigate complaints, and help you get the most out of your experience with Posh.

2.5 Improving and Expanding Services: Posh continuously strives to improve the quality and scope of our services. We use aggregated and anonymized data to analyze user behavior, test new features, and refine existing functionalities. By understanding how users interact with the platform, we can enhance the design, optimize performance, and introduce new offerings. Our research and development efforts are guided by insights derived from user data, enabling us to innovate in ways that meet evolving user needs.

2.6 Legal Compliance and Obligations: In certain situations, Posh may be required to use your information to comply with legal obligations, respond to regulatory inquiries, or address governmental requests. We also use your data to enforce our Terms of Service, investigate and prevent violations, and protect our rights and users' rights. When necessary, we use your information to prepare for or respond to legal proceedings, audits, or other formal obligations imposed by applicable laws and regulations.

3. HOW WE DISCLOSE YOUR INFORMATION

3.1 Sharing Between Posh Users

Rider and Driver Information Sharing: Posh shares essential information between Riders and Drivers to facilitate safe and reliable rides. For example, when a Driver accepts a ride request, the Rider receives details such as the Driver’s name, profile photo, vehicle information, real-time location, and ratings. Similarly, Drivers can view the Rider’s name, pickup, and drop-off locations, profile photo, and any relevant notes added to the Rider’s profile. This information exchange helps Riders and Drivers recognize one another and fosters a secure and efficient interaction.

Shared Rides and Ride Payment Options: When participating in a shared ride, Riders may view limited information about co-riders, including names and profile photos, to ensure safety and clarity throughout the shared experience. Additionally, if a ride is requested or paid for by a third party (e.g., through Posh Business, a corporate account, or a subsidized program), certain ride details such as the Rider’s identity, pickup, and drop-off locations, and ride cost may be shared with the party responsible for the payment.

Linked Accounts and Referral Programs: If you link your Posh account with family members, colleagues, or other trusted contacts, certain information about your activities on the platform may be shared with those accounts. Additionally, if you participate in Posh’s referral programs, information related to referral bonuses and usage milestones may be shared with the person who referred you or whom you referred for tracking and reward purposes.

3.2 Disclosures to Service Providers and Other Parties

Categories of Information Shared: Posh partners with various service providers to deliver core services and enhance your experience. These third-party providers may receive certain categories of personal information, including identifiers (e.g., name, email), financial information (e.g., payment details), location data, device information, and usage data.

Purposes for Third-Party Disclosures: These providers help us operate the Posh Platform and support various functions, including payment processing, customer service, identity verification, fraud detection, and marketing. They may also support Driver-specific services, such as background checks, insurance, and loyalty programs. Each provider is carefully vetted, and Posh ensures they uphold strict data protection standards when handling user information.

3.3 Legal Requirements and Platform Protection

Compliance with Legal Processes and Regulatory Bodies: Posh may disclose user information in response to lawful requests, such as subpoenas, court orders, or government investigations. Such disclosures may be necessary to comply with local, state, or federal regulations, protect Posh’s legal rights, or respond to inquiries from regulatory bodies. Posh may also share information with law enforcement agencies when there is a reasonable belief that a user’s conduct may violate legal standards or pose a risk to public safety.

Business Transactions (e.g., Sale or Merger): If Posh engages in a business transaction, such as a merger, acquisition, restructuring, or sale of assets, user information may be transferred or disclosed as part of that transaction. In such cases, the successor organization would inherit the responsibility for protecting your personal information, and we will provide notification and outline any changes in data handling practices following the transaction.

Disclosures with Your Consent: Posh may also share your information with third parties when you explicitly consent to such disclosures. This could include specific promotions, partnerships, or integrations you authorize through the platform. If you direct Posh to share information with a third party or connect your account with an external service (e.g., loyalty programs or travel apps), we will only share the necessary data to facilitate that connection or service as you specify.

4. HOW WE STORE AND PROTECT YOUR INFORMATION

4.1 Data Retention Practices: Posh retains your personal information only for as long as needed to fulfill the purposes outlined in this Privacy Policy, provide services on the Posh Platform, and comply with legal obligations. Profile information and account settings are retained as long as your account remains active. Transactional information, such as ride details and payment history, is generally retained for at least seven years to meet regulatory and tax obligations and recordkeeping and dispute resolution purposes.

If you request the deletion of your account, Posh will initiate the process of removing your data in accordance with applicable laws and our internal policies. However, certain data may be retained for longer periods if required by legal obligations or for legitimate business purposes, such as open claims, safety concerns, or ongoing investigations.

4.2 Security Measures and Limitations: Posh employs industry-standard security measures to protect your personal information from unauthorized access, use, or disclosure. This includes data encryption, secure storage protocols, regular system monitoring, and controlled access to sensitive data. We also restrict access to personal information to authorized personnel and third-party service providers who require it to perform specific functions, and they must adhere to strict confidentiality agreements.

While we take significant steps to protect your information, security systems can only be partially infallible. Users are encouraged to keep their account credentials secure and to notify Posh immediately if they suspect any unauthorized access or suspicious activity. In the event of a data breach affecting personal information, Posh will inform affected users promptly and take appropriate steps to mitigate potential risks.

5. YOUR RIGHTS AND CHOICES REGARDING YOUR DATA

5.1 All Users

Email and Text Message Preferences: Posh allows you to manage your communication preferences for promotional and marketing messages. You can unsubscribe from promotional emails by clicking the unsubscribe link in the message. Opt out of receiving promotional text messages by replying with the keyword provided or adjusting your settings within the app. Please note that you may still receive transactional or account-related communications necessary for using the Posh Platform.

Push Notifications: You can adjust your device settings to control whether you receive push notifications from Posh. Push notifications may include alerts about ride arrivals, payment confirmations, or promotional offers. Disabling these notifications may limit certain real-time updates and features, so consider this when managing your preferences.

Profile and Location Settings: You can access and edit certain information within your profile, including saved addresses, profile photos, and preferences, by logging into your account settings. Location services are essential to Posh’s functionality, particularly for Riders and Drivers. You can control location sharing through your device settings; however, disabling location access may impact the availability and accuracy of some platform features.

Accessing, Reviewing, and Deleting Information: Posh provides tools within your account settings for reviewing your data, such as ride history, payment information, and saved preferences. If you would like to access or delete your personal information, you may submit a request through the platform or contact Posh support. Account deletion requests are processed in line with applicable laws and may result in the removal of certain data. However, some information may be retained to meet legal obligations or resolve ongoing matters.

Cookie Tracking and Browser Controls: We use cookies and tracking technologies to enhance your experience on the Posh Platform. You can manage cookie preferences through your browser settings, including blocking or clearing cookies. Disabling cookies may affect the functionality and performance of certain features on the platform. For more details, please refer to our Cookie Policy.

5.2 Location-Specific Rights

Privacy Rights for U.S. States and Canada: Certain privacy rights apply to users in specific jurisdictions, such as California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, Virginia, and Canada. These rights may include the ability to access, correct, delete, or opt out of the sale or sharing of personal information for targeted advertising. For residents in these areas, additional details on exercising these rights are available in our location-specific privacy notices within this policy. Users can submit relevant requests through the platform, and we are committed to complying with applicable privacy regulations.

6. CHILDREN’S DATA

Our platform and services are designed for users 16 years and older, and we do not intentionally collect, store, or process personal information from children under 16. We believe that protecting children’s privacy is essential, and our practices are aligned with applicable data protection laws regarding children’s data, including the Children’s Online Privacy Protection Act (COPPA) and similar regulations worldwide.

The Posh Platform is not intended for use by children, and we have structured our systems and services to prevent the collection of information from individuals who do not meet our age requirement. However, if we discover that a child under the age of 16 has created an account or provided personal information on our platform without verified parental consent, we will promptly take measures to delete that information from our records to protect the child’s privacy and maintain compliance with applicable laws.

We encourage parents and guardians to monitor their children’s online activity and familiarize themselves with our policies. Parents who suspect their child may have provided personal information on the Posh Platform without parental consent are encouraged to contact us directly. Upon receiving a request from a parent or guardian, we will take immediate action to review the situation, verify the child’s age, and, if necessary, delete any data associated with the child.

For assistance with these concerns or to request the deletion of information on behalf of a minor, parents or guardians can contact Posh support at privacy@posh.com or use the contact options available on our Help Center. We are dedicated to promptly addressing any issues that involve children’s data and will work with parents or guardians to ensure the privacy and safety of minors on our platform.

7. LINKS TO THIRD-PARTY WEBSITES

The Posh Platform may contain links to third-party websites, services, or products not operated or controlled by Posh. These third parties may have their privacy policies and practices separate from Posh's. We encourage you to review the privacy policies of any third-party websites or services you interact with. Posh is not responsible for these external sites’ privacy practices or content.

If you have questions about third-party privacy practices, please get in touch with the relevant third party directly for further information.

8. CHANGES TO THIS PRIVACY POLICY

Posh may update this Privacy Policy periodically to reflect changes in our practices and services or to comply with legal requirements. When we make significant changes to the policy, we will notify you through appropriate means, such as by posting an update on the platform or sending a notice to the contact information associated with your account. We encourage you to review this Privacy Policy regularly to stay informed about how we protect and use your personal information.

By continuing to use the Posh Platform after any updates are made, you acknowledge and agree to the revised terms. If you have questions about the changes, please get in touch with Posh support.

9. CONTACT US

If you have questions, concerns, or requests regarding your privacy or this Privacy Policy, Posh’s support team can assist you. We are committed to addressing your privacy inquiries in a timely and transparent manner.

You can reach us by:

• Email: info@poshtechnologiesinc.com
• Mail:
• Support Center: Access our Help Center through the Posh Platform for additional resources and assistance.

For specific requests, such as data access, correction, or deletion, please provide relevant details to help us address your inquiry effectively. We strive to handle all inquiries in accordance with applicable privacy laws and Posh’s commitment to protecting your information.