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                            Privacy Policy

                            Effective Date: July 14, 2020

                            Pegasus Transtech, LLC (“Pegasus,” “the Company.” “we,” “us,” or “our”) is committed to privacy and data protection. This Privacy Policy applies to personal data Pegasus collects from you, through our interactions with you, through www.transflo.com and websites under the control of Pegasus (“Sites”), our mobile applications, and the Pegasus services (such as  Mobile+, Velocity+, Command Center, Docuype, ELD), including all media, document, updates, and support services associated with the Sites and the Pegasus services (collectively, the “Services”), as well as how we use and protect your personal data.

                            All references to Pegasus include not only Pegasus Transtech, LLC but also our affiliates, unless expressly stated otherwise.

                            This Privacy Policy does not apply to any third-party applications or software that integrate with the Services, or any other third-party products, services or businesses (collectively, “Third Party Services”). Third Party Services are governed by their own privacy policies. We recommend you review the privacy policy governing any Third Party Services before using them. 

                            PERSONAL DATA WE COLLECT
                            Pegasus collects data to provide the Services you request, ease your navigation on our Sites, communicate with you, and improve your experience using the Services. Some of this information is provided by you directly, such as when you create an account on our Sites, request a trial and/ or purchase Services. Some of the information is collected through your interactions with the Services. We collect such data using technologies like cookies and other tracking technologies, error reports, and usage data collected when you interact with Pegasus Sites or Services running on your device.

                            We also obtain data from third parties or use third parties (including brokers and carries) to assist us with data collection. For example, we may supplement the data we collect as described in this section by purchasing demographic data from other companies. We also use services from other companies to help us determine a location based on your IP address notably to customize certain services to your location. In addition, we utilize third-party services to collect usage data.

                            The data we collect depends on the Services and features thereof that you use, and includes the following:

                            Name and contact data. We collect your first and last name, email address, postal address, phone number, employer, company, job function, and other similar contact data. We may use this information to contact you or provide you with information on Pegasus or the Services.

                            Credentials. We process passwords and related security information used for authentication and account access and information security purposes.

                            Payment data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number).

                            Usage and location data. We collect personalized information about your use of the Services and your location while using the Services, to better understand uses thereof and identify potential improvements, as well as to send you promotional communications or offers tailored to your use of the Services and related interests.

                            Examples include:

                            • Information based on your use of the Services running on your device. This includes the types and frequency of tools and commands being used, the frequency and duration of use.
                            • Information on the web pages you visit on and off our Sites and the search terms you enter.
                            • Information regarding the performance of the Services and any problems you may experience while using them. This information enables us to diagnose problems and offer support in resolution.
                            • Data about your device and the network you use to connect to the Services, including IP address, device identifiers, and regional and language settings.

                            Web requests. We collect information regarding every web request sent to our servers. This information is used to provide support, as well as to assess usage and performance of the Services. The data collected for each request can include such things as timestamps, any exception messages, user agent, IP address, request time and duration, as well as files names. Note that we do not collect your project file data.

                            Location Information. The Pegasus mobile application collects information from Wi-Fi access points, GPS, mobile location services, and wireless networks and/or cell towers that indicate the current or prior location of the mobile device on which the Services are accessed (“Location Information”). After you install the Pegasus mobile application and consent to location tracking, it can collect Location Information from your mobile device. If you permit the Pegasus mobile application to access Location Information through the permission system used by your mobile operating system, we may also collect Location Information from your mobile devicewhen you are not actively using the Services. You may choose to stop our collection of Location Information through the settings that we provide in the Pegasus mobile application or by removing the Pegasus mobile application from your mobile device.  Although your Electronic Logging Device (“ELD”) is connected to the Pegasus mobile application you cannot use the Pegasus mobile application to turn off the collection of Location Information from your ELD. Some of the Services may use Google Maps to determine your location.  When Google Maps is part of the Services you choose to use, you are subject to Google’s Privacy Policy as set forth at https://www.google.com/policies/privacy.

                            Content. We may collect the content of messages you send to us, such as feedback or questions you ask our technical support representatives, when necessary to provide you with the Services you use. We will collect and utilize any data files you send to us for troubleshooting and improving the Services. When you contact us we may monitor and record chat sessions with our representatives in order to improve our services, facilitate the processing and resolution of your request or complaint.

                            Surveys and Studies. We may ask you to participate in a survey or study; and may request information from you. Participation is voluntary, and you have the choice of whether to disclose any requested information.

                            HOW WE USE PERSONAL DATA
                            We will only use your personal data when the law allows us to. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

                            Most commonly, Pegasus uses information that we collect from customers and visitors for the purposes of:

                            • providing the Services;
                            • providing ongoing support;
                            • communicating with you, including promotional communications and customer relationship management (“CRM”);
                            • providing information about other Services;
                            • helping us run our company, for example to improve the Services or our security, train staff or perform marketing activities, including CRM;
                            • complying with our legal obligations; and
                            • accounting and other administrative purposes.

                            Examples of the uses of information include:
                            Providing Services. We use data to carry out your transactions with us and to provide the Services to you. Often, this includes personal data such as email, name, job title, company, and address.

                            • Customer support. We use data to diagnose and address problems and provide other customer and support services.
                            • We use data, including names and addresses to pick-up and deliver loads and may provide limited data to platform other 3rd parties that maybe required to collaborate in the pick-up and delivery or other similar activities.
                            • Service activation. We use data, including device and application type, location, and unique device, application, network and subscription identifiers to activate software and devices that require activation.
                            • Software updates. Unless you have disabled the functionality of our Software Update Manager, our software products periodically communicate with our servers to perform functions such as checking for updates.

                            Jobs and Internships. We may ask for your contact information such as your name, address, telephone number, email address, job title, employer/company, cover letter, resume, and salary requirements. We collect this information to evaluate your candidacy for a position or internship at Pegasus.

                            Improving Services. We use data to continually improve the Services, including adding new features or capabilities. Data is collected throughout your interactions with the Services that enable us to understand customer usage and tailor future capabilities.

                            We track general, non-personalized information (e.g., operating system, browser version and type of device being used) to know how many people visit specific pages of the Services or utilize specific features of the Services so that we may improve those Services. We may use your IP address to customize services to your location, such as the language displayed on the Services.

                            We use a third party analytics platform (“Analytics Platform”), currently Appsee, to assist in tracking, understanding, and improving the user experience of the Services. If you use the Analytics Platform you will be required to agree to the Appsee terms of service and privacy policy. You may find out more about how Appsee stores and uses your information by accessing the privacy policy for Appsee’s services (see https://www.appsee.com/legal/privacypolicy).

                            Service Communications. We use data we collect to deliver and personalize our communications with you. For example, we may contact you by email or other means to notify you of changes in information and updates to the Services or to our Privacy Policy.

                            Marketing and event communication: We use personal data to deliver marketing and event communications to you across various platforms, such as email, direct mail, social media, and online via the Services. We also may send you invitations to trade shows or trainings relating to the Services that occur nearby you, based on your address. Third parties may also market to you on our behalf based on your use of their third-party services. You should consult and review the relevant third-party privacy statement or policy for information on their data processing practices.

                            If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference centers for you to manage your information and marketing preferences. For information about managing email subscriptions and promotional communications, please visit the Your Rights Regarding Personal Data section of this privacy statement. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.

                            HOW WE SHARE PERSONAL DATA
                            It is the policy of Pegasus and its subsidiaries to protect users’ information both online and off-line. Access to our users’ information is restricted to only those employees or agents, contractors or subcontractors of Pegasus who have valid reasons to access this information to perform any service you have requested or authorized, or for any other purpose described in this Privacy Policy. The information you provide will not be sold or rented to third parties.

                            We may provide your personal data to:

                            • Pegasus affiliates located in and outside your country;
                            • Outsourced service providers who perform functions on our behalf, located inside or outside of your country of residence (in such case, we will use appropriate legal framework to operate data transfers). For example, when you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction;
                            • Our authorized agents and representatives, located inside or outside of the your country of residence (in such case, we will use appropriate legal framework to operate data transfers), who sell products or provide services on our behalf, such as training service providers or product resellers;
                            • Anyone expressly authorized by you to receive your personal data; and
                            • Anyone to whom we are required by law to disclose personal data, upon valid and enforceable request thereof.

                            We will access, disclose and preserve personal data when we have a good faith belief that doing so is necessary to:

                            • Comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies, upon valid and enforceable request thereof; or
                            • Operate and maintain the security of the Services, including to prevent or stop an attack on our computer systems or networks.

                            Please note that some of the Services may direct you to services of third parties whose privacy practices differ from Pegasus’. If you provide personal data to any of those services, your data is governed by their privacy statements or policies. Pegasus is not responsible for the privacy practices of these other websites. Please review the privacy policies for these websites to understand how they process your information.

                            We require third parties to only use your personal data for the specific purpose for which it was given to us and to protect the privacy of your personal data. We will only disclose your personal data to third parties who agree to keep your information confidential.

                            HANDLING OF PERSONAL DATA
                            Security of Personal Data

                            Pegasus is committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.

                            These measures include, but are not limited to, technical and organizational security policies and procedures, security controls and employee training.

                            You are responsible for maintaining the security of your account credentials for the Services.  Pegasus will treat access to the Services through your account credentials as authorized by you.  Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution.  We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.  If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

                            If we become aware of a breach that affects the security of your personal data, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, Pegasus will provide any such notice that Pegasus must provide to you at your account’s email address. By using the Services, you agree to accept notice electronically.

                            Storage and Transfer of Personal Data
                            Personal data collected by Pegasus may be stored and processed in your region, in the United States or in any other country where Pegasus, its affiliates or contractors maintain facilities. All data from the Transflo mobile applications we collect under this Privacy Policy is securely transferred through https://svc.transflomobile.com/. We take steps to ensure that the data we collect under this Privacy Policy is processed pursuant to the terms thereof and the requirements of applicable law wherever the data is located.

                            Pegasus also collaborates with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your personal data within Pegasus or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured, and transferred according to applicable law.

                            If you would like to know more about our data transfer practices, please contact our Legal Department at [email protected].

                            Retention of Personal Data
                            Pegasus retains personal data for as long as necessary to provide the services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g. statute of limitations). If your personal data is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.

                            YOUR RIGHTS REGARDING YOUR PERSONAL DATA
                            Pegasus respects your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with the Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features of the Services.

                            You can stop all collection of information by the Pegasus mobile application by uninstalling it. You may use the standard uninstall processes available as part of your mobile device. You can stop collection of information by any of the other Services by ceasing to use such Services.

                            We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details and this can be easily accomplished under the settings section of the Services or by contacting [email protected]. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact [email protected].

                            Access to personal data: In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).

                            If you are a corporate user of the Services (which means your employer is a Pegasus customer of such Services: please first request access to your personal data with your employer. Your employer will then be in touch with us with respect to your request.

                            Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law.

                            Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via e-mail, postal mail or telephone about Pegasus products, services, events, activities, and information that may be of interest to you.

                            E-mail communications you receive from Pegasus will generally provide an unsubscribe link allowing you to opt-out of receiving future e-mail or to change your contact preferences. E-mail communications may also include a link to directly update and manage your marketing preferences. If you have a web account with Pegasus, You can also change your contact preferences through the user profile and settings section of the Site or via email at [email protected]. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.

                            California Shine the Light Law:  California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year.  If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to [email protected] or write us at: Pegasus Transtech, LLC, 201 North Franklin St., Suite 1700; Tampa, FL 33602.

                            COOKIES & SIMILAR TECHNOLOGIES
                            Pegasus uses cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (“Cookies”) to provide the Services and help collect data. This Cookies Policy explains how we use Cookies to collect information about the way you use the Services, and how you can control them.

                            How We Use Cookies
                            We use Cookies to track how you use the Services by providing usage statistics. Cookies are also used to deliver Company information (including updates) and allow product authentication to you based upon your browsing history and previous visits to the Services. Information supplied to us using cookies helps us to provide a better online experience to our visitors and users and send marketing communications to them, as the case may be. Information supplied to us upon launching of the Services will enable Pegasus to manage your permissions, license, license type, and improve the functionality of the Services.

                            We may combine the information we collect via Cookies with personal data that we have collected from you to learn more about how you use the Services to improve them.

                            Types of Cookies
                            We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on the Services can be grouped into the following categories:

                            • Strictly Necessary: These Cookies are necessary for the Services to work properly. They include any essential authentication and authorization cookies for the Services.
                            • Functionality: These Cookies enable technical performance and allow us to “remember” the choices you make while browsing the Services, including any preferences you set. They also include sign-in and authentication cookies and IDs that enable you to return without additional sign-in.
                            • Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the Services or utilize the Services running on your device. They help us understand which areas you use and what we can do to improve them.
                            • Targeting: These Cookies are used to deliver relevant information related to the Services to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit the Services. Some of these types of Cookies on the Services are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to the Services.

                            Cookies Set by Third Party Services
                            To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on the Services. We currently use, and may in future use content from Services such as Facebook, LinkedIn and Twitter. You may be presented with Cookies from these third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these cookies are used and how you can control them.

                            We also use Google, a third-party analytics provider, to collect information about Services usage and the users of the Services, including demographic and interest-level information. Google uses cookies in order to collect demographic and interest-level information and usage information from users that visit the Services, including information about the pages where users enter and exit the Services and what pages users view on the Services, time spent, browser, operating system, and IP address. Cookies allow Google to recognize a user when a user visits the Services and when the user visits other websites. Google uses the information it collects from the Services and other websites to share with us and other website operators’ information about users including age range, gender, geographic regions, general interests, and details about devices used to visit websites and purchase items. We do not link information we receive from Google with any of your personally identifiable information. For more information regarding Google’s use of cookies, and collection and use of information, see the Google Privacy Policy (available at https://policies.google.com/privacy?hl=en). If you would like to opt out of Google Analytics tracking, please visit the Google Analytics Opt-out Browser Add-on (available at https://tools.google.com/dlpage/gaoptout).

                            Social Sharing
                            We also embed social sharing icons throughout the Services. These sharing options are designed to enable users to easily share content from the Services with their friends using a variety of different social networks. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these services. These services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access. If you do not want your personal data shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the Services and do not participate in social sharing through the Services.

                            Other Similar Technologies
                            Pegasus web pages may use other technologies such as web beacons to help deliver cookies on the Services and count users who have visited those Services. We also may include web beacons in our promotional email messages or newsletters to determine whether you open and act on them as well as for statistical purposes.

                            In addition to standard cookies and web beacons, our services can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally.

                            How to Control and Delete Cookies
                            Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your Cookie preferences across these environments.

                            If you are using a mobile device to access the Services, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device.

                            Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Services may not operate properly, and you may not have access to the Services available through the Services. Pegasus is not liable for any impossibility to use the Services or for any degraded functioning of that Services that are caused by your settings and choices regarding Cookies.

                            To learn more about Cookies and web beacons, visit www.allaboutcookies.org.

                            Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked.  If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Pegasus, do not respond to DNT signals.

                            CHILDREN’S PRIVACY
                            THE SERVICES ARE NOT INTENDED FOR CHILDREN
                            You must be at least the age of majority in your place of residence to use the Services. The Services are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to inform the child (or his or her parent or legal guardian) that he or she cannot use the Services.

                            California Minors:  While the Services is not intended for anyone under the age of 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: [email protected].  When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it.  We are not required to remove any content or information: (1) that federal or state law requires us or a third party to maintain; (2) that was not posted by you; (3) that is anonymized so that you cannot be identified; (4) for which you don’t follow our instructions for removing or requesting removal; or (5) for which you received compensation or other consideration for providing the content or information.  Removal of your content or information from the Services does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.

                            NOTICE TO INTERNATIONAL VISITORS
                            We are headquartered in the United States and the Services are controlled and operated from the United States. We process and store personal information in the United States, where privacy laws may not be as protective as in your place of residence. If you are using the Services from outside of the United States, by providing your personal information to us, you consent to the transfer of your personal information to the United States for processing consistent with this Privacy Policy.

                            CHANGES TO THIS PRIVACY POLICY
                            We may update this Privacy Policy based upon evolving laws, regulations and industry standards, or as we may make changes to our business including the Services. We will post changes to our Privacy Policy on this page and encourage you to review our Privacy Policy when you use the Services to stay informed. If we make changes that materially alter your privacy rights, Pegasus will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should discontinue your use of the Services. You may also request access and control of your personal data as outlined in the Your Rights Regarding Your Personal Data section of this Privacy Policy.

                            QUESTIONS OR COMPLAINTS HANDLING
                            We understand that you may have questions or concerns about this Privacy Policy or our privacy practices or may wish to file a complaint. If so, please contact us in one of the following ways:

                            Pegasus Legal Department
                            Email: [email protected]
                            Mail: Attention: Legal Department

                            Pegasus Transtech, LLC
                            201 North Franklin St.
                            Suite 1700
                            Tampa, FL 33602