Privacy Policy

We collect information in three ways: directly from you, automatically through your use of the Platform, and from third parties.

Information you provide directly includes:

• Account Information — name, email address, phone number, company name, job title, billing address
• Business Information — USDOT number, MC number, FMCSA authority data, CARB compliance status, port concessionaire permit number
• Driver Information — driver name, CDL number, vehicle license plate, truck/chassis number, appointment details
• Payment Information — credit/debit card details (last 4 digits only; full card data is processed by Stripe, Inc.)
• Operational Content — gate entry/exit records, inspection notes, equipment photographs, task logs, yard configuration data
• Communications — support tickets, feedback, emails, and chat messages sent to Qargolab

Information collected automatically includes: pages visited, features used, time spent on Platform, IP address, browser type and version, operating system, device identifiers, screen resolution, API call logs, authentication events, and approximate location derived from IP address.

Information from third parties includes: payment confirmation and fraud signals from Stripe; publicly available FMCSA SAFER carrier and driver data; publicly available port and terminal appointment data.

We do not collect biometric data, social security numbers, or government-issued identification numbers. Images uploaded during inspections are stored securely and accessible only to authorized users within your organization.

We use information collected for the following purposes:

• Service Delivery — processing gate transactions, recording operational events, managing accounts, processing payments, and providing support
• Platform Improvement — analyzing usage patterns, identifying bugs, improving features, and developing new modules based on aggregated usage data
• Communications — sending transactional emails (receipts, account notifications, security alerts), responding to support requests, and sending product updates (you may opt out of marketing communications)
• Legal Compliance & Safety — complying with applicable laws, protecting rights and property, and detecting, investigating, and preventing fraud, abuse, and security incidents
• Aggregated Analytics — creating de-identified, aggregated datasets for internal analytics, industry benchmarking, and product planning that cannot reasonably identify any individual or company

Our legal basis for processing includes: (a) performance of a contract with you; (b) our legitimate interests in security, fraud prevention, and product improvement; (c) your consent where specifically requested; and (d) legal obligation.

We do not use your data for behavioral advertising or sell your personal information to third-party advertisers.

We do not sell your personal information for monetary consideration. We share information only in the following circumstances:

• Service Providers — cloud hosting (e.g., AWS), payment processors (Stripe, Inc.), email delivery services, analytics providers, and customer support tools. All are bound by written contracts prohibiting use for any purpose other than providing services to Qargolab.
• Other Platform Users — operational data (gate records, inspection results, driver check-ins) is visible to authorized Users within your organization and to counterparty Users involved in a specific operational event.
• Business Transfers — in the event of a merger, acquisition, or sale of assets, your information may be transferred. We will notify you prior to such transfer.
• Legal Requirements — we may disclose information when required by law, court order, subpoena, or regulatory request, or when necessary to protect rights, property, or safety.
• Aggregated Data — we may share de-identified, aggregated information that cannot reasonably identify you for industry research, benchmarking, or analytics purposes.

We do not share personal information with third parties for their independent marketing or advertising purposes.

We retain your personal information for as long as necessary to provide the Platform, comply with legal obligations, resolve disputes, and enforce our agreements.

Specific retention periods:

• Account information — duration of account + 90 days
• Operational records (gate logs, inspection data) — duration of account + 3 years
• Payment records — 7 years (tax compliance)
• Security and access logs — 12 months rolling
• Support communications — 3 years

When your account is terminated, we retain your data for up to 90 days to allow for data export requests, after which it is deleted or anonymized (except where longer retention is required by law).

You may request deletion of your account and associated data at any time by contacting privacy@qargolab.com.

We implement commercially reasonable technical and organizational security measures to protect your information, including:

• Encryption of data in transit (TLS 1.2+) and at rest (AES-256 or equivalent)
• Role-based access controls limiting employee access on a need-to-know basis
• Multi-factor authentication for administrative access
• Regular security testing and vulnerability assessments
• Incident response procedures with defined notification timelines

No method of transmission or storage is 100% secure. Despite our efforts, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

In the event of a data breach affecting your personal information, we will notify you as required by applicable law, including California Civil Code §1798.82.

We use the following types of cookies and tracking technologies:

• Strictly Necessary — authentication, security, session management. Cannot be disabled.
• Functional — user preferences, UI settings. Can be limited.
• Analytics — usage statistics and performance monitoring. Can be disabled via cookie preference center.
• Marketing — not currently used.

The Platform does not currently alter its data collection practices in response to browser Do Not Track signals because there is no uniform standard for such signals. We will update this disclosure if that changes.

You can manage cookie preferences through your browser settings or our cookie preference center accessible in the Platform footer.

The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from anyone under 18.

If we become aware that we have collected personal information from a minor without verified parental consent, we will delete such information promptly.

Contact us at privacy@qargolab.com if you believe we have inadvertently collected a minor's information.

This section applies to California residents and supplements the rest of this Privacy Policy.

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA: Identifiers, Personal Records (Cal. Civ. Code §1798.80), Commercial Information, Internet/Network Activity, Geolocation Data, Professional/Employment Info, and Inferences. We do not collect Social Security numbers, precise GPS location (unless enabled), biometric data, or health information.

As a California resident, you have the following rights:

• Right to Know — request disclosure of categories and specific pieces of personal information collected, sources, purposes, and third parties disclosed to
• Right to Delete — request deletion of personal information, subject to legal exceptions
• Right to Correct — request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing — we do not sell or share personal information for cross-context behavioral advertising. If this changes, we will provide a clear opt-out mechanism.
• Right to Limit Use of Sensitive PI — CDL numbers and FMCSA authority numbers may qualify as sensitive PI. We use these solely to operate the Platform.
• Right to Non-Discrimination — we will not deny services, charge different prices, or degrade experience for exercising privacy rights
• Right to Data Portability — we will provide your personal information in a portable, machine-readable format upon request

To exercise your rights, email privacy@qargolab.com with the subject "California Privacy Rights Request." We will verify your identity and respond within 45 days (extendable to 90 days with notice). Authorized agents may submit requests with written authorization.

In compliance with the California Online Privacy Protection Act (CalOPPA):

• This Privacy Policy is posted and accessible from the Platform homepage
• We disclose all categories of personally identifiable information collected
• Users may review and update their information by logging into account settings
• Changes to this Privacy Policy will be communicated via email and by updating the "Last Updated" date
• We do not alter data collection practices in response to browser Do Not Track signals (see Cookies section)

We may update this Privacy Policy from time to time. We will notify you of material changes by: (a) sending an email to your registered address; (b) posting a prominent notice on the Platform; or (c) updating the "Last Updated" date above.

Your continued use of the Platform after the effective date constitutes acceptance of the revised Policy.

For privacy inquiries and rights requests, contact:

PROJECTX LLC d/b/a Qargolab Attn: Privacy Officer Marina Del Rey, California Email: privacy@qargolab.com