Privacy Policy

Privacy Policy Last Updated: June 27, 2025 Framilies Inc. d/b/a Crewz or Crewz Carpool or Crewz Rideshare (“Framilies”, “Crewz”, “we”, “us”, or “our”) respects your privacy and is committed to protecting it through compliance with this privacy policy (“Privacy Policy”). This policy describes the types of information we may collect from you or that you may provide when you access the Crewz website, mobile and web applications (each, an “Application”), content, products, and related services (collectively, the “Crewz Platform”) as well as our practices for collecting, using, maintaining, protecting, and disclosing that information. Your access to and use of the Crewz Platform is subject to the Crewz Terms of Use and the practices described in this Privacy Policy. Please make sure that you have carefully read and understand the Terms of Use and this Privacy Policy before you use our Services. Capitalized terms not defined in this Privacy Policy will have the meaning ascribed to them in the Terms of Use. By using our Services, you accept the Terms of Use and the practices described in this Privacy Policy. If you do not feel comfortable with the practices described in this policy or the terms set forth in the Terms of Use, you must not access or use the Crewz Platform. This Privacy Policy may change from time to time. Your continued use of the Platform after we make such changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. A. THE DATA WE COLLECT When you use our Services, we may collect data provided by you (e.g., data provided during the account creation process), created during the use of our Services (e.g., location, app usage and device data), or from other sources (e.g., other Users or account owners, business partners, vendors, insurance and financial solution providers and government authorities). The types of data we may collect include: User Profile Information: When you establish an account, we collect certain data from you, which may include: your full name, email address, phone number, address, profile picture (photographs are optional), gender (optional), login name and password, billing and payment information (including payment verification information), emergency contact information (including such contact’s full name, phone number and relationship), information regarding participants, including, but not limited to, preferences, educational and organizational information, and previous service needs. Furthermore, consistent with legal requirements and to determine eligibility as a member, we may also collect government identification documents (which may include identification numbers and images, birth date, gender, signature, and/or social security number). Finally, we may collect vehicle and insurance information, User settings and evidence of health or fitness to provide Services. Background Check Information: Consistent with legal requirements, the Terms of Use, and our safety practices, we may collect information required to facilitate background checks. This may include information such as driving history or criminal record, social security number, date of birth, license status, known aliases and prior addresses, prior employment verification, caregiving experience, child abuse and neglect scan, reference check(s) and right to work. This information is provided by the user but may be collected and processed by an authorized vendor on our behalf. Demographic Data: We may collect demographic data about Users through surveys. You provide this information on a voluntary basis. Communications: When you communicate with us through phone, email, text, chat, or otherwise, we may retain those communications. This includes date and time, as well as the content of text or in-app messages. Consistent with legal requirements, we may record communications between users and such communications may be recorded and stored by us or a third-party vendor. Transaction Information: We collect transaction information related to the use of our Services, including the type of services requested or provided; trip or order details (such as date and time, requested pick-up and drop-off addresses and distance traveled); and payment transaction information (amount charged and payment method). We also associate a User’s name with anyone who uses their referral code. Usage Data: We may collect data on how Users interact with our Services. This includes access dates and times, app features or pages viewed, IP address, Internet Service Provider (ISP), browser type, app crashes, referring/exit pages, operating system, date/time stamp, clickstream data and other system activity. Location-Based Information: We may collect location-based information through the Application and third-party software, including, but not limited to, geographic areas and other traffic and transportation-related data. Location information is only collected if the Application is running in the foreground. Promotions and Contests: If you participate in a contest or giveaway with us, we may ask you for your email address, phone number, mailing address or additional information needed for the entry process, such as a prize selection choice. These contests and the information you provide are voluntary. We recommend that you read the rules for each contest that you enter. User Feedback: To the extent you post information in comments in a publicly available area of our Services (e.g., feedback and reviews), it will be available publicly and other Users of the Services who may use it at their discretion. Device Information: When you download the Application, we automatically collect data about the device you use to access the 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. Cookies: Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). If you decide at any time that you no longer wish to accept Cookies from our Services for any of the purposes described above, then you can change your browser settings to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to fully experience the personalized and interactive features of our Services. Pixel Tags: In addition, we may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web Users. In contrast to Cookies, which are stored on a User’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send email messages in a format Users can read, and they tell us whether emails have been opened to ensure that we are sending only messages that are of interest to Users. We do not tie the information gathered by Pixel Tags to our Users’ personal information. Collection of Information by Advertisers: Certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, the browser you use to visit our Services (but not your name, address, email address or telephone number). They do this by using Cookies or other technologies. This policy does not apply to, and we are not responsible for, Cookies or pixel tags in third party ads. We encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies. If you would like more information about this practice and to know your choices in having this information used by these companies, visit: http://www.aboutads.info/choices or http://www.networkadvertising.org. Collection of Information by Advertisers: In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Site or Application. This includes third party analytics services, including, but not limited to Google Analytics (“Analytics Services”), which we engage to help analyze how Users use the Platform, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Platform. The information generated by the Cookies or other technologies about your use of our Platform (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on User activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Site, Application and Services, you consent to the collection, use and processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at support@crewz.co. We may also partner with ad companies to support our marketing efforts, including by serving you ads better tailored to your likely interests. If you don’t want to take advantage of these services, you may be able to opt-out by visiting http://www.aboutads.info/ or http://networkadvertising.org/choices/. Please note that even if you opt out, you may still receive advertisements from us. However, in that case, the advertising will not be tailored to your interests. We do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. Contacts and Calendars: If you permit Crewz to access the address book and calendar on your device through the permission system used by your mobile platform, we may access for our Services and for other purposes described in this Privacy Policy or at the time of consent or collection. B. HOW WE USE YOUR DATA We use the data we collect to provide, personalize, maintain and improve our Services. This includes using data to: 1. Provide Our Services - Create/update accounts. - Enable transport and other services/features, such as: - using location data to navigate Rider pick-ups and order drop-offs, calculate ETAs and track the progress of rides. - features that involve data sharing, such as sharing a user’s first name and photo and vehicle information (including stock vehicle photos) with Riders/Drivers to facilitate pick-ups, Rider profile and trip details for ETA sharing and User ratings. - match available Drivers to Riders. Riders can be matched based on availability, location/proximity, User settings/preferences and other factors such as likelihood to confirm a trip based on their past behavior or preferences. - Trip estimates and pricing, in which the price of a trip is determined based on factors such as estimated time and distance, predicted route, estimated traffic and the current number of Users requesting or providing Services. - Process payments. - Provide trip updates, generate receipts and inform Users of changes to our Terms of Use, Services or policies. - Perform necessary operations to maintain Services, including to troubleshoot software bugs and operational problems. - Monitor and analyze usage and activity trends. - Ensuring compliance with our Terms of Use and other policies. Crewz performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with Users, meet legal or regulatory requirements, or on the grounds that they are necessary for purposes of Crewz’ and its Users’ legitimate interests. 2. Safety and security We use data to help maintain the safety, security and integrity of our Services and Users. This includes: - Verifying a User’s identity and eligibility to provide Services, including potentially through reviews of background checks, to help prevent use of our Services by unsafe users. - Using device, location, User profile, usage and other data to prevent, detect and combat other types of fraud. This includes identifying fraudulent accounts or uses of our Services, preventing use of our Services by unauthorized users, verifying User identities in connection with certain payment methods, and preventing and combating unauthorized access to Users’ accounts. In some cases, such behavior may result in automatic deactivation consistent with our Terms of Use. - Drawing insights and making predictions about usage patterns and safety. In some cases, such behavior may result in automatic deactivation consistent with our Terms of Use. - Using User ratings, reported incidents and other feedback to identify noncompliance with our Terms of Use and as grounds for deactivating Users. - Investigating Zero Tolerance Policy violations; and - Preventing potentially prohibited or illegal activities. Crewz performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with Users, for legal or regulatory compliance, and/or for purposes of the legitimate safety and security interests of Crewz, our Users and members of the general public. 3. Customer support Crewz 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. Crewz performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with Users or for purposes of Crewz’ legitimate interest in monitoring and improving its customer support services. 4. Research and development We use data for testing, research, analysis, and product development to improve the User experience. This helps us make our Services more convenient and easier to use, enhance the safety and security of our Services and develop new services and features. Crewz performs the above activities on the grounds that they are necessary for purposes of Crewz’ legitimate interests in improving and developing new services and features. 5. Enabling communications between Users. Crewz performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with Users. 6. Marketing and Advertising. Crewz uses data to market its Services. This may include: - Sending emails, text messages, push notifications and in-app messages or other communications marketing or advertising Crewz products, Services, features, offers, promotions, sweepstakes, news and events. - Using location, trip and order history, and usage data to send marketing communications that are personalized based on Users’ observed or inferred interests and characteristics. - Displaying Crewz advertising on third-party apps or websites. This includes using location, trip and order history, and usage data, and sharing hashed email addresses and device or User identifiers with advertising partners to personalize such ads to Users’ interests. Crewz performs the above activities on the grounds that they are necessary for purposes of Crewz’ legitimate interests in informing Users about Crewz Services and features or those offered by Crewz partners. 7. Non-marketing communications. Crewz may use data to send surveys and other communications that are not for the purpose of marketing the Services or products of Crewz or its partners. Crewz performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with Users, or for purposes of Crewz’s and its Users’ legitimate interests in monitoring and improving its customer support services, improving the Services and improving and developing new services and features. 8. Legal proceedings and requirements. We use data to investigate or address claims or disputes relating to use of our Services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, to comply with data reporting requirements and other official inquiries; or pursuant to legal process or governmental request, including from law enforcement. Crewz performs the above activities on the grounds that they are necessary for purposes of Crewz’ legitimate interests in investigating and responding to claims and disputes relating to use of Crewz’ Services and features, and/or necessary for compliance with applicable legal requirements. 9. Legitimate Business Purposes. We may use personal information to create anonymous information records by excluding information that makes the information personally identifiable to you. If information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, we may use it for any business purpose. C. CHILDREN THE PLATFORM IS NOT DIRECTED AT CHILDREN AND CHILDREN ARE NOT ELIGIBLE TO USE OUR PLATFORM. D. HOW WE SHARE INFORMATION CREWZ DOES NOT SELL YOUR PERSONAL INFORMATION AND WILL NOT IN THE FUTURE SELL YOUR PERSONAL INFORMATION WITHOUT PROVIDING A RIGHT TO OPT-OUT. Your information may be shared with third parties as described below: 1. With other Users: Our Services are designed to connect Users for Services. As such, if you are a User, we must share personal information about you and the other users or participants. In the case of a lost or found item, we will seek to connect you with the other user. 2. With third parties. In addition to the ways we share personal information as described elsewhere in this Privacy Policy, we may share personal information with other third parties in the following manners: - Payment Processing Information. For online payments and/or Automated Clearing House (ACH) payouts, we use the payment services of Stripe. We do not process, record or maintain your credit card or bank account information or other related information necessary to process payments. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please see https://stripe.com/us/privacy. - Governmental Entities and Enterprise Clients. Crewz may be asked or required by certain applicable governmental entities or Enterprise Customers to report certain information about users, Service details, or participants for purposes of licensure, approval, or required data reporting. - User Screening Providers and Resources. We may work with background check, identity verification, physical exam (where applicable), onboarding, and other required or voluntary user screening providers. - Consultants and Other Business Service Providers. We may share your personal information with consultants, lawyers, accountants and other business service providers. This information is provided to them to enable them to provide us with critical services such as development, cloud storage, marketing and advertising services, data analytics, insurance and financing services, customer support, order fulfillment, safety and security and other services. These third-party service providers have access to your personal information only for the purpose of performing services on our behalf. In particular, we share your personal information with Google, in connection with the use of Google Maps in our apps (see Google’s privacy policy for information on their collection and use of data). - Affiliates. We may share personal information with our parent companies, subsidiaries, joint ventures, or other companies under a common control (“Corporate Affiliates”), if we have such Corporate Affiliates in the future, in which case we will require our Corporate Affiliates to honor this Privacy Policy. - Corporate Restructuring. We may share some or all personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding personal information as described in this Privacy Policy. - Research partners, including those performing surveys or research projects in partnership with us or on our behalf. - Legal Reasons. Regardless of any choices you make regarding personal information, we may disclose personal information if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants or other requests for information served on us; (c) to protect or defend our rights or property or other Users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use. 3. With Your Consent. We may share a User’s personal data other than as described in this Privacy Policy upon the User’s consent. E. DATA RETENTION Retention. We retain User profile, transaction, and other information for as long as a User maintains their Crewz account. We retain transaction information related to services and payments for at least seven years to ensure we can perform legitimate business functions, such as accounting for tax obligations. For Drivers, Crewz may retain vehicle and background check information to the extent required by law or regulation, or for as long as they maintain their Crewz account, whichever is greater. Changing Personal Information. You may review, update, or correct the personal information in your account by editing your account or contacting us. Data Security. Crewz has implemented administrative, technical, and physical security controls designed to safeguard personal information. However, no online activity is ever fully secure or error-free. While we strive to protect your personal information, we cannot guarantee your information is absolutely secure. Please keep this in mind when disclosing personal information and take reasonable measures to protect your information, including using complex passwords and changing them often, and make sure you have a secure browser. If you believe your account has been accessed by an unauthorized User, please contact us immediately. F. YOUR RIGHTS To the extent applicable, various laws, including Colorado, California, and Virginia state laws, provide some residents with the following rights: Data access. You may request a copy of your personal information by sending an email to support@crewz.co. You have the right to know what information we have collected about you in the last 12 months, including: - The categories of personal information we have collected about you; - The categories of sources from which the personal information is collected; - The business or commercial purpose for collecting your personal information; - The categories of third parties with whom we have shared your personal information; and - The specific pieces of personal information we have collected about you. Deletion. Users may request deletion of their accounts at any time. We may retain User data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy. Users may request deletion of their account at any time by sending an email request to support@crewz.co. Following an account deletion request, Crewz 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 any of the reasons listed below. Because we are subject to legal and regulatory requirements, this generally means that we retain their account and data for the applicable statutory retention period after a deletion request. For Users, their data is generally deleted within 90 days of a deletion request, except where retention is necessary, including, but not limited, to the following: - Complete your transaction; - Detect and protect against security incidents, including to prosecute those responsible for that activity; - Debug to identify and repair errors that impair existing intended functionality; - Exercise free speech or ensure the right other Users in exercising free speech or any other right provided them or us by law; - Comply with the California Electronic Communications Privacy Act (Ca. Penal Code §1546 et seq.); - When necessary for the achievement of such research and with the User’s consent, to engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws; - Comply with a legal obligation; and/or - Make other internal and lawful uses of the information that are compatible with the context in which you provided it. Correction. You may request that we correct inaccurate information about you by sending an email request to support@crewz.co. Opt-out of sales and sharing. You may opt out of the “sale” or “sharing” of your personal information. “Sale” refers to the disclosure of personal information to a third party in exchange for money or other value. “Share” refers to the disclosure of personal information to a third party for purposes of targeted advertising. To opt-out of the sharing of your information, please email support@crewz.co. Limit the use of your personal information. You may limit the use of your personal information to that which is necessary to perform the Services or as otherwise permitted by law by emailing support@crewz.co. Opt-out of profiling: You may request that we opt you out of the processing of your data for purposes of certain kinds of “profiling” that could have a significant impact on consumers. Profiling generally refers to automated processing of personal data to analyze or predict an individual’s behaviors or characteristics. Right to non-discrimination. We will not discriminate against any User who exercises these rights. Specifically, if you exercise your rights, we will not deny you Services, charge you different prices or rates for Services or provide you a different level or quality of Services. Right to data portability. You have the right to obtain your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will confirm receipt of your request within 10 days and provide information about how we will process the request, our verification process, and when you can anticipate a response to the request. We will use commercially reasonable efforts to honor your request within 45 days from receipt. If additional time is needed, we will notify you of the same, along with an explanation and anticipated timeline for the extension which shall not exceed 90 days from the date of receipt. All requests must be verified to ensure that the person making the request is the consumer about whom we have collected information. In certain cases, Crewz may decline to take action on your request as permitted by law. Should we decline your request, We will provide you with a written explanation of the reasons for our decision, and an opportunity to provide a written appeal within thirty (30) days of receipt of our decision to decline to take action. In the event we deny your appeal, We will provide a written explanation of our decision, and instructions on how to request further review where permitted by law. G. THIRD PARTY SITES AND SERVICES The Services may contain links to other websites, applications and services (“Third Party Services”). Crewz is not responsible for the privacy practices or the content of these Third Party Services. We encourage you to read the privacy policies of each and every Third Party Service you visit. Please contact those websites directly if you have any questions about their privacy policies. H. NOTIFICATION OF CHANGES We may update this policy from time to time as the Crewz Platform evolves and privacy laws change. We reserve the right to update or modify this Policy at any time without prior notice. We will notify you of any material modifications through the Platform or by some other form of communication like email, using the contact information you have provided us. When you use Crewz, you are agreeing to the most recent version of this Privacy Policy. I. ADDITIONAL INFORMATION Questions regarding this Privacy Policy or our data collection and processing practices of the Services should be directed to Crewz by emailing such questions to support@crewz.co.