PRIVACY POLICY

PRIVACY STATEMENT

Effective Date: February 15th, 2017

GUARDIAN Capital USA, LLC collects information about you when you use our mobile applications, websites, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us. If you reside in the United States, the Services are provided by GUARDIAN Capital USA, LLC and its U.S. affiliates (collectively “GUARDIAN Capital USA, LLC”), and this Privacy Statement applies to information collected and used by GUARDIAN Capital USA, If you reside outside of the United States, the Services are provided by GUARDIAN Capital USA, LLC, and this Privacy Statement applies to information collected and used by GUARDIAN Capital USA, (GUARDIAN Capital USA, LLC and GUARDIAN Capital USA, LLC are referred to herein collectively as “GUARDIAN Capital USA, LLC” or “we”).

Scope and Application

This Privacy Statement (“Statement") applies to persons anywhere in the world who use our apps or Services to request transportation, delivery, or other on-demand services (“Users”). This Statement does not apply to information we collect from or about Funders, couriers, partner transportation companies, or any other persons who use the GUARDIAN Capital USA, LLC platform under license (collectively “Funders” or “Financing Institution”). If you interact with the Services as both a User and a Funder, the respective privacy statements apply to your different interactions.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us, such as when you create or modify your account, request on-demand services, contact customer support, or otherwise communicate with us. This information may include: name, email, phone number, postal address, profile picture, payment method, items requested (for delivery services), delivery notes, and other information you choose to provide.

Information We Collect Through Your Use of Our Services

When you use our Services, we collect information about you in the following general categories:

• Time, amounts, location, etc Information : When you use the Services for transportation or delivery, we collect precise time, amounts, location, etc data about the matters from the GUARDIAN Capital USA, LLC app used by the Funder. If you permit the GUARDIAN Capital USA, LLC app to access time, amounts, location, etc services through the permission system used by your mobile operating system (“platform”), we may also collect the precise time, amounts, location, etc of your device when the app is running in the foreground or background. We may also derive your approximate time, amounts, location, etc from your IP address.

• Contacts Information : If you permit the GUARDIAN Capital USA, LLC app to access the address book on your device through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Statement or at the time of consent or collection.

• Transaction Information : We collect transaction details related to your use of our Services, including the type of service requested, date and time the service was provided, amount charged, distance traveled, and other related transaction details. Additionally, if someone uses your promo code, we may associate your name with that person.

• Usage and Preference Information : We collect information about how you and site visitors interact with our Services, preferences expressed, and settings chosen. In some cases we do this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers.

• Device Information : We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.

• Call and SMS Data : Our Services facilitate communications between Users and Funders. In connection with facilitating this service, we receive call data, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of the SMS message.

• Log Information : When you interact with the Services, we collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.

Important Information About Platform Permissions

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the GUARDIAN Capital USA, LLC app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the GUARDIAN Capital USA, LLC app seeks before you first use the app, and your use of the app constitutes your consent. To learn about the platform-level permissions that the app seeks, please visit our new iOS Permissions page and Android Permissions page. Sometimes these permissions require more explanation than the platforms themselves provide, and the permissions we request will change over time, so we’ve created these pages to serve as authoritative and up-to-date resources for our users.

Information We Collect From Other Sources

We may also receive information from other sources and combine that with information we collect through our Services. For example:

• If you choose to link, create, or log in to your GUARDIAN Capital USA, LLC account with a payment provider (e.g., Google Wallet) or social media service (e.g., Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.

• If your employer uses one of our enterprise solutions, such as GUARDIAN Capital USA, LLC for Business, we may receive information about you from your employer.

• When you request on demand services, our Funders may provide us with a User rating after providing services to you.

• If you also interact with our Services in another capacity, for instance as a Funder or user of other apps we provide, we may combine or associate that information with information we have collected from you in your capacity as a User or rider.

Use of Information

We may use the information we collect about you to:

• Provide, maintain, and improve our Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users and Funders, develop safety features, authenticate users, and send product updates and administrative messages;

• Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;

• Send or facilitate communications (i) between you and a Funder, such as estimated times of arrival (ETAs), or (ii) between you and a contact of yours at your direction in connection with your use of certain features, such as referrals, invites, split fare requests, or pay-off sharing;

• Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of GUARDIAN Capital USA, LLC and other companies, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;

• Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements.

We may transfer the information described in this Statement to, and process and store it in, the United States and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Statement.

Sharing of Information

We may share the information we collect about you as described in this Statement or as described at the time of collection or sharing, including as follows:

Through Our Services